What Is a Safe Cosmetic?

Nobody wants unsafe products but when it comes to cosmetics how easy is that to achieve? Well, depending on where you set your boundaries that can be almost impossible and in some cases your cosmetics could be the dangerous groceries you buy! Surprised? Well, while we understand that the term 'safe cosmetics' contains an adjective and a noun - the subject is the cosmetic (a product for making us beautiful on the surface) and the describing word 'safe' meaning that the 'cosmetic' should be at low risk of causing harm, placing people in danger or injuring them. We often forget that in the case of a cosmetic, this is a dynamic relationship and that is why the safety of a cosmetic is a moving target.
Just like your fresh fruit and veggies, your chocolate bars, your ice cream and milk, cosmetics don't last forever. Sometimes they don't even last for the duration of the shelf-life which sucks when you have spent a fortune buying them but unfortunately it is true. While it is usual and inevitable that a cosmetic product will change over time a perfectly wholesome and 'safe' cosmetic can become anything but once it goes past the point of no return. So, to fully answer the question and find out what a safe cosmetic really is we need to address the following:

1. The purpose.
2. The Ingredients and their relationship to each other.
3. The Manufacturing Process.
4. The Packaging.
5. The Testing (Evidence)
6. The Storage Instructions throughout the supply chain.
7. The Use-instructions.
8. The Disposal.

This list constitutes a sort of life-cycle analysis of a typical product and as such will give us a much better rounded appraisal of a product safety and while it may not be water tight, it is a darn sight better than coming at it from just one-dimension.

1. The Purpose.

Before a cosmetic product gets off the paper the creator needs to understand what they are trying to achieve. Are they creating a babies nappy balm, a lipstick, a hair dye or mascara? This sounds silly but it isn't as the cosmetics industry has rules and regulations that apply the safety of any given ingredient to the way and place in which it is to be used. For example, colours such as N-Substituted derivatives of p-Phenylenediamine (a component of HENNA) are allowed up to 6% in hair dyes if the pack contains a set of warning phrases but they have no place in Mascara of products for use around the eye area such as eyebrow dyes or colourants. The safety has been assessed in an applied setting so understanding what you are creating is not as silly as it first seems.

2. The Ingredients and their relationship to each other.

It never ceases to amaze me how many people develop brands without a knowledge or appreciation of the chemistry that goes into making a product safe. Each ingredient put into a product has the ability to react with the others making the finished product more or less safe than you intended. Some ingredients de-activate preservative systems, some form nasty by-products, some speed up oxidation and others are just plain old irritating without something to calm them down. An old but good example of this is with Sodium Lauryl Sulphate (and its milder cousin Sodium Laureth Sulphate). These pretty efficient (AKA Harsh due to their defatting nature) surfactants can be made much milder with the addition of Cocamidopropyl Betaine. You may say "Why use a harsh surfactant in the first place" which sounds valid until you understand that the efficiency of SLS/ SLES means that you have to use less which means that the overall formula may be more efficient, less irritating and less environmentally impactful than a blend made up with more mild surfactants.

3. The Manufacturing Process.

This again is very important and takes into account things like GMP (Good Manufacturing Practice) and ingredient interactions caused by excessive heat, mixing or pH changes. A theoretically safe product can turn to high-drama if it is made in a dirty plant and your beautifully mild and natural preservative may be worthless if it is not kept below a certain temperature and buffered at the right pH. The same goes for actives - especially things like Retinol that has to be manufactured in an airless environment to maintain any integrity.

4. The Packaging.

Again it is imperative that the packaging is clean but packaging also plays a huge role in how the end-user interacts with your goods. Some products such as sunscreens benefit from being in a format that facilitates delivery of a large dose (pump packs, squeezy bottles etc) as the product is ONLY safe if the consumer uses enough of it but products such as AHA face serum should only dispense a small dose that is hard for children to access. Further, we have all heard stories of people who picked up the hair removal cream instead of the conditioner - being able to safely identify a product when you have a soapy head and water in your eyes is crucial if that is where you are to use the product.

