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Dear Safe Cosmetics Australia….

April 13, 2012

Dear Amina Leslie and the Safe Cosmetics Australia team,

I just wanted to write to you to tell you how pleased I am to not have to go to an American website now to get my propaganda.  Everyone here likes ‘Australian Made’ so I am sure that you will do well.  While I support the move to a greener, cleaner and more sustainable future (which by definition means less toxic) after checking out your website and documentation I was left confused and it’s mostly down to one thing.  Evidence.

There is no doubt in my mind (as a chemist, mother, tree-hugger and person who doesn’t want cancer- who does?) that we, as a cosmetics industry could do better. However, to make bold claims such as saying that “Chemicals have been known to trigger allergic reactions including skin rashes and asthma attacks”  is, absolute nonsense based on how you are communicating it.  Do you even know what a ‘chemical’ is?  I would be very interested to  hear how you are planning to rid the world of such filth but won’t ask you directly as I can’t imagine that you would give me much air time……..

Further I am concerned about the focus on heavy metals – yes I do know that the guys in the states have been running a highly successful ‘get the lead out’ campaign and I have to agree, if people were putting lead into my lipstick I would wish to grab them and shove it where the sun don’t shine (on them, not me of course)  but nobody DOES put lead in their lipsticks.   For just under $200 per sample my lovely friends at a local testing facility will run any of your ‘certified toxin free’ lipsticks through their machinery and show you the lead.  It would be present in pretty much all lipsticks using metal oxide colours (the natural ones usually contain more actually because they less highly refined) because it is natural.  OK too much lead is a bad thing and no lead would be amazing but it is practically impossible to do and the levels showing up are in the parts per million rather than bucketload that your responses allude to.  Still, there is no need to respond to this because I can already see it coming so I’ll go and say goodbye to my husband and kids now and then bury my (probably toxic) body underground so that your mission to rid the world of chemicals continues unimpeded.

I could go on but doubt that there is any point as hitting people over the head with common sense has the same effect as hitting them over the head with a big hammer. They don’t like it.  Therefore I will just carry on doing what I’ve been doing for the past fourteen years and that is learning day by day about how to make things better, safer, more effective and more economical by referring to real, solid scientific evidence.

Before I go I will say this. I am a fair, honest and open-minded person who works as an independent chemist in a world full of ego’s and fear-based prejudices (OK so that doesn’t sound very fair or open-minded but at least it is honest) and as such I would be the first to welcome the body of evidence that you have called upon to draw your conclusions.  In the meantime I will not be advising any of my customers to apply to your scheme, to pay money to have you ‘certify’ them or to help you ‘spread the word’.  I held off writing this for a good few months (I saw you pop up some time ago but you have been really quiet until the last few weeks) because I am acutely aware at how passionate your supporters can be and I haven’t really felt like starting a fight but now that you have got yourself into the media as an ‘expert’ and that my customers are asking my opinion I feel that a comment is necessary.

I am not against a toxin-free world but I am against any campaign, group or other activity that uses fear as it’s motivator, especially when it is unsubstantiated.

Most of all I am terribly sad about this whole thing because it gives me further evidence (as if I need any more, the stories I could tell you) that the newspapers, media and general public are so easily conned by all of this and rather than question the basis for your assumptions go ahead and give you a platform.

This isn’t a battle.  I do not want to ‘win’ but what I would like is to see people wake up.  However, I am under no illusion that is going to happen in my lifetime.

Oh, did you know that fear can also give you cancer?  No, thought not.

Amanda

PS: If you want to find out more about this group please google them. I am not posting a link as I don’t want to give them any more publicity. Thank you.

23 Comments leave one →
  1. dene62 permalink
    April 13, 2012 11:36 pm

    A very good letter, Amanda. It is unfortunate that Amina Leslie appears to have little understanding of chemistry, as many of the entries in both the “restricted list” and “prohibited lists” are incorrect, either in the description of the chemical itself, or the assignation of toxicological effects. This will detract greatly from any credibility of the SCA as a whole. Indeed, one substance (at least) is listed on both the restricted AND the prohibited lists, albeit under different names, which underlines my belief that there is a lack of scientific rigour associated with the campaign.

