I have written an article in some length about the use of Micronized Minerals in mineral makeup and its effect on creating nano-sized particles within this process. For some this has been a long time concern and I couldn't agree more to a certain extent. But now we are faced with a whole new complication caused by certain watchdog groups.
The question remains; is titanium dioxide safe when used in Mineral Makeup?
Yes...it is! It isn't as simple as nano particles or whether or not titanium dioxide will cause cancer. It is about the facts surrounding the safe use of this ingredient in mineral cosmetics, sunscreens, and food products, and the disinformation sprinkled throughout with unsubstantiated research.
What has most recently occurred in this past year, the Environmental Working Group has been working in unison with the Campaign for Safe Cosmetics to fundamentally use a broad stroke to demonize many cosmetic ingredients that have been used for generations without complication or incident.
Although I strive to create products that meet or exceed safety demand for the finest and safest ingredients, I am still faced with the difficult decision to withdraw from the campaign. I continue to stand by what I and other Indie manufacturers have done by creating products in all facets of beauty as an alternative to the big box companies utilizing a compilation of synthetic chemicals in their formulas. And my products and philosophy speak for themselves. As an Indie company, we have been swept into the melee of these two entities trying to create FDA Legislation which could make it virtually impossible for small cosmetic manufacturers to exist. I find it contradictory to further support an entity that wishes to create instability within the industry and undue paranoia among consumers. What I once felt was an excellent entity to support Indie manufacturers philosophy, has now in my humble opinion, become tainted and the ramifications of their actions will be far reaching.
I Attempt To State My Position
I have been in contact with the campaign for safe cosmetics via email and have expressed my concerns. I requested an explanation of why I am seeing safety ratings for Titanium Dioxide being reclassified from a 1 to a 5-8 depending on usage. Unfortunately, this is where the broad stroke is being painted as a one size fits all mentality. Further research is required and based on the research that I have reviewed most of their claims are unfounded and have yet to be proven unequivocally. Furthermore, most ingredients also reflect huge data gaps which should pose the question, "how they arrive at their analysis achieving these ratings with so little information?" Also be aware that the campaign clearly states that even with a low safety concern rating, they are not necessarily stating a particular ingredient is safe creating further confusion for the consumer.
I have stated my arguments with this entity and advised them as long as they continue to use our memberships to support their agenda against those who are diligent in creating the safest products to date, then I in good conscience could no longer be affiliated with them. They further advised me they are working on trying to expand the data base to include different types of processed ingredients. When and if they do practice fair reporting then I may reconsider my position.
It was explained to me they are not discerning between TiO2, Micronized Titanium Dioxide versus Non-micronized Titanium Dioxide. They are being classified as one in the same. I find this level of intolerance for certain ingredients to be inexcusable and irresponsible reporting. It further dismays me the level of concern it has raised with several customers recently. However, once explained what is happening right now within the watchdog groups and the difference between these types of minerals, their concerns were alleviated. It is myself and others within my industry whom have a growing level of contention with watching ingredients which were once determined safe now achieving safety ratings of 3 or higher. (medium to high level of concern)
This now includes examples of essential oils and other herbs and botanicals that have been used for years in holistic remedies. Whereby your favorite soap company or skin care line created by an Indie will also be affected if they create an aromatherapy or healing soap bar or cream for the skin.
During my conversations with the Campaign they confirmed the higher rating was completely based on usage of TiO2, which is micronized (nano size) Titanium Dioxide used primarily in liquid foundations and sunscreens where transparency is essential to avoid whitening of the skin. However, they are refusing to convey this tidbit of information to the consumer and have not done any research on mineral makeup to date, but are strictly testing and researching liquid sunscreen safety and synthetically formulated foundations where this ingredient is used extensively. Furthermore, the exposure levels are consistently higher for those exposed at a manufacturing level and this is also not explained in the report to the casual user. Mineral Makeup correctly designed will not be absorbed by the skin but will sit on top of it and refract UV Rays away from your face. This is the research necessary in order to stipulate differences and not be absolutely so black and white in their theories.
There are only a small number of companies that may use this in their mineral makeup products and of those they have recently changed their formulas to not include TiO2 any longer, including one of my competitors, Jane Iredale. This type of Titanium has proved to not be as effective in mineral makeup since you cannot achieve the level of coverage women and men are seeking. This includes micronized Zinc Oxide. And after all, isn't that the whole point of clean mineral makeup needing to be equivalent in coverage as a liquid foundation without using all the gunk?
Unfortunately, this argument falls on deaf ears since their agenda is to actually target big box companies which may abuse the safety standards in targeted products by the CFSC. This endeavor could be considered commendable, but what they are proposing may come at a very high price, sacrificing the Indie manufacturer. We will become the casualties of this war and the campaign will be eliminating the cosmetic manufacturers which have showed support of their efforts to bring us to where we are today. Their agenda will only allow for big box companies to get bigger and eliminate your choices as a consumer. You can learn more about FDA Globalization Act of 2008 at this Link (FDA Article) and still sign the petition if you find this legislation to be too broad scoped.
Support A Cause For Choice
We all appreciate the support of our customers as we feel these issues should be dealt with a discriminatory scalpel mindset.... not an axe, bloodying the entire industry! So right now it is a wait and see game with the FDA and the EWG and the Campaign for Safe Cosmetics to see if there will be compromise and clear parameters set forth in the draft before the House Committee. Hopefully, fair play will be set forth to develop growing Indie businesses, not shove them into a position of having to close their doors.
Please rest assured that my company, Sterling Minerals Cosmetics, will continue with safety standards above and beyond what is required by the FDA, the European Union Cosmetics Directive (EU) and the requirements as set forth by Japans industry since we wish to continue to ship globally. We will always remain compliant in our formulations as an FDA Registered Company, always continue with full disclosure of our products through Truth and Labeling Practices, and to be involved at a legislative level within my own state. I am currently liaison for my state to the Indie Beauty Network who is working diligently on most of the Indie cosmetic companies behalf, meeting with legislators in Washington D.C. And I will keep you informed as this proposed legislation moves forward or if it should move forward. In the meantime, if anyone has questions, please don't hesitate to either comment here or write to me directly through our website.
Enjoy your weekend and know that you are using the safest form of cosmetics to date for your overall skin health. Conscientious Indie Companies wouldn't have it any other way!
So please relax and enjoy a nice cup of joe as our warm weather gives way to Mr. Jack Frost!
UPDATE 2/24/2010: Please follow the latest story. The FDA Globalization Act of 2009! It has been a victory for the INDIE manufacturer of skincare products and mineral cosmetics. So far, congress has listened to the issues and they are treating the small business entities with fair practices with setting new regulations that allow us to remain in business.
Also, It appears that the Campaign For Safe Cosmetics is making some adjustments in their ingredient categories and separating out the varieties of different types of processed minerals, botanicals and essential oils.
However, with this new scoring, they are also assessing safe ingredients with wide range of scores based on bad science with the practice being reflected to date with huge data gaps. This practice is still unacceptable and will not draw my support.
The campaign is striving to attack this on a state by state basis to enact laws within each state making it impossible to provide products in these states. This will be to the detriment of their own economy and provide zero benefit to the consumers. If these laws pass as written in their current form, a consumer will have few choices since most to all will be gone from their store shelves.
Also companies that support the campaign will also be in violation as most use ingredients which are deemed carcinogens and neurotoxins according to CFSC. Somehow I don't believe they understand the full scope that by signing their name to the compact has actually done to their bottom line. The campaign for safe cosmetics is striving to become the recognized surveyor of all that is harmful with little actual evidence to support their theories.