September 27, 2016
[Curt Breneman, dean of the School of Science, recently sat down with News Channel 13 reporter Benita Zhan for a report on the safety of personal care products. The topic has been in the news as Congress considers legislation that would authorize Food and Drug Administration oversight of cosmetics, against a backdrop of recent accounts of cosmetic and hair care products with adverse effects. Breneman is a chemist. He earned his doctorate from the University of California at Santa Barbara in chemistry, with an emphasis on physical organic and computational chemistry. His research is in the field of computational chemistry and predictive cheminformatics, with emphasis on computational drug discovery methodology and materials informatics methods. This guest post summarizes the key points Breneman made in his interview, and some of the advice he has for consumers.]
Just because it’s natural, doesn’t mean it isn’t chemical.
Everything has chemicals in it, it’s just whether we choose to define them as chemicals or not. Natural products are particular natural occurrences of chemicals. When you talk about safe, natural, chemical-free things, they really don’t exist as such. There are chemicals in everything.
Historically, we’ve come to believe that there are lot of things in nature, for example, aloe vera, that provide us with benefits. Generally speaking, we believe that it’s a good thing to put on burns, because we have a lot of history around that usage. But if you think about it, that’s a clinical trial in the large. In the absence of some kind of way of controlling that study, it could be wishful thinking, it could be a placebo effect, but I doubt it, because it has persisted as something that is considered a good thing.
And some other things, for example soy, have chemicals most people aren’t even aware of. Soy, which is the basis for some products, contains estrogenic compounds, and those are considered an environmental pollutant outside of their natural uses.
So natural doesn’t always mean safe. The real question is: how well controlled is it? Herbal supplements, for example, have active ingredients. But how much of each ingredient? I don’t know that they’re always assayed, and the answer is that they’re probably not. When we take pharmaceuticals, we know they have a particular molecule in a particular concentration. With supplements, cosmetics, and personal care products, who knows exactly?
Even safe ingredients and compounds can have adverse consequences when combined.
There is a list of things that are called GRAS, “generally recognized as safe.” If you put all that stuff in a product, technically it should theoretically be safe. But it’s a different story when you begin to combine compounds and ingredients.
For example, we’ve all seen FDA warnings on prescription drugs that say “tell your doctor if you’re taking supplements.” Even though it’s a natural supplement, it may contain a bioactive compound in an unknown concentration that could theoretically affect the action of a prescribed drug.
You can even do this dietarily without intending to do so. If you’re taking something like Coumadin (warfarin) for blood-thinning, you have to watch out for other things that have vitamin K in them, like kale (or other dark green vegetables). That’s a case where a natural product can influence the effect of a pharmaceutical agent.
Even combinations of over-the-counter drugs can yield adverse results. For example, it’s not a great idea to take Tylenol and aspirin together, even though individually, both are considered safe at a certain level.
When it comes to personal care products, the issue is that we really don’t have a good idea of what sorts of chemical combinations are safe except by experience. Right now, if you consume natural products that are generally considered safe and there’s a cross-reaction, there’s no agency that I know of that can come in and say, “we can see that that’s bad, you can’t do that.” So there needs to be some mechanism by which, if an adverse effect occurs, the cause can be understood, controlled, and the product possibly taken from the market.
Cosmetics, supplements, and personal care products aren’t subject to the same review as pharmaceuticals. Their contents are not overseen by a government authority, and they are not subject to safety and efficacy testing overseen by a government authority.
Very few packaging claims on personal care products are verified by a government authority. For example, the claim “organic” is now overseen, and it has a definition that we can go back to. But claims like “natural,” “chemical-free,” “gentle,” and even the ingredients listed on the bottle are not overseen at this point.
When we see those claims, we’re taking their word for that, and we don’t have clear definitions for those claims, and we don’t know that an assay has been done on the ingredients. The manufacturers are trying to let you know how they want you to view their product, but we have no specific evidence against which to weigh that claim.
We also have no way to address the safety of these products. Historically, there have different kinds of voluntary testing to determine some effects, such as the effect of substances on sensitive tissues. There’s a pressure not to do that because we don’t want to subject animals to this, but some of these tests have become computational, so that no animals are involved in the tests. Regardless, those tests were voluntary.
Currently, we put something out there and subject humans to it as an uncontrolled and uninformed clinical trial in the large, and then see what happens. If we’re going to do that, as we do with products every day, if a problem comes up, there has to be a way of addressing it. I’m not suggesting that cosmetic or personal care products have to go through the whole clinical trial process that pharmaceutical companies have to go through when a new potential drug is being tested. Because then you would probably end up paying $600 for your face cream — and it may or may not make it incrementally safer. But you really want to have a way of addressing problems that arise.
From the perspective of manufacturers, generally I would think they would want to have that brand protection – they would want to have the consumer confidence that there’s somebody out there who could help if there is a problem so that they can trust what they’re getting.
Government regulation can offer a mechanism to report adverse effects, control them, and, if necessary, remove them from the marketplace.
There should be, in my view, a mechanism by which government can respond to reports of adverse effects, in a relatively quick way. Because otherwise what we have is uninformed consent. Someone buys something assuming its safe — because we assume a lot of things when we go to a store — but really this is the same thing as having gone to a drug trial and having been told, ‘here’s a pill, we’re not going to tell you what’s in it and we’re not quite sure what it’s going to do to you.’
I’m generally in favor of rational regulation if there’s a reason why something should be regulated, or if a mechanism can be put in place to protect the public. In my view, this could be done without necessarily causing any front-load costs on a company. This would only be something that would create a mechanism by which problems could be addressed.
For the moment, the safest option probably lies in an established record.
My advice would be to go for the simpler things that have been proven over time. I look for things that have a known track record or that I’ve used over the years without problems. If I’ve heard of something causing a problem, I would tend to be very wary of that.
When I shop, I generally look at things I know and have used. And I lean toward things that don’t have a lot of added dyes or fragrances. That’s my personal preference.