    I actually wrote directly to Amina (or, rather, her company) to explain that they cannnot describe phenoxyethanol as being nature-derived, as they do on their web site. I did receive a very polite response, but my follow-up comments were, effectively, fobbed off.

    I share your sentiments about the industry being open to improvement, but it is essential that it is done in the right (realistic) way – whatever country you live in. SCA is not the way forward any more than the Campaign For Safe Cosmetics are in the USA.

    • RealizeBeautyEd permalink
      April 13, 2012 11:41 pm

      And so say all of us 🙂
      I wouldn’t mind so much if there was evidence to back up the claims OR if there was some logic to the arguments but sadly no. However, I know all too well how the world works and expect to be burned at the stake for pointing out the obvious. I am a chemist therefore I am evil.

      • dene62 permalink
        April 13, 2012 11:45 pm

        I know how you feel, Amanda – as I write, there’s a mob armed with pitchforks and burning torches outside my house 😦

      • RealizeBeautyEd permalink
        April 13, 2012 11:46 pm

        Stay safe 🙂

  2. personalcaretruth permalink
    April 14, 2012 12:40 am

    Amanda and Dene, you both have a fan in me! I believe in the truth and nothing but the truth. Fabulous article, Amanda and kudos to you for writing the truth!

    I will not be bullied by any one person or organization, by fear mongering, misinformation or half truths. The activists need to step up to the plate and supply responsible, truthful and science backed information. Consumers, wherever they may be, deserve it, so they can make informed decisions about the products they use on themselves and their family members.

    If you’re an individual or organization spreading misinformation and fear, it’s nothing more than lip service, in my book and you should be ashamed of yourself!

    Have a great day!

    Lisa

  3. April 14, 2012 2:15 am

    I’m sorry to see these Scare Campaigns making their way through the world and finding a voice in what I used to regard as thinking, intelligent societies. We have our very own government-funded version of the EWG now here in Denmark, and it is depressing to see all this misinformation spreading. Thanks for an excellent post.

  4. April 14, 2012 2:20 am

    PS. I am not a chemist or scientist

    • RealizeBeautyEd permalink
      April 14, 2012 7:21 am

      Hi there Lisa,
      Thanks for stopping by and commenting. I think that it really is time for us to all start calling out sloppy and misplaced activism as all it does is maintain fear and confusion without making the world a better place. If the groups put even a quarter of their marketing efforts into funding legitimate research or reporting on real studies then we might get somewhere but they don’t. You don’t need to be a scientist for this, you just need to sit for one minute and think rather than sucking it all up. What the world needs right now is a greater level of consciousness and it’s truth not fear that wake people up.

      • dene62 permalink
        April 14, 2012 7:23 pm

        Again I agree, Amanda. We need more people to call out the nonsense and scaremongering so that “ordinary” consumers can see there’s more to the situation than they would otherwise be told. I also wish that more people from within the industry would call out companies that make false claims. The worst offenders are those who claim “100% natural” – a huge proportion of them are not telling the truth (although not all!). It would be great to have a central point of reference where these companies are exposed – they damage the credibility of the entire industry, imho.

      • RealizeBeautyEd permalink
        April 15, 2012 9:05 am

        Being a rebellious (ass) soul I am not a fan of collaborated ‘call out’ sites as all that finger pointing tends to leave me feeling bruised. I think that the public are capable of drawing their own informed conclusions about individual brands once they have gained some confidence and feel like they have some support. Nobody wants to be the proverbial ‘turd in a swimming pool’ so what I am hoping is that the work that is done here helps to give the public another friendly couch to sit on, think and ultimately draw their own conclusions. That is all we should do and yes, I wish that more from within the industry would talk about the many, many great things that are going on.

