Valerie George06.20.23
Dear Valerie: Do you think Sodium Lauryl Sulfate or its Laureth counterpart will ever get used by chemists again? Why did sulfates get put on the naughty list in the first place?
—SAD OVER SULFATES
Dear Sad:
What is fortunate about SLS and SLES is that they have not suffered the same fate their maligned preservative counterparts, parabens, suffered. There are no poorly designed studies that should be retracted or websites haranguing these surfactants for causing cancer. In fact, even the EWG acknowledges [today] that these efficient surfactants only garner a 1-3 on its EWG’s Skin Deep database. Where does the hatred for SLS and SLES come from? Marketing.
Having grown up as a chemist in the salon professional world, we always learned that Pureology was to blame (or take credit) for consumers demanding their showers be sulfate-free. Pureology, once an independent brand acquired by L’Oréal, was founded on the premise of creating safe, gentle shampoos that were less stripping of artificial color from consumers’ hair by avoiding Sodium Lauryl Sulfate and Sodium Laureth Sulfate. It became easier just to call these products “sulfate-free.” The craze was born.
I always thought this story was industry legend, tidbits of marketing lore passed down to young, budding chemists, until I read Jim Markham’s autobiography, Big Lucky. Markham is a celebrity hairstylist and serial entrepreneur known for his involvement in Sebring International (yes, the Jay Sebring of the Manson murders!), ABBA Pure and Natural, Pureology and Color Proof. In his book, he recounts how sulfates were deemed an important ingredient category from which to protect consumers. As an aside, I highly recommend the audio version of Big Lucky, recorded in his voice, where each chapter is recapped with his secrets to success in bullet point format.
Warning! The following paragraph contains spoiler alerts about how Markham sowed the seeds for a sulfate-less future, also contained within Chapter 20 of Big Lucky should you choose to skip ahead.
A friend of Markham’s wife, Kerry, was diagnosed with cancer. Her oncologists provided a long list of cosmetic product ingredients to avoid. Markham told her to just use ABBA Pure and Natural, but Kerry proclaimed that she couldn’t because ABBA contained ingredients that were on the restricted list, including Sodium Lauryl Sulfate and Sodium Laureth Sulfate. This came as a shock to Markham, so he set out to create a solution for Kerry that was free of her list of 20 dangerous ingredients to avoid. Not only was Pureology born, but so were the tales about the harms of sulfates for consumers.
What was meant to be just formulations free of SLS and SLES turned into a craze where many ingredients, not even related to surfactants, had to be avoided because the word “sulfate” was contained within. I wonder what would have happened had Markham just used the more appropriate SLS/SLES when speaking to free-from claims?
We would still have been shorted two great ingredients that can be used effectively by chemists in formulations. I do think—compared to parabens—sulfates have a chance of making a comeback. They’re not maligned for carcinogenic properties, although ethoxylated sulfates like Sodium Laureth Sulfate do contain trace amounts of 1,4-dioxane. SLS and SLES have clear feedstock origin stories and can be free of coconut, which is one of the newer challenges with consumers on today’s market.
These surfactants can also be used at lower use levels with greater detergency than some of their “sulfate free” counterparts. They also can be used in lower levels with other secondary and tertiary surfactants that dominate the foaming profile.
I’m not sure we formulators will gain approval from marketing to switch back to SLS/SLES any time soon, but I think the shift is happening. This is more than I can say for parabens.
Dear Valerie:
When I formulate products, I try my hardest to make sure products are safe. I use common sense and not use exotic ingredients that I know little about. My company also conducts Preservative Efficacy Testing and stability. Other than that, what should be done?
—SAFETY FIRST
Dear Safety:
The cosmetics industry in the US is currently a rather self-regulating industry, at least up until the passing of MoCRA (Modernization of Cosmetics Regulation Act) in late 2022, which is a supplement to existing regulation that creates more structure and framework around cosmetics regulation in the US.
While the FDA has several guidelines about making and selling cosmetic products, it only regulates cosmetic products; FDA does not pre-approve every product entering the market. To place a product on the market, products must be safe. This is not changing with MoCRA.
Historically, the onus of safety has been assigned to the manufacturer or brand, and how a product gets deemed safe was left to industry. This nebulousness has led others to think the cosmetics industry in the US is not regulated, despite this not being the case.
