A Case Against the EWG

Source: the Environmental Working Group

Source: the Environmental Working Group

Misinformation - one of the biggest challenges I see in the cosmetic space today. There’s so much fear and mistrust, I find this is seriously stunting our ability as an industry to do better. Instead, we’re bending to the fear-mongering trends to appease consumers. Here in North America, one of the bigger drivers for this misinformation, fear and mistrust is the Environmental Working Group (EWG), an organization that coins themselves as science based, but seems to always be complacent with half truths. It really irks me to see them constantly referred to as reliable, even from Universities. They are not, and we need to be thinking more critically about the information we receive from them. This blog post will be a case against the EWG. Before you exit this page because you’re now feeling like I’m part of the problem, another industry member okay with ‘poisoning’ consumers at large, I would just urge you to read through my points. Disclaimer, I am a neutral scientist with no brand affiliation - outcomes of this topic has zero implications on the work I do. You can be assured that I’m not spinning the research and conversation for a company's favor.

Who is the EWG?

According to the EWG, they are an American activist group that specializes in research and advocacy in the areas of agricultural subsidies, toxic chemicals, drinking water pollutants and corporate accountable. They are a nonprofit organization, founded in 1993 be Ken Cook and Richard Wiles, headquartered in Washington DC. For their role in cosmetics, they certify companies, are active politically, and have their own Skin Deep Database - a place where you can find a hazard scores for ingredients used in your cosmetic products. 

Unbeknownst to consumers, they are heavily funded by the organic lobby. For example, in the fiscal year of 2015, they raised nearly $13.7 million and spent $12.5 million, with their president Ken Cook earning $289,022 in reportable income. Their certifications are not cheap for brands, but they’ve got such a rapport with consumers, even larger companies like Procter & Gamble with Herbalescense, are jumping on the bandwagon. Fear mongering is an incredibly effective strategy to sell products. A general flaw for us humans at thinking critically, we’re emotional decision makers. When someone, especially when they’re propped up on a pedestal, tells us that natural products are safer (or greener), that your products are killing you, that cosmetic scientists are evil and corrupt, well it would be dangerous not to believe them…   My friend Sam Farmer put it perfectly “they’re using consumer ignorance of cosmetic science - and ignorance isn’t a bad thing here, of course, consumers don’t have a background - to sell products and make money.”  The EWG also makes money through their affiliate programs. “Here is the Aveeno Active Naturals Radiant Tinted Moisturizer with a rating of 10. A 10 rating is the most dangerous product that can be found in the Skin Deep Database (according to them). But if you click on the picture they’ll be happy to have you buy the product through their affiliate program.” - Perry Romanowski, Chemists Corner

Source: the Environmental Working Group

Source: the Environmental Working Group

In a podcast I did with Perry Romanowski and Belinda Carli, director at the Institute of Personal Care Sciences, we talked about how effective fear mongering is at making money in the cosmetic space, and why this is a problem. Tune into the podcast below.

Who isn’t the EWG?

Source: the Environmental Working Group

Source: the Environmental Working Group

An organization that reflects the opinions of the scientific community. A decade ago, George Mason University surveyed about 1000 members of the Society of Toxicology, a professional association of toxicologists. Just about 80% of them felt that the EWG overstated the risks of chemicals. Toxicology, the area of science that is directly relevant to the ‘toxic’ impacts of different agents… a profession that the EWG would be well served to include in their staff. Ultimately, the outcomes of this survey indicate that the EWG’s views DO NOT represent the majority of scientific views on the health risks from chemicals.

EWG’s Skin Deep Database - a showcase of poor interpretation of science and straight up bias. Alas, it’s the dose that makes the toxin. Anything can be a hazard - even water if you drink enough. It’s obvious that they simply have a preference for natural, which you’ll be hard pressed to find negative points on… Even when there’s strong evidence to support an ingredients safety, they are seemingly unwilling to change their ratings. I.e. there’s a few or even just one study that indicates danger… let’s ignore the bulk of the data and just focus on this one study, regardless of methods or if it’s been replicated. There’s a name for this. They are cherry-picking data, only using science when it supports their beliefs, a hallmark for quacks. To my understanding, the EWG NEVER changes their stance on a cosmetic ingredient. Something to remember here - they are also political. It doesn’t look that great to consumers if you change your opinion.

In a podcast interview I did with Dr. Mojgan Moddaresio, Cosmetics Safety assessor and Cosmetic compliance expert, in addition talking about how cosmetic product safety is determined by scientists, we also talked about the EWG. Big take home, risk assessment is NOT the same as hazard assessment - a toxicological fundamental that the EWG quite obviously ignores. Tune into the podcast below.