    • RealizeBeautyEd permalink
      April 15, 2012 9:42 am

      I beg to differ, a scientist is just someone who is curious and who seeks to understand. Chemistry is on way to investigate stuff we don’t know and clearly you have an interest in that 🙂 A degree is just a formal training, we need to feel it and live it to fully understand.

  5. April 14, 2012 2:29 am

    Great post, Amanda! You and Dene both have a fan in me. I greatly appreciate anyone who supports the truth and isn’t afraid to defend it!

    If the activist groups expect me to take them seriously, then they need to provide science based facts, not misinformation, hype and scare tactics. This is one gal who won’t jump on the fear wagon and is disgusted by those driving it!

    Keep sharing the truth and exposing the fear mongers for what they are!

    Have a great weekend!

    Lisa

  6. gedh permalink
    March 19, 2013 10:01 pm

    Just to mention that the claims on the SCA website are unscientific, scaremongering AND ungrammatical! The first two I could just about take, but …

    Seriously, thank you for your intelligent rebuttal of the site – unfortunately, you and the few sane people who are left in the world seem to be lone voices in the wilderness.One result of this is the ridiculous “free from” advertising by “natural” companies. As a small cosmetics maker myself I want to sell based on the lovely ingredients that ARE in my products, not by quoting a long list of “nasty chemicals” (which seems to include ALL chemicals – why don’t we just all wash with saponaria officinalis?) and slagging off other companies who don’t reach the Moral and Ethical Heights that I aspire to ….!

  7. Amina Leslie permalink
    April 27, 2016 7:10 am

    Wow what a pack of bullies you all come across as. I think you best remove this page as it is deformation & further action will be taken. Kindly remove my name & my business name from your website. Try publishing an article that is informative & has a point. My lawyers will be in touch

    • April 27, 2016 6:18 pm

      I don’t see a small group of people talking rationally about a scaremongering campaign as “a pack of bullies”. No threats have been made. YOU are the one making the threats, not us. I find threats of litigation are mostly just noise – an attempt to scare off people. This won’t work in this case. I, for one, would welcome you taking legal action. Your disinformation can easily be destroyed in court, and the publicity would be wonderful. Science would win.

      Your ad hominem response suggests that you are unable to offer a proper rebuttal to the statements made in this article and the subsequent comments.

      ” Try publishing an article that is informative & has a point.”

      That has been done. The point has been made.

      This page is not “deformation”; that is what YOU are doing to the truth about cosmetic ingredients. You mean DEFAMATION (I think), but defamation is only the case when falsehoods are being told. In this case, you ARE spreading false information.

      I hope this comes to court. I would welcome the opportunity to take the stand and give evidence against your case.

  8. April 30, 2016 12:41 pm

    Then remove my name & my Registered Trademark from this page and have your talk without involving me?! A positive discussion is one that does not blame an individual, this post is neither informative or correct. I started SCA to help others who wanted more information on products, to help those that are seeking a natural alternative to mainstream synthetic products. Many people do not understand the array chemicals that are listed on any given label, many people do need help in selecting products that are suitable for allergy prone skin. I am not a corporation, I am a sole trader with a passion for natural & organic ingredients that are widely accepted as the healthier choice to nasty synthetics – Science supports this with evidence *studies that provide valuable understanding and that has proven carcinogenic and hormone disrupting chemicals have a negative effect on the human body. Science is fact we agree on this, but this article ignores science and focuses on my website. Why? What is the point you are trying to make? That I should close my website because you have a differing opinion?

    Dene you emailed me repeatedly in 2012 and I kept all the emails. Stalking and harassing is a criminal offence – regardless of the fact that you were working for a chemical company and paid to do so. I see now that you just want to argue & I find that sad. It is truly a negative way to live.

    Amanda, I thank you for writing this post. It has shown me that not everyone is a decent human being. By all means have your discussion, but don’t head the article with an individuals name and their business name. Clearly you do not intend to assist anyone with this article – it is not about helping anyone, but your ego.

    • May 1, 2016 10:16 pm

      This is not my page, so I have no say in what is posted in the articles.

