2.26: summary:
. do you trust a product's list of ingredients?
there are significant exceptions to the law,
and even that law is not fully enforced.
. certain carcinogens don't have to be listed
because they are formed by combining
2 or more of the listed ingredients;
eg, my soap has Sodium laureth sulfate;
(ethylene oxide * sodium laurel sulfate)
and, that includes 1,4-dioxane.
. of course there are exceptions for pesticides
because they are in trace amounts
but trace doses can be endocrine disruptors.
. talc often contains asbestos;
and the quality control is not perfect;
yet ingredients don't have to say
"may contain trace amounts of asbestos".
2.23: the law:
Rabbi Gavriel Price:
. the FDA recognizes the good of trade secrets;
The FDA regulations require only that
food labels list certain ingredients
in descending order according to weight;
ingredients that are less than 2% of weight
can be placed in any order;
and Medicine ingredients are in alphabetical order.
unlisted flavors and spices:
“natural flavors” can include [excitotoxic MSG]
or a chametz ingredient [leavened foods
forbidden on the Jewish holiday of Passover].
unlisted “incidental additives”:
. An “incidental additive” is exempt if,
it is present at “insignificant levels”
and has no “technical or functional effect”;
eg, it comes from the remains of a different recipe,
or is an unnecessary sub-ingredient;
eg, margarine may contain beta-carotene
but a product that uses such margarine
would not have to list the beta-carotene.
[see Code of Federal Regulations]
2001: "trace amounts" of "natural" ingredients:
. as many as one-fourth of all food manufacturers
do not list all of their ingredients
posing a danger to individuals with food allergies,
a new FDA investigation finds.
In addition, only "slightly more than half" of the companies
checked their products to ensure that all of the ingredients
were "accurately reflected on the labels."
The FDA currently allows omission of
"trace amounts" of "natural" ingredients.
However, the investigation found that
many unlisted ingredients were not intentionally added,
but instead resulted from residue left on utensils or baking pans,
making it "difficult" for manufacturers to know
if or when an ingredient has entered a product.
Each year, 30,000 people must go to the hospital
for allergic reactions to food,
and as many as 200 die.
University of Guelph 2013:
professor Steven Newmaster:
. commercial herbal products (CHP)
contain many unlisted ingredients,
fillers and cheap alternatives.
44 products from 12 separate corporations were tested .
It was determined that 60% of CHP contain
plant species not referred to on their labels.
Fillers added to 32% of products tested were:
• Rice • Soybeans • Wheat
This poses a problem for persons with allergies
or with bad reactions to gluten.
Michael F. Jacobson of the CSPI:
(Center for Science in the Public Interest)
agreed that "Brewers Should Label Beer Ingredients":
. 30 years ago the CSPI sued the government
to get ingredients listed on alcoholic beverages.
But the government required only that
allergens like sulfites and Yellow 5 to be labeled.
theguardian 2013:
. gum arabic is a common cola emulsifier
yet it's rarely listed on cola labels.
Sudan is responsible for 40-80% of the world's production;
in the first half of 2013,
the country's exports rose to 33,000 tonnes.
mondediplo 2011:
The trade in gum arabic hides secrets
about its most powerful client, Coca-Cola.
When Democratic congresswoman Maxine Waters
tried to get a bill passed in 2007
to ban all trade in Sudanese gum arabic,
assistants to members of Congress say they were
approached by lobbyists....
gum arabic aka GUM ACACIA:
Acacia Gum is a purified vegetable gum
obtained from the acacia tree.
Sometimes referred to as gum arabic.
cga.ct.gov 2008:
. summary of federal ingredient labeling laws,
especially those relating to allergens:
The Nutrition Labeling and Education Act (NLEA) of 1990
amends the Food, Drug and Cosmetic Act (FD&CA).
It requires most food to bear nutrition labels
and prescribes their form and content.
NLEA also preempts state food labeling laws.
Specifically, it prohibits states from
establishing or enforcing labeling requirements
that are different from federal law.
The Food Allergen Labeling and Consumer Protection Act
(FALCPA) of 2004 further amends the FD&CA.
It requires food labels to state the presence of
the eight major food allergens identified by the act.
They are: milk, eggs, fish, shellfish,
tree nuts, wheat, peanuts, and soybeans.
The Congressional findings state that
the eight major allergens are responsible for
90 % of all food allergies.
2.25: 1,4-dioxane in soap:
my soap contains Sodium laureth sulfate;
but doesn't list the 1,4-dioxane.
safecosmetics.org`WHAT IS 1,4-dioxane?:
1,4-dioxane is generated through a process called ethoxylation,
in which ethylene oxide, a known breast carcinogen,
is added to other chemicals to make them less harsh.
This process creates 1,4-dioxane.
For example, sodium laurel sulfate,
a chemical that is harsh on the skin,
is often converted to the less-harsh chemical
sodium laureth sulfate (the “eth” denotes ethoxylation).
The conversion process can lead to
contamination with 1,4-dioxane.
Other common ingredients that may be
contaminated by 1,4-dioxane
include PEG compounds and chemicals that include
the clauses “xynol,” “ceteareth” and “oleth”.
Most commonly, 1,4-dioxane is found in products that
create suds, like shampoo, liquid soap and bubble bath.
Environmental Working Group’s analysis suggests that
97 percent of hair relaxers, 57 percent of baby soaps
and 22 percent of all products in Skin Deep
may be contaminated with 1,4-dioxane.
Independent lab tests co-released by the
Campaign for Safe Cosmetics in 2007 showed that
popular brands of children’s bubble bath and body wash
contained 1,4-dioxane.
HOW TO AVOID: The FDA does not require 1,4-dioxane
to be listed as an ingredient on product labels
because the chemical is a contaminant
produced during manufacturing.
Without labeling, there is no way to know for certain
whether a product contains 1,4,-dioxane,
making it difficult for consumers to avoid it.
Alternative processes to ethoxylation do exist,
but many companies don’t take advantage of them.
Vacuum-stripping can remove 1,4-dioxane from an ethoxylated product,
or manufacturers can skip ethoxylation entirely
by using less-harsh ingredients to begin with.
Organic standards do not allow ethoxylation at all,
and some conventional companies, such as Johnson & Johnson,
have agreed to alter the process that results in this contamination.
A study by the Organic Consumers Association shows that
1,4-dioxane is nonexistent in a variety of cosmetics
certified under the USDA National Organic Program.
2.25: asbestos in talc:
John Whysner, MD, PhD:
Talc is a mineral similar to asbestos;
the two minerals are often found together.
The modest association with ovarian cancer
has been attributed to asbestos contamination.
reuters 2016:
Dr. Adetunji Toriola:
"We know that inflammation increases ovarian cancer risk.
We know talcum powder causes inflammation.
The question is, does talc cause cancer
by causing inflammation in the ovaries?".
. Dr. Daniel Cramer, a Harvard University epidemiologist,
first reported on a potential link between
talc and ovarian cancer in 1982.
. his work suggests that talc exposure
increases the risk of ovarian cancer by 30 %.
. the International Agency for Research on Cancer,
part of the World Health Organization,
classified the use of talc-based body powder on the genitals
as "possibly carcinogenic to humans".
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