Nonetheless, there are two important laws pertaining to cosmetics marketed in the US: the Federal Food, Drug, and Cosmetic Act (FD&C Act) and the Fair Packaging and Labeling Act (FPLA). FDA regulates cosmetics under the authority of these laws.
FD&C Act ensures products are not adulterated (contaminated), misbranded (falsely labeled or misleading), and otherwise are compliant with FDA guidelines.
FPLA ensures your packaging and advertising information accurately represents your product and allows the consumer to make an informed decision to purchase your product.
Today, there is not a set list of tests that the FDA requires brands to conduct in order to establish safety; the brands simply must prove that their product cannot be adulterated, is not misbranded and is consumer safe. How the brand or manufacturer gets there, is up to the brand. With the implementation of MoCRA, there may be more definition to this regulation, or it may still have some vagueness to it. All of this has yet to be determined.
Fortunately, there are tests and protocols that we can conduct to ensure products are safe, before or despite MoCRA going into effect. You have a head start with conducting PET; this assures the product can stand up to adulteration for when (not if) it encounters pathogens. Stability testing not only establishes shelf life, but it also ensures the product does not undergo physical or chemical transformation.
Safety In Use testing analyzes a product’s tolerability during normal use conditions of a product. HRIPT is an acronym for Human Repeat Insult Patch Testing, which looks at a product’s propensity to cause irritation use-over-use during a specified period. Of course, a product’s formulation can always be assessed by a toxicologist, which takes into consideration dose and instructions of use for a product.
As a chemist, it’s unlikely you’ll conduct any of the latter testing, but it will likely be conducted by the brand or your research organization. However, there are ways you can contribute to safety by thinking ahead of any toxicology reviews, such as utilizing the ingredient directories laid out by the Cosmetic Ingredient Review (CIR) Board or Scientific Committee on Consumer Safety (SCCS) to understand the use restrictions for every ingredient being used.
Valerie George
askvalerie@icloud.com
Valerie George is a cosmetic chemist, science communicator, educator, leader, and avid proponent of transparency in the beauty industry. She works on the latest research in hair color and hair care at her company, Simply Formulas, and is the co-host of The Beauty Brains podcast. You can find her on Instagram at @cosmetic_chemist or showcasing her favorite ingredients to small brands and home formulators at simply-ingredients.com
—SAD OVER SULFATES
Dear Sad:
What is fortunate about SLS and SLES is that they have not suffered the same fate their maligned preservative counterparts, parabens, suffered. There are no poorly designed studies that should be retracted or websites haranguing these surfactants for causing cancer. In fact, even the EWG acknowledges [today] that these efficient surfactants only garner a 1-3 on its EWG’s Skin Deep database. Where does the hatred for SLS and SLES come from? Marketing.
Having grown up as a chemist in the salon professional world, we always learned that Pureology was to blame (or take credit) for consumers demanding their showers be sulfate-free. Pureology, once an independent brand acquired by L’Oréal, was founded on the premise of creating safe, gentle shampoos that were less stripping of artificial color from consumers’ hair by avoiding Sodium Lauryl Sulfate and Sodium Laureth Sulfate. It became easier just to call these products “sulfate-free.” The craze was born.
I always thought this story was industry legend, tidbits of marketing lore passed down to young, budding chemists, until I read Jim Markham’s autobiography, Big Lucky. Markham is a celebrity hairstylist and serial entrepreneur known for his involvement in Sebring International (yes, the Jay Sebring of the Manson murders!), ABBA Pure and Natural, Pureology and Color Proof. In his book, he recounts how sulfates were deemed an important ingredient category from which to protect consumers. As an aside, I highly recommend the audio version of Big Lucky, recorded in his voice, where each chapter is recapped with his secrets to success in bullet point format.
Warning! The following paragraph contains spoiler alerts about how Markham sowed the seeds for a sulfate-less future, also contained within Chapter 20 of Big Lucky should you choose to skip ahead.
A friend of Markham’s wife, Kerry, was diagnosed with cancer. Her oncologists provided a long list of cosmetic product ingredients to avoid. Markham told her to just use ABBA Pure and Natural, but Kerry proclaimed that she couldn’t because ABBA contained ingredients that were on the restricted list, including Sodium Lauryl Sulfate and Sodium Laureth Sulfate. This came as a shock to Markham, so he set out to create a solution for Kerry that was free of her list of 20 dangerous ingredients to avoid. Not only was Pureology born, but so were the tales about the harms of sulfates for consumers.