5. The Testing.

So, before you go out to the market you test your product for efficacy and shelf life right? Not necessarily..... In some countries product testing is not mandatory for ALL cosmetics (sunscreens are always tested) but that doesn't mean it is not a good idea. While ingredient suppliers give you efficacy data to back up claims involving their ingredients they don't know what else you have in your product so running tests to prove that your cosmetic doesn't irritate people or give them pimples or burns is essential if you are claiming a 'safe' product. On top of that Preservative Efficacy Testing and Stability Testing are a must if you want to ensure that the stuff inside the pack remains 'safe' for the duration of its saleable life as is an assay of actives.

6. The Storage Instructions throughout the supply chain.

It is not unusual for people to store things such as lip balms, sunscreen and hand-cream in hot cars and use them on the run. Further, if you are exporting it is likely that your containers will sit in the hot sun for hours if not days as they make their way across the continents. Then there's the in-store experience which includes UV light, heat and copious dippings of fingers. From time to time it is possible to see peroxide bottles jumping off the shelf due to them being stored in the window of a general store and it is very common to see once red shampoos and hand washes turn clear due to the interaction between the dye and light. Therefore a 'safe' cosmetic is one that understands how it performs in all expected environments and communicates that on the pack "don't expose me to UV"......

7. The Use-instructions.

How many times do we (as consumers) read the back of the pack? Probably not as often as we should BUT that doesn't mean that we shouldn't pay attention to what we write. There is no way that an AHA product is safe to use 6 times a day, a retinol cream should be used non-stop for months with no sun protection and a walnut scrub exfolliant to be used on broken skin. People generally have the view that if a little is good, a lot will be better and that is why education, efficient communication and appropriate measures (with packaging etc) should be taken to ensure that miss-use is kept to a minimum.

8. The Disposal.

One of the biggest problems from an environmental perspective of cosmetics (once they are made) is that many of them end up in our water ways and this is because the skin doesn't tend to suck in as much as it is given credit for. Because of this it makes sense that a safe cosmetic be one that understands how it acts in the environment. When a product is being developed the chemist will review material safety data which outlines how biodegradable and safe the chemistry is for the environment. For the most part it is possible to formulate products with biodegradable ingredients but in the case of some colour, styling, perfume and sunscreen products the process of degradation is more complex. In cases where a cosmetic is expected to take a long while to biodegrade or may be dangerous to aquatic organisms in large doses it may be pertinent to communicate that with consumers. An example of this was seen with some chemical sunscreens which were found to be contributing to coral bleaching on the barrier reef. These same sunscreens may be perfectly reasonable to use in the city for daily use as they may be diluted to such a degree that renders them inactive when they reach the waterways - a VERY applied relationship that involves some in-use decision making.
The same holds true for cosmetic packaging which can also build up in the environment or break down to un-safe by-products. This is why biodegradable and minimalistic packaging plays no small part in product safety.
While I am sure that some things have been missed in this overview it is clear that a safe cosmetic is much more than the sum of its ingredients from a direct health perspective. A safe cosmetic is one that considers its impact from concept through to its disposal and as such a product may be 'safe' in one environment but 'unsafe' in another. This complex and multi-faceted approach to safety requires a large amount of thought, investment and specialist knowledge to ensure that the end product is as safe as you expected it to be and that is rather daunting. For that reason I can thoroughly recommend that anyone looking to join or re-invest in the 'safe' cosmetics industry seek some advice from a whole host of professionals including regulatory consultants, chemists, and environmental research groups and marketing companies to ensure that you don't forget an important box. Further, from a legal perspective it is also essential that anyone involved in making decisions about a cosmetic brand has a direct relationship with their local Cosmetic Society and from that the international federation to ensure the relevance and accuracy of scientific information.

All cosmetics can be safe if you handle them correctly but to do that involves a level of engagement and ownership that is often swept under the carpet. It may well be time to stand up and be accountable as that really is the only way to make the world a better place.

Amanda Foxon-Hill

20 May 2011