It seems that more and more these days news breaks that a commonly used consumer good is contaminated with some toxic substance. Mercury in soda. Arsenic in apple juice. Fungicides in orange juice. Lead in lipstick. GoodGuide scientists track these reports, and our inboxes fill with inquiries from concerned consumers wanting to know how bad the problem is and whether we will be including this information in our ratings. We take this job very seriously, as we know people rely on the information we provide. At first glance, it might seem easy and obvious to simply fold in new findings, but in fact, there are important questions we ask before taking this plunge. To demonstrate what I mean, I’d like to share our approach to evaluating the recent reports around lipstick contaminated with lead.
The Food and Drug Administration (FDA) has just released results of tests for lead in lipstick. Updating a 2009 study, the FDA tested about 400 lipstick products and found an average level of lead contamination of about 1.1 part per million, similar to its earlier study. However, several products had higher levels than the FDA had seen previously. Sampled products from the Maybelline (Color Sensational -125-Pink Petal) and L’Oreal (Colour Riche-410-Volcanic) brands (both owned by L’Oreal) contained lead levels above 5 parts per million (ppm), and a several other brands (NARS, Cover Girl Queen, Maybelline and Stargazer) had products with levels above 4 ppm (ppm). Lead is not intentionally added to these products by manufacturers, it is present as a natural contaminant in the raw materials used in some lipsticks.
Given that lead is a recognized developmental neurotoxin and that there is general consensus in the scientific community that lead exposure should be reduced as much as possible, how serious are these FDA findings about lead levels in lipstick? Should GoodGuide modify its health scores for lipstick products to take these findings into account? To answer these questions, we look at two main issues:
First, we determine whether there are any regulatory standards or guidelines that have been established for a toxic chemical that are relevant to the product category at issue. We tap into many resources, including the FDA, EPA, European Union agencies, and California’s Proposition 65 (which typically sets the most stringent standards regarding toxics exposure) to answer the question of whether or not there are official guidelines that could be used to assess the significance of the lead levels FDA is reporting. In the case of lead, Proposition 65 specifies that the maximum allowable daily dose of lead is 0.5 micrograms. However, this limit does not refer to the concentration of lead in a consumer product (which is what FDA is reporting), but rather to the dose a consumer could receive from customary use of a products containing lead contamination. To estimate the lead dose associated with lipstick use, additional information about lipstick application rates and skin absorption rates are needed. Other potentially relevant standards (like the US drinking water standard on lead) are also not easily applied to the FDA results, because they are based on assumptions of exposure (e.g, that people drink 2 liters of water per day) that are clearly not applicable to lipstick use. All said, there aren’t any applicable regulatory standards for assessing the level of health risk associated with the reported lead contamination in lipstick. Based on current data, it’s hard to determine whether the ingestion of lipstick residue or absorption of lipstick residue through the skin leads to significant buildup of lead. The truth of the matter is a majority of lipsticks on the market, especially those with color additives, will contain some amount of lead. At the end of the day, without a firm regulation in place to use as a barometer, it’s very difficult to incorporate this finding into our quantitative scoring algorithm (more on this later).
Beyond the regulatory and scientific issue lies the data availability issue. To ensure the reliability of our product comparisons, we are only able to incorporate contamination data into our system if we have product-level data for a large percentage of the products in the category. It would be inaccurate to say something only negative about a handful of products that have been tested in the absence of data on most of the other products in a category (because they might very well have been found contaminated if they had been tested). That’s why small sample testing reports aren’t usually incorporated into GoodGuide. In the case of lead in lipstick, the FDA appears to have done a fairly large analysis of products (400), but they are far short of actually covering the category – GoodGuide rates more than 11,000 lipsticks, lip glosses and lip balms. In an ideal world, we’d have lead concentrations for all lipsticks on our site, but such data isn’t at our disposal because lead testing isn’t a widespread practice. It’s moments like these that a category-specific regulatory standard would be incredibly useful, as companies would be incentivized to test their products for contamination. In the absence of both regulatory guidelines and relatively comprehensive testing data, we aren’t able to incorporate findings generated by the FDA lipstick study into our ratings system. Since most lipsticks appear to have some level of lead contamination, the data are insufficient to discriminate between “better” or “worse” lipsticks on this issue.
In cases where ratings aren’t modified, we share news about contamination incidents with our community. We hope this post brings clarity to how we approach some of the reports that cross our desks and welcome your thoughts below.