Julie Gunlock wrote a blog post entitled “The ‘toxic’ lies behind Jessica Alba’s booming baby business” (to read the post, click here ) We’re not necessarily fond of Jessica Alba nor her Honest Company, but the statements made by Julie Gunlock need to be addressed. She contends that the Honest Company’s main commodity is fear and the “false promise that their products are safer than others.”
I will not comment on her admonitions about how The Honest Company’s products are full of chemicals (as this should be obvious), or that Alba had recognized that “many people – particularly women (sic) – have been convinced that common chemicals are a bogeyman that lurks, waiting to harm them” – since everything is made of chemicals, some bad for us, some that are not. We aren’t part of the “man made is absolutely bad, natural is absolutely good” camp.
What I will address is her claim that chemicals used in products are “there for a reason” and they’re completely safe because “chemicals are regulated under nearly a dozen federal agencies and regulations.” She states: “ chemicals in products … are used in trace amounts, often improve the safety of those products and have undergone hundreds of safety tests.”
As she herself says, nothing could be further from the truth.
First, let’s address her contention that “chemicals in products…are used in trace amounts.”
The idea that chemicals won’t harm us because the amounts used are so tiny is not new; it’s been used by industry for many years. However, new research is being done which is profoundly changing our old belief systems. For example, we used to think that a little dose of a poison would do a little bit of harm, and a big dose would do a lot of harm (i.e., “the dose makes the poison”) – because water, as Julie Gunlock herself reminds us, can kill you just as surely as arsenic, given sufficient quantity. The new paradigm shows that exposure to even tiny amounts of chemicals (in the parts-per-trillion range) can have significant impacts on our health – in fact some chemicals impact the body profoundly in the parts per trillion range, but do little harm at much greater dosages. The old belief system did not address how chemicals can change the subtle organization of the brain. Now, according to Dr. Laura Vandenberg of the Tufts University Center for Regenerative and Developmental Biology “we found chemicals that are working at that really low level, which can take a brain that’s in a girl animal and make it look like a brain from a boy animal, so, really subtle changes that have really important effects.”
In making a risk assessment of any chemical, we now also know that timing and order of exposure is critical – exposures can happen all at once, or one after the other, and that can make a world of difference. And we also know another thing: mixtures of chemicals can make each other more toxic. For example: a dose of mercury that would kill 1 out of 100 rats, when combined with a dose of lead that would kill 1 out of 1000 rats – kills every rat exposed.
And finally, the new science called “epigenetics” is finding that pollutants and chemicals might be altering the 20,000-25,000 genes we’re born with—not by mutating or killing them, but by sending subtle signals that silence them or switch them on or off at the wrong times. This can set the stage for diseases, which can be passed down for generations. So exposure to chemicals can alter genetic expression, not only in your children, but in your children’s children – and their children too. Researchers at Washington State University found that when pregnant rats were exposed to permethrin, DEET or any of a number of industrial chemicals, the mother rats’ great granddaughters had higher risk of early puberty and malfunctioning ovaries — even though those subsequent generations had not been exposed to the chemical. Another recent study has shown that men who started smoking before puberty caused their sons to have significantly higher rates of obesity. And obesity is just the tip of the iceberg—many researchers believe that epigenetics holds the key to understanding cancer, Alzheimer’s, schizophrenia, autism, and diabetes. Other studies are being published which corroborate these findings.
So that’s the thing: we’re exposed to chemicals all day, every day – heavy metals and carcinogenic particles in air pollution; industrial solvents, household detergents, Prozac (and a host of other pharmaceuticals) and radioactive wastes in drinking water; pesticides in flea collars; artificial growth hormones in beef, arsenic in chicken; synthetic hormones in bottles, teething rings and medical devices; formaldehyde in cribs and nail polish, and even rocket fuel in lettuce. Pacifiers are now manufactured with nanoparticles from silver, to be sold as ‘antibacterial.’ These exposures all add up – and the body can flush out some of these chemicals, while it cannot excrete others. Chlorinated pesticides, such as DDT, for example, can remain in the body for 50 years. Scientists call the chemicals in our body our “body burden”. Everyone alive carries within their body at least 700 contaminants.
This cumulative exposure could mean that at some point your body reaches a tipping point and, like falling dominoes, the stage is set for something disastrous happening to your health.
The generations born from 1970 on are the first to be raised in a truly toxified world. Probably one in three of the children you know suffers from a chronic illness – based on the finding of many studies on children’s health issues. It could be cancer, or birth defects – perhaps asthma, or a problem that affects the child’s mind and behavior, such as a learning disorder, ADHD or autism or even a peanut allergy. We do know, for example:
- Childhood cancer, once a medical rarity, is the second leading cause of death (following accidents) in children aged 5 to 14 years.
- According to the American Academy of Allergy Asthma & Immunology, for the period 2008-2010, asthma prevalence was higher among children than adults – and asthma rates for both continue to grow. 
- Autism rates without a doubt have increased at least 200 percent.
- Miscarriages and premature births are also on the rise,
- while the ratio of male to female babies dwindles and
- teenage girls face endometriosis.
Dr. Warren Porter delivered a talk at the 25th National Pesticide Forum in 2007, in which he explained that a lawn chemical used across the country, 2,4-D, mecoprop and dicambra was tested to see if it would change or alter the capacity of mice to keep fetuses in utero. The test found that the lowest dosage of this chemical had the greatest effect – a common endocrine response.
Illness does not necessarily show up in childhood. Environmental exposures, from conception to early life, can set a person’s cellular code for life and can cause disease at any time, through old age. And the new science of epigenetics is showing us that these exposures can impact not only us, but our children, grandchildren and great-grandchildren.
I think that pretty much demolishes the argument that chemicals in “trace amounts” don’t do us any harm.
