by Brian Malkin
On February 7, a week before Valentine’s Day, Janet Nudelman, representing the nonprofit coalition of environmental- and cancer-prevention groups, the Campaign for Safe Cosmetics (“CSC”), once again wrote to FDA, asking FDA to take follow California and Canadian health authorities and set safe limits of lead in lipstick. The letter notes that while FDA maintains certain information on its website about lead in lipstick, e.g., a “Is there lead in lipstick?” page and December 5, 2011 updated “Lipstick and Lead: Questions and Answers” page, FDA has not conducted a formal assessment of lead in lipstick nor determined safe limits.
FDA’s Questions and Answers explains that while FDA sets specifications for lead in color additives used in cosmetics (currently no more than 20 parts per million (“ppm”), FDA does not set limits for lead in cosmetics nor conduct any pre-market approval of cosmetics that could lead to uncover total amounts of lead in lipsticks. FDA stated that since the 1990s it has been aware of traces of lead in lipsticks, which was highlighted again principally by CSC in 2007. As a result of CSC’s report, FDA tested in 2007 some 400 lipstick brands, concluding none of them were unsafe, falling all below the more conservative 5 ppm limit recommended by the State of California and below the 10 ppm limit set by Health Canada, which has draft guidelines on impurities in cosmetics. The original study appeared in a July/August 2009 Journal of Cosmetic Science article.
FDA updated its data from a survey of lipsticks from February to July 2010, which will be published in the May/June 2012 issue of the Journal of Cosmetic Science, FDA’s Questions and Answers states. What concerned CSC was that left without specific FDA guidelines or lead limits, lead levels in some lipsticks have more than doubled when compared to the maximum amounts found in 2007 (e.g., in 2007, Cover Girl/Procter & Gamble and Revlon sold lipsticks with just over 3 ppm lead, whereas in 2010, Maybelline/L’Oréal sold brands with 7 or more ppm (exceeding the California guideline but still less than Health Canada), despite a majority having levels below 5 ppm). Also, CSC pointed out that FDA’s study demonstrated that it is possible to manufacture lipsticks with lead levels as low as 0.03 ppm, suggesting that FDA could limit lead levels to below Health Canada’s limits, perhaps approaching the 0.03 ppm mark. CSC analogized this to maximum allowed lead limits in candy that is set to 0.1 ppm “not because that limit is considered safe but because FDA determined that level to be the lowest level candy manufacturers can feasibly achieve.”
CSC posted an article from Forbes author Amy Westervelt on its website February 7, that included a quote from the Personal Care Products Council that represents L’Oréal and other cosmetic companies:
Lead is never used as an intentionally added ingredient in or as an additive to lipstick. However, because lead is found naturally in air, water, and soil, it may be also found at extremely low levels as a trace contaminant in the raw ingredients used in formulating cosmetics, just as it is in many thousands of other products.
Westervelt goes on to note that the Environmental Protection Agency limits drinking water to 15 parts per billion, the Centers for Disease Control and Prevention issued a recent report asserting that there is no safe level of lead for children, as well as other expert opinions finding pregnant women particularly vulnerable to lead exposure because lead easily crosses the placenta and enters the fetal brain, where it can interfere with normal development. In addition, experts have pointed out that lead exposure builds up over time rather than being eliminated from the body.
So, with all this information in mind, this leads us back to wonder, will Valentine’s Day kisses lead to lead exposure? Perhaps it depends on whom you kiss and what lipstick they are wearing.