      //Many people do not understand the array chemicals that are listed on any given label, //

      I agree. This includes you, given the evidence of what you post on your website.

      //I am a sole trader with a passion for natural & organic ingredients that are widely accepted as the healthier choice to nasty synthetics //

      No, they are not “widely accepted as the healthier choice” by anyone with a smattering of understanding of toxicology.

      //Science supports this with evidence *studies that provide valuable understanding//

      No, it doesn’t. There is zero scientific evidence to support your blanket claim that natural substances are all safe and all synthetic substances are toxic. This is sheer nonsense and a catastrophic lack of understanding on your part.

      //carcinogenic and hormone disrupting chemicals have a negative effect on the human body//

      This is only correct if the exposure to such chemicals is sufficiently high. A fact that you appear to ignore completely.

      //Dene you emailed me repeatedly in 2012 and I kept all the emails. Stalking and harassing is a criminal offence – regardless of the fact that you were working for a chemical company and paid to do so. I see now that you just want to argue & I find that sad. It is truly a negative way to live.//

      I sent no more than about half a dozen e-mails to you. If that constitutes “stalking and harassing” to you, then I suggest you reassess your sense of perspective. I was not “working for a chemical company” and I was not “paid to do so”. So you are wrong on those counts as well. I don’t “just want to argue”. I want people to be honest and accurate with their claims. You are highly inaccurate with many of your claims. If you had any sense of ethics, you would share that desire. I am not interested in arguing for the sake of arguing, but I WILL attempt to correct misinformation such as yours. If that makes you sad, then please try to ensure that you do not spread misinformation.

      //Amanda, I thank you for writing this post. It has shown me that not everyone is a decent human being. By all means have your discussion, but don’t head the article with an individuals name and their business name. Clearly you do not intend to assist anyone with this article – it is not about helping anyone, but your ego.//

      Why would anyone thank someone for showing such a negative thing? Attacking someone’s character for trying to tell the truth is not especially positive, so you are hardly innocent of the charge you lay at the door of others. It is YOUR business that is making the misleading claims, so it is YOUR business that has to be named. If you feel that you have a defence against the accusations, then provide your evidence instead of making ad hominem attacks on those challenging your claims. Amanda’s company is called “Realize Beauty”. Yours is called “Amina Cosmetics”, and you accuse AMANDA of having ego issues!

      Please try to address the specific charges instead of making threats and ad hominem attacks. If you can rebut the accusations with credible evidence, I, for one, will publicly apologise.

      Just as an example of the problems we have, here is a quote from the SCA website:

      “show the Australian Government that it is not acceptable to consider chemicals innocent until proven guilty.”

      Please provide a full package of toxicological studies in support of every ingredient used by your company. This must include a multigenerational oral study in a least one species. I think that you will find that the data are not available, and that you are actually guilty of using chemicals on the presumption of “innocence” merely because they are natural in origin.

    • RealizeBeautyEd permalink*
      May 2, 2016 8:25 am

      Hi Amina,

      Thanks for making contact. I can understand where you are coming from with your comments especially after reading the conversation under the article.

      I wrote this a long time ago now but I remember feeling angered by the articles being published by Safe Cosmetics Australia. These days I just feel deep sadness. I work alone as an independent cosmetic chemist and actually have so little ego left that I am considering giving it up as it is personally soul destroying to see the art of chemistry reduced to a list of ‘goodies’ and ‘baddies’ without the appropriate context or alternative – and this process began way before SCA so I am not blaming you for that.

      I have written several responses to your feedback then erased them all, mainly because on reflection I see my original article as the response rather than an attack and further, that in writing an elaborate response of the kind that immediately came to mind I would, in fact be just offering up opinions on a situation that is far too complex and multi-layered for opinions alone. I agree that on re-reading my tone was a little more agitated than I usually manage but I am not sure there is a law against being agitated.