“Another criticism of the EWG database is that the ratings demonstrate a lack of understanding of the raw materials they are rating. For example, they list SODIUM COCOYL SULFATE and give it a zero rating with zero data. They also have a listing of SODIUM LAURYL SULFATE and give it a 1-2 rating with a “fair” amount of data. This makes no sense. Anyone who knows chemistry knows that Sodium Cocoyl Sulfate is essentially the same thing as Sodium Lauryl Sulfate. Here’s a good explanation why.” Perry Romanowski, Chemists Corner

A Case Point Example from the Skin Deep Database: Methyl Paraben

Rated at 4, a moderate health concern, the EWG states that endocrine disruption is of a HIGH concern, and biochemical or cellular level changes is also a MODERATE concern. Below was taken from the Skin Deep Database.

Source: EWG Skin Deep Database

Source: EWG Skin Deep Database

 In light of consumer concerns with endocrine disruption, despite it’s only moderate health risk rating, it’s easy to see why consumers would take this information as a reason to avoid it. You hear this everywhere - ‘parabens cause endocrine disruption and are linked with breast cancer’, pointing to sources like this as a ‘see, the EWG agrees’, here they say that there’s strong evidence of endocrine disruption. Listed as their reference for strong evidence, the European Commission on Endocrine Disruption - I spent quite a while looking for their source information and couldn’t find it… it’s hard not to draw conclusions on the fact that they chose not to put a hyperlink to make it easier to find their source information. I couldn’t even find it in the list of references at the bottom of the page. Perhaps I’m missing something, so if you find this source, please send it my way. I think that it’s funny that they include the Opinion on Parabens (2011) from the Scientific Committee on Consumer Safety in their references, granted the information from this source wasn’t even expressed in the rating.

Taken right from the above reference

  • “With regard to their general toxicological profile, acute, subacute and chronic toxicity studies in rats, dogs and mice have proven parabens to be practically non-toxic, not carcinogenic, not genotoxic or co-carcinogenic, and not teratogenic (SCF 1994).” 

  • “After thorough study of the available knowledge, the SCCP concluded that there was insufficient data to establish a link between the use of underarm cosmetics and breast cancer (SCCP/0874/05).”

  • “In summary, the in vitro data and in vivo rodent test results up to 2005 indicated that parabens can exert estrogenic activity, but with potency values that are 3 to 6 orders of magnitude lower than the potency of the positive control 17β-estradiol. The estrogenic activity of parabens appears to increase with increasing chain length.” 

  • “In vitro studies show the potential of endocrine modifying effects of parabens, with estrogenic activity as a function of chain length. PHBA, the common metabolite does not seem to exhibit endocrine modifying effects.” 

I’m sorry, but did they read the same article that I did????

In reality, here’s what we know about the parabens approved for use in cosmetic products.

In 2004, a study in the Journal of Applied Toxicology found parabens in breast tumors. Note, levels were not compared to normal breast tissue, a major limitation… journalists reporting on this study drew their conclusions based on assumptions. Today, parabens are thought to be weak estrogen mimics and potential endocrine disruptors, implicated in a variety of hormonal related problems and diseases. In my research through the available literature, most of the conclusions related to adverse health effects were made from anecdotal assumptions or had unrealistic methods. What do I mean? There hasn’t been a replicated study (and there's been many studies) to show that parabens cause endocrine disruption (especially at the dosage in your cosmetic products) in humans, and there hasn’t been a study that concluded with significant evidence that these chemicals cause the above health issues. Just because it's seen in tissues doesn't mean it's causing harm. Correlation does not mean causation.

Today, parabens are one of the most rigorously tested ingredients in cosmetics and time and time again are demonstrated to be safe. E.g with respect to endocrine disruption, while parabens are a weak estrogen mimic, Butylparaben (one of the more estrogenic parabens, reminder from above, these effects increase with carbon chain length/branching) is 10,000 times less potent than estradiol, which they would have to compete with to bind receptors to have an estrogenic effect....

Despite the implications from the Skin Deep Database, that there’s moderate evidence for allergenicity and toxicity, parabens are frequently cited in scientific literature as the least allergenic of preservatives. In fact, in the Cutis Dermatological journal, parabens were nominated the 2019 Nonallergen of the Year.  Parabens have been seen in our urine... From a toxicological standpoint, seeing something in your urine is actually a good thing in many cases - this is an indication that it readily passes through your body. Parabens have been demonstrated to be non-accumulative in tissues. Did you know parabens are also found in many of our foods naturally? Carrots and berries, for example, naturally contain parabens.

