Request for health care providers to be present during ICCR meetings
Submitted by Dr. Beth Jordan, ARHP Medical Director
June 19th, 2008
Good afternoon. My name is Dr. Beth Jordan. I am an internist, formerly of the Mayo Clinic, and I currently serve as the medical director of the Association of Reproductive Health Professionals (ARHP). ARHP positions itself as the leading source of trusted medical education and information on reproductive and sexual health. ARHP was founded in 1963 and is a multidisciplinary professional association with over 11,000 members, including physicians, nurse practitioners, physician assistants, nurse midwives, pharmacists, researchers, and educators, all with expertise in reproductive health research or practice. Our diverse membership embodies the health care team.
ARHP is accredited by the Accreditation Council for Continuing Medical Education to provide continuing medical education to health care providers through a variety of educational programs, meetings, and publications. We are also accredited by the Accreditation Council for Pharmacy Education as a Provider of continuing pharmacy education.
ARHP advocates for evidence-based research and supports the availability of, and education about, a wide range of safe, effective, and appropriate new technologies to enhance the health of all women.
I am pleased to be here today to provide public comment on (1) the concerns reproductive health care providers have about low dose exposure to reproductive toxins in cosmetics and personal care products; (2) the need for more research on potentially hazardous chemicals found in such products (3) the need for stronger government regulation of ingredients used in cosmetics based on the precautionary principle; and (4) recommendations to strengthen stakeholder involvement in the ICCR process.
There are mounting concerns about the safety of products the public has long thought to be safe. Just as plastic baby bottles and plastic wares have recently been called into question because of the presence of Bisphenol A (BPA), the safety of chemical compounds in cosmetics, previously thought to be safe, are now being challenged, as well. ARHP is particularly concerned about the safety of personal care products like shampoo, deodorant, shaving cream, nail polish, lipstick and mascara. These concerns stem from three areas:
- The well established and documented health hazards caused by a variety of toxicants currently in cosmetics, such as lead and mercury.
- The burgeoning body of evidence around the health hazards of specific toxicants known to be in cosmetics, such as phthalates.
- The need for additional research on specific chemical compounds in cosmetics, such as parabens, that are possible endocrine disruptors or carcinogens, but that have not been tested thoroughly enough to know their risks.
WHAT WE KNOW
We know that women of childbearing age are exposed to a variety of chemicals on a daily basis from many different sources, including personal care products, that can act as reproductive and developmental toxicants.
- In September of 2007, The Campaign for Safe Cosmetics purchased over 30 lipsticks from major cosmetics brands in four cities and sent them to an independent lab for lead testing. More than half came back with levels of lead, a proven neurotoxin. Lead can cause learning, language and behavioral problems and is also linked to infertility and miscarriage.
- Mercury is a known neurotoxin but some cosmetic companies still add it legally at low levels to some eye products as a preservative. Under federal law cosmetics may contain up to 65 parts per million of mercury. Mercury lingers in the body and builds up over time. It can pass from a pregnant woman or a nursing mother to her baby. Because they alter the way young brains develop, these pollutants can harm babies and children most of all.
We also know there is a growing body of scientific evidence that is linking toxic chemicals in the consumer products we use everyday to increasing rates of birth defects, reproductive harm and other adverse health effects. Chemical compounds like phthalates, which are known to be widely used in cosmetics, are getting national attention as the evidence emerges that they are harmful to human health.
Phthalates are endocrine disrupting chemicals. There is well-documented evidence that phthalates induce birth defects, low sperm counts, and other reproductive toxicity in experimental animals. Some studies suggest a link between delayed sexual development in boys and girls and exposure to phthalates. Boys are especially vulnerable to the effects of phthalates as they impair development of male reproductive organs.
The FDA has recommended that doctors performing certain procedures, such as dialysis in pregnant women and newborn boys, should look for alternatives to phthalate-containing devices. Yet, phthalates remain largely unregulated in cosmetics and are widely used in nail polish and fragrances.
WE NEED MORE INFORMATION
In some instances, early research points to the possible harmful effects of a specific chemical compound, but more evidence is needed to know the risks for sure. Parabens, which are compounds used as preservatives in products such as underarm deodorants and lotions, fall into this category.
In 2004, English researchers identified parabens in an analysis of 20 breast tumors. The researchers were quick to point out that the results of their study did not prove that parabens caused the breast tumors. However, recent evidence from over a dozen scientific studies has also suggested that several types of parabens can bind to an estrogen receptor and can cause estrogen-like responses. Because parabens mimic the hormone estrogen, which is known to play a role in the development of breast cancer, more research into the effect of parabens on human health is needed. In the face of scientific uncertainty and credible threats of harm, ARHP supports Precautionary Action in the form of governmental recommendations to decrease overall harmful exposure.
MOVING FORWARD USING THE PRECAUTIONARY PRINCIPLE IN GOVERNMENT REGULATIONS
According to industry estimates, consumers use somewhere between 15 and 25 different cosmetic products that can contain more than 200 different chemical compounds, the vast majority of which have never been screened for safety by the government or the cosmetic industry's safety panel.
As health care providers we believe there are steps that consumers can and should take to reduce their exposure to toxic chemicals in their everyday lives. But, above all, we believe that chemicals should be tested for safety before being used in products consumed by millions of American men, women, and children everyday. The federal government should require the FDA to use precautionary action in matters related to chemical testing for cosmetics and test all chemicals used in cosmetics for safety before approving them for the market.
RECOMMENDATIONS FOR STRENGTHENING THE ICCR PROCESS
ARHP is concerned about the known and potential harm cause by some chemicals in cosmetics. Health care providers need to be more informed and educated about the effects of chemicals used in everyday products on reproductive health and fertility so we can help our patients make good choices. In order to advocate independently for evidence-based science informing reproductive health related policy, we also need to be at the table when regulation and policy that will affect the health and well-being of our patients is being discussed. As you examine the ICCR process, ARHP makes the following recommendations on behalf of reproductive health care providers to ensure that we, and our patients, are participants in the process that will have an impact on the regulation of products that affect everyone’s health.
The ICCR process should:
- Identify ways to remove obstacles to more effectively regulating cosmetics, as opposed to working to remove safe cosmetics regulations themselves.
- Include women’s health, environmental health and other advocacy organizations at the table at all stakeholder convenings related to the activities of the ICCR.
- Solicit input directly from these and other stakeholders, as opposed to using the industry trade associations as the intermediary for communications;
- Invite stakeholder groups like ARHP and the Campaign for Safe Cosmetics to “enter into constructive dialogue with ICCR members to provide feedback and advice on priority actions and directions for future work”– a function currently described as the sole jurisdiction of “industry trade associations.”
- Invite a broad spectrum of stakeholders to serve on working groups responsible for developing proposed guidelines and policy statements for adoption by the members.
- Bring participating governments up to the highest standard possible for regulating cosmetics, not weaken existing safe cosmetics standards.