What was meant to be just formulations free of SLS and SLES turned into a craze where many ingredients, not even related to surfactants, had to be avoided because the word “sulfate” was contained within. I wonder what would have happened had Markham just used the more appropriate SLS/SLES when speaking to free-from claims?
We would still have been shorted two great ingredients that can be used effectively by chemists in formulations. I do think—compared to parabens—sulfates have a chance of making a comeback. They’re not maligned for carcinogenic properties, although ethoxylated sulfates like Sodium Laureth Sulfate do contain trace amounts of 1,4-dioxane. SLS and SLES have clear feedstock origin stories and can be free of coconut, which is one of the newer challenges with consumers on today’s market.
These surfactants can also be used at lower use levels with greater detergency than some of their “sulfate free” counterparts. They also can be used in lower levels with other secondary and tertiary surfactants that dominate the foaming profile.
I’m not sure we formulators will gain approval from marketing to switch back to SLS/SLES any time soon, but I think the shift is happening. This is more than I can say for parabens.
Dear Valerie:
When I formulate products, I try my hardest to make sure products are safe. I use common sense and not use exotic ingredients that I know little about. My company also conducts Preservative Efficacy Testing and stability. Other than that, what should be done?
—SAFETY FIRST
Dear Safety:
The cosmetics industry in the US is currently a rather self-regulating industry, at least up until the passing of MoCRA (Modernization of Cosmetics Regulation Act) in late 2022, which is a supplement to existing regulation that creates more structure and framework around cosmetics regulation in the US.
While the FDA has several guidelines about making and selling cosmetic products, it only regulates cosmetic products; FDA does not pre-approve every product entering the market. To place a product on the market, products must be safe. This is not changing with MoCRA.
Historically, the onus of safety has been assigned to the manufacturer or brand, and how a product gets deemed safe was left to industry. This nebulousness has led others to think the cosmetics industry in the US is not regulated, despite this not being the case.
Nonetheless, there are two important laws pertaining to cosmetics marketed in the US: the Federal Food, Drug, and Cosmetic Act (FD&C Act) and the Fair Packaging and Labeling Act (FPLA). FDA regulates cosmetics under the authority of these laws.
FD&C Act ensures products are not adulterated (contaminated), misbranded (falsely labeled or misleading), and otherwise are compliant with FDA guidelines.
FPLA ensures your packaging and advertising information accurately represents your product and allows the consumer to make an informed decision to purchase your product.
Today, there is not a set list of tests that the FDA requires brands to conduct in order to establish safety; the brands simply must prove that their product cannot be adulterated, is not misbranded and is consumer safe. How the brand or manufacturer gets there, is up to the brand. With the implementation of MoCRA, there may be more definition to this regulation, or it may still have some vagueness to it. All of this has yet to be determined.
Fortunately, there are tests and protocols that we can conduct to ensure products are safe, before or despite MoCRA going into effect. You have a head start with conducting PET; this assures the product can stand up to adulteration for when (not if) it encounters pathogens. Stability testing not only establishes shelf life, but it also ensures the product does not undergo physical or chemical transformation.
Safety In Use testing analyzes a product’s tolerability during normal use conditions of a product. HRIPT is an acronym for Human Repeat Insult Patch Testing, which looks at a product’s propensity to cause irritation use-over-use during a specified period. Of course, a product’s formulation can always be assessed by a toxicologist, which takes into consideration dose and instructions of use for a product.
As a chemist, it’s unlikely you’ll conduct any of the latter testing, but it will likely be conducted by the brand or your research organization. However, there are ways you can contribute to safety by thinking ahead of any toxicology reviews, such as utilizing the ingredient directories laid out by the Cosmetic Ingredient Review (CIR) Board or Scientific Committee on Consumer Safety (SCCS) to understand the use restrictions for every ingredient being used.
Valerie George
askvalerie@icloud.com
Valerie George is a cosmetic chemist, science communicator, educator, leader, and avid proponent of transparency in the beauty industry. She works on the latest research in hair color and hair care at her company, Simply Formulas, and is the co-host of The Beauty Brains podcast. You can find her on Instagram at @cosmetic_chemist or showcasing her favorite ingredients to small brands and home formulators at simply-ingredients.com