      I could erase the article but to be honest it has sat quietly on the blog for years during which time the tide has continued to flow away from ‘chemicals’ and towards naturals and certified cosmetics. My job of selecting ingredients for my formulating clients has only got harder thanks in part to the desire for a ‘clean’ INCI ‘free from’ a growing list of ingredients and, in spite of me explaining the chemistry and environmental footprint of newer technology to my client list many still choose to avoid these chemicals based on name alone. Now I am willing to accept that might just be because I’m an un-convincing and less-than-perfect sales person but that’s the truth of it.

      As for questioning my humanity, I respect that you have a right to do that and will leave it at that.

      Regards

      Amanda

  9. May 6, 2016 11:14 am

    Good Morning Amanda,

    Thanks for returning my call and posting this reply. I believe that as a chemist you would have an amazing understanding of chemicals and to be honest you sounded lovely on your voice message! I am sure that we would have a lot to talk about and I am certainly open to both sides of the debate here; there are man-made chemicals that help sustain our way of life and there is a place for all types of chemicals, natural or synthetic. Reading your reply, I can understand how this has impacted your job, formulating natural products that perform to a high standard is difficult – I hope that you continue your work despite the challenges as we all need science and chemists such as yourself.

    The regulations SCA seeks, is to have chemicals assigned to specific uses based on scientific studies prior to being permitted for use in Australian cosmetics – rather than the current format that does not test chemicals for health and safety prior to use. I can understand your initial reaction seeing a list of permitted chemicals and a list of nasty chemicals to avoid. However, in offering a toxic-free trademarked logo that consumers can identify with we also need to offer the information to the general public so that they can be informed and have confidence in our logo. Publishing the criteria that our accreditation is based on is essential so that consumers can decide for themselves if our criteria meets their needs. As stated on the website, the lists are neither complete and always evolving as new scientific studies and new chemicals become available.

    Published at the top of the list ‘nasty chemicals to avoid’ is the following statement;

    “Your health comes first, which is why SCA is reviewing hundreds of Australian brands that claim to be safe and natural. Accredited brands must meet our strict criteria, products must be formulated using plant and mineral based ingredients over petrochemicals and nasty synthetics. However, just because an ingredient is plant based doesn’t necessarily mean that it is safe for your health. The best advice is to use less products to avoid irritation and toxic accumulation of chemicals that concern your specific health requirements.”

    SCA offers an independent review system for Australian cosmetics; a platform for consumers who seek natural & organic products; a logo to easily identify brands that meet our toxic-free criteria. SCA seeks the truth in chemicals and until the Australian Government regulates the chemical industry, there is a place for a platform that encourages consumers to think about their health first over trusting a government that does not require mandatory product and ingredient testing.

    ****As we are all well aware, the issue of chemical safety needs to be addressed****

    The Australian Government is the regulatory system that has the ability to regulate chemicals and further determine the health and safety of cosmetic ingredients.

    The point of this conversation (the article posted above) raises many issues and at times pointed the blame towards myself and SCA – I should have expected this response from opposing individuals. Regardless, I do sincerely thank you for writing this article and I am apologetic for being offended by the article and for potentially offending you Amanda. As you’ve stated, there is no point in deleting the discussion. We all have our jobs to do and it is healthy to discuss this massive issue to gain insight and understanding from all perspectives.

    As for publishing the scientific studies that support SCA’s toxic-free criteria on our website, permission from the organisations to use their content is required. To focus on SCA’s mission, to provide a toxic-free standard that consumers can readily identify, it is not SCA’s responsibility to re-publish information that is already available to consumers. If you would like more information on chemical classification, health and safety, then you can find information including scientific studies published on hundreds of websites across the world, this is a global concern and one that consumers can choose to ignore or connect to if their particular circumstance drives them to do so. SCA also has a page under the “Resources” tab, see “Regulations” where you can find many other companies that promote natural and organic chemicals and also links to Australian and global regulatory organisations that publish information including studies that support SCA’s view point.

    Great to touch base with you and I look forward to following your blog. I would also like to take this opportunity to invite you to write an article to be published on SCA’s website. It would be of benefit to everyone to share your valuable insight and expertise on this matter.

