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More Than Skin Deep:

Charlotte Vallaeys is a Farm & Food Policy Analyst at The Cornucopia Institute (, one of the nation’s leading organic industry watchdogs.

For years, consumer advocacy groups that are part of the Campaign for Safe Cosmetics have reported on toxic chemical ingredients and residues in beauty and body care products, revealing that this notoriously underregulated industry is rather liberal with its use of possibly carcinogenic and other toxic synthetic ingredients.

The news spread of potentially dangerous synthetics—so readily absorbed through the skin and yet so ubiquitous in our every-day beauty products. Consumers with an interest in avoiding unnecessary toxic exposure believed they had found refuge in body care products made with “natural” and “organic” ingredients.

A conflicted, contradictory practice

But what few consumers know is that unlike organic claims on food, which are closely regulated and monitored by the USDA National Organic Program, beauty products often use the word “organic” on labels of products that are based on conventional and petrochemical ingredients. The USDA has a conflicted, contradictory practice in not properly regulating “organic” claims on personal care products, even as it certifies qualified products.

“While responsible companies that make organic claims produce products whose main ingredients are made from organic, notconventional or petrochemical, materials, the lack of regulation means ‘Buyer Beware,’” says David Bronner, CEO of Dr. Bronner Soaps. “For some companies, the term ‘organic’ is a marketing tool with no real meaning, and consumers need to research their brands.”

The green seal

The green “USDA Organic” seal may appear only on products that are made with at least 95 percent certified organic agricultural ingredients and contain no toxic or suspected carcinogenic or synthetics.

A recent report by the Organic Consumers Association (OCA) reveals that this distinction—between many beauty and body care products using the word “organic” and those actually bearing the green “USDA Organic” seal—is significant. Using an independent testing lab, OCA analyzed various “organic” and “all-natural” beauty and body care products for residues of one toxic chemical, 1,4-dioxane.

While some of the self-proclaimed “organic” and “all-natural” products tested contained up to 30 parts per million 1,4-dioxane residues, all of the USDA certified organic products—with the green seal—were found to be free of these residues. Products certified under the German BDIH “natural” program were also clean.

Europe and the U.S.

The European Union has banned the use of known or suspected carcinogens, mutagens, and reproductive toxins-including 1,4-dioxane-in beauty products. Belgium and Germany have recalled body care products when residues of 1,4-dioxane were discovered, citing it as a health threat. The International Agency for Cancer Research classifies this chemical as a probable human carcinogen. So why is it so pervasive in Americanbeauty and body products?

In the U.S., there is no prohibition against the use of ingredients contaminated with suspected carcinogens in beauty and body care products, despite that they are readily absorbable through the skin. The FDA also does not require premarket safety testing of cosmetics and body care products, leaving it up to the manufacturers to assure that their products are safe. The FDA explicitly prohibits only seven ingredients from body care products due to their extreme levels of toxicity. Chemical contaminants that are classified as “possible” or “probable” carcinogens are allowed, as are the endocrine-disrupting phthalates (which mimic hormones).

Differing views

Scientists disagree over the level of carcinogenicity of this very common chemical. A team of scientists commissioned to review 1,4-dioxane by the Voluntary Children’s Chemical Evaluation Program writes that 1,4-dioxane “can be considered as a carcinogen in laboratory animals,” but that the evidence suggests that it is a non-genotoxic compound that requires high, prolonged dosing to induce tumors. In an article titled “An Updated Evaluation of the Carcinogenic Potential of 1,4-dioxane,” Dr. Julie Stickney suggests that the EPA “significantly overestimates the potential cancer risk from 1,4-dioxane.”

Other questions abound: some studies show that lab animals develop cancer after ingesting 1,4-dioxane, but does that mean that showering with a shampoo and body wash containing 1,4-dioxane will do harm? After all, few, if any, of us take daily sips of our suds. Few studies have been performed on the effects of dermal contact with 1,4-dioxane residues. One study did find an increase in tumors after application of 1,4-dioxane directly to the skin; other experiments did not.

But other scientists believe that the possible carcinogenicity of 1,4-dioxane through skin contact should not be taken lightly. Dr. Devra Davis, head of the Center for Environmental Oncology at the University of Pittsburgh, said in an NPR interview that “it’s classified as a probable carcinogen, so I was frankly shocked to learn that it’s present in body care products.”

It boils down to trust

As with most chemicals, we willnot find an easy answer or a clear verdict. Scientists have a very rudimentary understanding of thousands of chemicals and their effects on our health and our bodies. Our ability to produce chemicals and our understanding of how they affect the environment and public health rarely progress simultaneously; as with DDT and PCBs, we humans tend to figure out how to produce and widely distribute a chemical before we fully understand its impacts.

So for consumers, it boils down to trust. Do we trust the companies that assure us these chemicals are safe, or do we trust lessons from history mixed with a healthy dose of skepticism and caution? Industry representatives certainly would like us to opt for the first choice. John Baily, executive vice president for science of the Cosmetic, Toiletry, and Fragrance Association, an industry trade group, says, “Cosmetics are safe, whether their formulas contain synthetics or plants,” and adds, “Virtually everything we’re surrounded by carries a hazard of some sort. I think that at the end of the day the levels of 1,4-dioxane in these products do not present a risk by any scientific measure.”

And yet, while scientists disagree among themselves about the level of carcinogenicity of 1,4-dioxane, and industry tries to assuage our fears, you and I have been slathering this chemical on ourselves and our children—often every day. As a consumer, doesn’t it seem only natural and wise to question the sanity of this? The FDA would require manufacturers to remove 1,4-dioxane from products only if there is demonstrated harm. But why should the burden of proof be on the unsuspecting consumer?

This question becomes especially salient when we consider that chemical residues such as 1,4-dioxane are simply not necessary in our body care products. Plenty of companies with a true interest in the values of organics (the ecological principle, not the marketing tool) use only environmentally friendly ingredients that are safe for humans. These companies include those that market USDA certified organic products, like Dr. Bronner’s and Terressentials, and some that are not certified organic, like Burt’s Bees and Tom’s of Maine.

The true meaning of the words

We encourage all companies marketing themselves as “organic” or “all-natural” to take the necessary steps to remove these chemicals and residues from their products. “Organic” and “all-natural” can be useful marketing tools for them only as long as consumers can trust these claims and are not turned off by findings of potentially dangerous chemical residues. These companies should reformulate, or else drop the “organic” and “all-natural” claims. In response to the OCA report many companies in the natural foods marketplace have indicated that they are now doing just that.

In the meantime, consumers can use OCA’s lab results ( to learn which companies can be trusted and which use petrochemicals and questionable synthetics. The surest way to distinguish safe and truly organic products from the others is the presence of the little green seal that states “USDA Organic.”

“It’s nice to know I can trust the seal when it comes to body care products,” says Kerstin Lindgren, a member of the Harvest Food Co-op in Boston. “I couldn’t possibly remember all the brands and the ingredients that are free of toxic residues, so it helps to be able to use the green seal as a guide.”