With all the fear, the cosmetic industry has responded, making swift steps away from parabens to other less tested, or sometimes demonstrably less safe preservatives…. Harder to fear monger names less recognizable for consumers. THIS is a concern.

 

There’s so much more to unpack here, such as the EWG’s straight up BS on sunscreens, but to avoid writing a novel, I’ll leave this article here. I would like to see my industry be better, be more sustainable especially, but to do this, we need to be relying on science and not pseudoscience. A call to action - be critical of your information sources. Even (especially) giant NGO’s can be guilty of spreading misinformation for financial gain



References

  • Adoamnei, E et al. (2018) Urinary concentrations of parabens and reproductive parameters in young men. Science of The Total Environment, 621:201-209.

  • Berger, K et al. (2018) Personal care product use as a predictor of urinary concentrations of certain phthalates, parabens, and phenols in the HERMOSA study. Journal of exposure science & environmental epidemiology. 1.

  • Bledzka D et al. (2014) Parabens. From environmental studies to human health. Environmental international. 67:27-42.

  • "Charity Navigator Rating - Environmental Working Group". Charitynavigator.org. Retrieved 2011-03-30.

  • EWG 2015 Annual Report" (PDF). ewg.org. 2015-12-31. p. 12. 

  • Crovetto, S et al. (2017) Bacterial toxicity testing and antibacterial activity of parabens. Toxicological & Environmental Chemistry, 99(5-6):858-868.

  • Darbre P.D., Aljarrah A., Miller W.R., Coldham N.G., Sauer M.J., Pope G.S. Concentrations of parabens in human breast tumours. J Applied Toxicology 24(1), 5-13 (2004a). 

  • Darbre P and Harvey P. (2014) Parabens can enable hallmarks and characteristics of cancer in human breast epithelial cells: a review of the literature with reference to new exposure data and regulator status. Applied toxicology. 34(9):925-938.

  • Engeli, T et al. (2017) Interference of Paraben Compounds with Estrogen Metabolism by Inhibition of 17β-Hydroxysteroid Dehydrogenases. International journal of molecular sciences. 18(9):2007.

  • Hafeez F and Maibach H. (2013) An overview of parabens and allergic contact dermatitis. Skin Therapy Lett. 18(5), 5-7

  • Haman C et al. (2015) Occurrence, fate and behavior of parabens in aquatic environments: a review. Water research. 68:1-11.

  • Campbell, H (2018). "Environmental Working Group Abandons Independent Pretense And Puts Another Industry Executive On Its Board". American Council on Science and Health. 

  • Jurewicz, J et al. (2017) Environmental exposure to parabens and sperm chromosome disomy. International journal of environmental health research, 27(5):332-343.

  • Kolatorova, L et al. (2017) The Exposure to Endocrine Disruptors during Pregnancy and Relation to Steroid Hormones. World Academy of Science, Engineering and Technology, International Journal of Medical and Health Sciences, 4(11).

  • López-Ortiz, C et al. (2018) Fate of parabens and 4-hydroxybenzoic acid in aquifer materials columns during step experiments with fresh and sea waters. Journal of Hydrology, 557:335-347.

  • Moos, R et al. (2017) Daily intake and hazard index of parabens based upon 24 h urine samples of the German Environmental Specimen Bank from 1995 to 2012. Journal of Exposure Science and Environmental Epidemiology, 27(6):591.

  • Niederberger, C. (2017) Re: Human Semen Quality, Sperm DNA Damage, and the Level of Reproductive Hormones in Relation to Urinary Concentrations of Parabens. The Journal of Urology.

  • Reeder M, Atwater A. (2019) Parabens: the 2019 nonallergen of the year. Cutis 103(4):192-193.

  • Sasseville D et al. (2015) “Parabenoia” Debunked, or “Who’s afraid of parabens?” Dermatitis. 26(6):254-259.

  • Scientific Committee on Consumer Safety SCCS. (2005) Extended Opinion on Parabens, underarm cosmetics and breast cancer. Directorate-general for health and consumers.

  • Scientific Committee on Consumer Safety SCCS. (2010) OPINION ON Parabens. Directorate-general for health and consumers.

  • Smarr M et al. (2017) Urinary concentrations of parabens and other antimicrobial chemicals and their association with couples’ fecundity. Environ health perspect. 154(4):730-736.

  • Song, C et al. (2017) Removal of parabens and their chlorinated by-products by periphyton: influence of light and temperature. Environmental Science and Pollution Research, 24(6):5566-5575.

  • Zulaikha S et al. (2015) Hazardous ingredients in cosmetics and personal care products and health concern: a review. Public Health Research. 5(1):7-15.