Second, what about her contention that “chemicals are regulated under nearly a dozen federal agencies and regulations … which have undergone hundreds of safety tests.”
The chief legal authority for regulating chemicals in the United States is the 1976 Toxic Substances Control Act (TSCA).
It is widely agreed that the TSCA is not doing the job of protecting us, and that the United States is in need of profound change in this area. Currently, legislation entitled the 2013 Chemical Safety Improvement Act, introduced by a bipartisan group of 26 senators, is designed to improve the outdated TSCA but it is still in committee. The chemicals market values function, price and performance over safety, which poses a barrier to the scientific and commercial success of green chemistry in the United States and could ultimately hinder the U.S. chemical industry’s competitiveness in the global marketplace as green technologies accelerate under the European Union’s requirements.
We assume the TSCA is testing and regulating chemicals used in the industry. It is not:
- Of the more than 60,000 chemicals in use prior to 1976, most were “grandfathered in”; only 263 were tested for safety and only 5 were restricted. Today over 80,000 chemicals are routinely used in industry, and the number which have been tested for safety has not materially changed since 1976. So we cannot know the risks of exposing ourselves to certain chemicals. The default position is that no information about a chemical = no action.
- The chemical spill which occurred in West Virginia in 2014 was of “crude MCHM”, or 4-methylcyclohexanemethanol, one of the chemicals that was grandfathered into the Toxic Substances Control Act of 1976. That means that nobody knows for sure what that chemical can do to us.
- Carcinogenic effects? No information available.
- Mutagenic effects? No information available.
- Developmental toxicity? No information available.
Lack of information is the reason the local and federal authorities were so unsure of how to advise the local population about their drinking water supplies. (And by the way, in January, 2014, a federal lawsuit was filed in Charleston, WV, which claims that the manufacturer of MCHM hid “highly toxic and carcinogenic properties” of components of MCHM, hexane and methanol, both of which have been tested and found to cause diseases such as cancer.)
We assume that the TSCA requires manufacturers to demonstrate that their chemicals are safe before they go into use. It does not:
- The EPA requires a “Premanufacture Notification” of a new chemical, and no data of any kind is required. The EPA receives between 40-50 each week and 8 out of 10 are approved, with or without test data, with no restrictions on their proposed use. As 3M puts it on their PMN forms posted on EPA’s web site, “You are not required to submit the listed test data if you do not have it.”
- The TSCA says the government has to prove actual harm caused by the chemical in question before any controls can be put in place. The catch-22 is that chemical companies don’t have to develop toxicity data or submit it to the EPA for an existing product unless the agency finds out that it will pose a risk to humans or the environment – which is difficult to do if there is no data in the first place. Lack of evidence of harm is taken as evidence of no harm.
We assume that manufacturers must list all ingredients in a product, so if we have an allergy or reaction to certain chemicals we can check to see if the product is free of those chemicals. It does not:
- The TSCA allows chemical manufacturers to keep ingredients in some products secret. Nearly 20% of the 80,000 chemicals in use today are considered “trade secrets”. This makes it impossible for consumers to find out what’s actually in a product. And there is no time limit on the period in which a chemical can be considered a trade secret.
These limitations all help to perpetuate the chemical industry’s failure to innovate toward safer chemical and product design. It’s one of the reasons the USA is one of the few nations in the world in which asbestos is not banned.
Finally, and because I just couldn’t resist: her example of using what she concedes are “toxic fragrances” to cover up that “other toxic stink – the one coming out of your baby” speaks for itself.
In conclusion, I don’t think that we’re being alarmist in trying to find better alternatives for products we use every day. Nor are the promises of companies like Alba’s false.
 Living on Earth, March 16, 2012, http://www.loe.org/shows/segments.html?programID=12-P13-00011&segmentID=1
 Sorensen, Eric, “Toxicants cause ovarian disease across generations”, Washington State University, http://news.wsu.edu/pages/publications.asp?Action=Detail&PublicationID=31607
http://www.sciguru.com/newsitem/13025/Epigenetic-changes-are-heritable-although-they-do-not-affect-DNA-structure ALSO SEE: http://www.eeb.cornell.edu/agrawal/documents/HoleskiJanderAgrawal2012TREE.pdf ALSO SEE: http://www.the-scientist.com/?articles.view/articleNo/32637/title/Lamarck-and-the-Missing-Lnc/
 Theofanidis, D, MSc., “Chronic Illness in Childhood: Psychosocial and Nursing Support for the Family”, Health Science Journal, http://www.hsj.gr/volume1/issue2/issue02_rev01.pdf
 Ward, Elizabeth, et al; Childhood and adolescent cancer statistics, 2014, CA: Cancer Journal for Clinicians, Vol 64, issue 2, pp. 83-103, March/April 2014
 Porter, Warren, PhD; “Facing Scientific Realities: Debunking the “Dose Makes the Poison” Myth”, National Pesticide Forum, Chicago, 2007; http://www.beyondpesticides.org/infoservices/pesticidesandyou/Winter%2007-08/dose-poison-debunk.pdf
 The “regulations” mentioned, all of which fall under the TSCA, might include:
- the Environmental Protection Agency’s Chemical Action Plans for certain chemicals – to date, 10 chemicals have Chemical Action Plans in place. These plans attempt to outline the risks each chemical may present and identify the specific steps the agency is taking to address the concerns.
- Confidential Business Information (CBI) – designed to protect intellectual property and confidential business information.
- Chemical Data Reporting (CDR) Rule: use and exposure information to help the EPA screen and prioritize chemicals for additional review.
- Chemical Prioritization: Which allows the EPA to identify which chemicals in commerce warrant additional review.
- Risk Assessment: Under TSCA, EPA assesses chemicals using conservative assumptions about the possible hazards a chemical may pose.