Can California program help tame the beast within beauty products?

The dangerous game of chemical whack-a-mole

A recent series of articles in the New York Times documented appalling conditions in nail salons that often have poor ventilation, inadequate protections, and long work days. Workers breathe in and contact toxic chemicals continuously, damaging their health, especially if they are pregnant. Indeed, a report last year from Women's Voices for the Earth, Beauty and Its Beast, summarized the many studies showing that salon workers are at greater risk of asthma, reproductive issues, and serious skin conditions because of the myriad harmful chemicals they encounter at work. These chemicals are in every day beauty products including nail polish, polish removers, hair dye, hair spray, and hair straighteners.

We've had some success in removing chemicals of concern from beauty products--for example, as phthalates gained notoriety for disrupting the body's natural hormones, many nail polishes now proudly claim to be "phthalate-free." But, in a terrible toxic trade-off, some companies replaced phthalates with another chemical called triphenyl phosphate (TPP). TPP is also used as a so-called "flame retardant chemical," and it causes heart defects, obesity, and toxicity to fish when tested on animals. Like a nightmarish version of the kid's game of whack-a-mole, when one chemical of concern is knocked down, another replacement chemical which may be as bad or worse pops up to take its place.

The goal of removing chemicals of concern from products is to make safer products and ultimately improve people's health by reducing exposures to toxic chemicals. But if a toxic chemical is removed from a product, and another equally hazardous chemical is used in its place, we aren't making progress towards this goal. This problem is christened with many names: regrettable substitution, toxic whack a mole, toxic treadmill, the toxic shell game, the chemical conveyor belt. But regardless of what you call it, the real question is: can this sick cycle be stopped? The key lies in requiring that replacement chemicals be proven safe-- before they are put into products.

And that's just what a new California program called Safer Consumer Products is trying to do-- it's the first in the nation to require an 'alternatives analysis' when replacements are used for chemicals of concern. Alternatives analysis is designed to prevent bad substitutions by evaluating potential replacements for health and environmental safety before they are used. If successful, the alternatives analysis process could finally put the brakes on the toxic cycle of chemical substitutions.

How would this work? First, the program could name "nail polish containing phthalates" as a Priority Product. Then, companies that manufacture nail polish containing phthalates would need to consider an important question: is the chemical necessary? If it is necessary (for example to achieve performance or legal requirements for the product), then the next question: Is there a safer alternative? This is where the alternatives analysis comes in.

The Safer Consumer Products process includes alternatives analysis to make sure that replacements for chemicals of concern are safer.

The alternatives analysis requires that each potential alternative be evaluated for adverse health and environmental impacts throughout the product's life cycle. The life cycle consideration is important because we want to avoid toxic trade-offs from start to finish. An example of an undesirable life cycle trade-off: a replacement chemical is less hazardous for people using the nail polish, but more hazardous to manufacturing workers making the nail polish because it releases a toxic by-product during the production process.

The idea is that through this alternatives analysis process, companies can avoid substitutions that pose hazards, while at the same time identifying those that are safer.

For a company thinking about using TPP as a substitute for phthalates, an alternatives analysis would reveal that TPP is itself hazardous to human health and the environment, and not a safer replacement for phthalates. The company would need to consider other chemicals or design changes to find a truly safer option. The company could then reformulate, redesign or otherwise change their product to eliminate the chemical of concern and utilize a demonstrated safer substitute.

Safer Consumer Products recently released a work plan which lists the product categories from which Priority Products will be selected over the next 3 years. Beauty, hygiene and personal care products are on the list, and as we saw earlier, this category is rife with hazardous chemicals which pose risks to salon workers and every day users.

Maybe alternatives analysis will be the sword to slay beauty's beast, as the method holds great promise for identifying safer substitutions for chemicals of concern. But the details matter-- in order to find the truly safer alternatives, the analysis must be comprehensive and guided by health-protective principles. Otherwise, we risk falling back down the hole of the toxic whack-a-mole.