Letter to Dr. Linda Katz, Director of the FDA Office of Cosmetics and Colors
February 7, 2012
We were pleased to see that on December 5, 2011, the Office of Cosmetics and Colors posted online the results, including brand names, of a new analysis that found lead in 400 lipsticks tested by your agency. This new report found higher levels of lead in lipstick than previously reported, and adds to our concern about the health risks of lead-containing lipstick -- a product used by millions of women of childbearing age who are unaware that they may be building up their blood lead levels each time they apply lipstick.
As you may know, on January 4, 2012, an advisory committee to the U.S. Centers for Disease Control and Prevention recommended that the CDC shift its policies to focus on aggressive prevention efforts for lead exposure i. Based on new information as well as new understanding of old data, the committee's report asserted that there is no safe level of lead for children; that the low-dose effects of lead extend beyond the neurodevelopmental realm into cardiovascular, immunological, and endocrine effects; and that the health effects of lead exposure appear to be irreversible.
The CDC committee’s report identifies imported cosmetics as a risk factor for lead exposure in pregnant and lactating women. However, the FDA study on lead in lipstick indicates that lead is also a problem with cosmetics manufactured in the US.
Many experts agree that there is no safe blood level of lead for children and pregnant women. Lead is a proven neurotoxin that can cause learning, language and behavioral problems such as lowered IQ, reduced school performance and increased aggression. Pregnant women are particularly vulnerable to lead exposure, because lead easily crosses the placenta and enters the fetal brain where it can interfere with normal development.
Lead builds up in the body over time and lead-containing lipstick applied several times a day, every day, can add up to significant exposure levels. Therefore, in the interest of public health, we urge the Office of Cosmetics and Colors to take action to reduce the amount of lead in lipstick.
We are hopeful that the Office of Cosmetics and Colors shares our goal of ensuring that cosmetics sold in America are as safe as they can possibly be. However, we are concerned about misleading statements on your web page entitled, “Lipstick and Lead: Questions and Answers.” http://www.fda.gov/Cosmetics/ProductandIngredientSafety/ProductInformation/ucm137224.htm
We first wrote to you about these concerns in January 2010, and we have not heard back from you about the following questions and concerns:
We respectfully request that the Office of Cosmetics and Colors reviews and revises the web page entitled “Lipstick and Lead: Questions and Answers” in light of our concerns.
Lastly, we are pleased to see on your web page that OCC is currently evaluating whether to recommend an upper limit for lead in lipstick. We urge FDA to take this important step to protect consumers from unnecessary lead exposures from lipstick, as requested in a letter dated Nov. 19, 2007 and signed by U.S. Senators John Kerry, Dianne Feinstein and Barbara Boxer. http://www.safecosmetics.org/downloads/Kerry-Boxer-Feinstein_letter-to-FDA-lipstick.pdf
We look forward to hearing back from you about this matter.
Founding members of the Campaign for Safe Cosmetics include Alliance for a Healthy Tomorrow, Breast Cancer Fund, Clean Water Fund, Commonweal, Environmental Working Group, Friends of the Earth, Massachusetts Breast Cancer Coalition, National Black Environmental Justice Network, National Environmental Trust and Women's Voices for the Earth. www.SafeCosmetics.org
i January 4, 2012. “Low Level Lead Exposure Harms Children: A Renewed Call for Primary Prevention,” Report of the Advisory Committee on Childhood Lead Poisoning Prevention of the Centers of Disease Control and Prevention http://www.cdc.gov/nceh/lead/ACCLPP/Final_Document_010412.pdf