    Also glad that I did post a reply on this article, I certainly don’t feel any harm has been done – quite the opposite really.

    Regards,

    Amina

    • RealizeBeautyEd permalink*
      May 6, 2016 9:21 pm

      Hi Amina, thanks for the response, I’m glad you have taken the time to explain a little more about SCA. I would be happy to come and spend some time with you and go through an example of the process of certification that you are working with. I am open to the idea of different ways of looking at the chemicals we use in cosmetics especially ways that result in the public being able to make a more informed choice about the products that they purchase. However, in my experience I have found it difficult to push past the prejudice that has arisen over certain chemicals to the point that many are now widely known as ‘nasties’ rather than as individual chemicals to be evaluated on their own merit based on the application they are put to. This for me is where marketing and market perception cloud the issue and I would not be wanting to sign up for promoting any more of that in any way (not that that is what you are asking/ implying). My other nagging issue is with the premise that regular cosmetics are unsafe when my experience shows me that safety is about so much more than just the ingredients in a product or even the sum of those ingredients. One has to consider the target market, manufacturing practice, preservation, packaging suitability, chemistry, physical characteristics of the product AND the directions for use to enable a decision of safety to be reached. In the EU a cosmetic has to pass through a toxicology or safety assessment prior to being placed onto the market, I have been working in this area for the last eight years and know how in-depth and all-encompassing the EU process is and yet chemicals that one might classify as ‘nasty’ can pass an assessment when formulated into a suitable product.
      So yes, let’s see if we can meet and chat and find out what can be done.

  10. May 14, 2016 10:14 pm

    Fantastic! I quite agree with what you are saying and there are certainly many issues that arise when discussing chemicals, product safety and doing the right thing by consumers. Ultimately the goal for anyone working in the cosmetics industry is to provide a safe and healthy product, I don’t think that anyone sets out to harm the general public with a shampoo or body lotion! But, it is alarming that chemicals are not tested prior to permitting them for use in formulating personal care products, and that many companies market their products as “natural & organic” yet the bulk of the product is often 98% man made synthetic ingredients. Implementing a platform such as Safe Cosmetics Australia, has proven to be fundamental in raising awareness of our Governments lack of chemical assessment. The mere fact that you post this blog and direct the title at Safe Cosmetics Australia identifying the campaign with chemicals and safety got you talking and that’s what we should all be doing. Talking about chemical safety and raising awareness for a healthier future.

    I completely agree with what you are saying, when you talk about labeling chemicals as ‘nasty’ or trying to arrange chemicals into any kind of acceptable list that categorizes ingredients – This is where the great chemical debate arises. If tests were carried out on each chemical prior to permitting them for use in cosmetic formulations, then we wouldn’t need to have this discussion. It is unfortunate that Australia lacks the regulations and the funding to test every single chemical available, but that is not a reasonable reason to subject consumers to hazardous chemicals. Back in 2012 our Government did not publish a single word on the fact that chemicals are not tested prior to use in cosmetics, consumers did not realise that the beauty products they used contained chemicals that had not been tested – today there is so much evidence available at everyone’s fingertips that finally we are seeing this issue addressed. It certainly won’t be resolved quickly, but if people don’t raise concern for their own health and the environment we live in, then we all have a lot to answer for.

    Safe Cosmetics Australia supports the National Toxics Network (NTN) in pursuing assessment of chemicals prior to use in Australian Cosmetics and furthermore, publishing public lists of chemicals that are Exempted or Reported chemicals.

    “NTN would like to make it clear that by making submissions and participating in this reform process, we are not endorsing the Government’s approach to these reforms. We will continue to advocate for a pre-market regulatory scheme that puts the health of the community and environment at the centre of regulatory decision-making as well as addresses the significant problem of un-assessed chemicals already in widespread use.”

    Recommended reading:

    National Toxics Network (NTN) https://www.nicnas.gov.au/communications/consultations/past-consultations/nicnas-reforms/public-submissions-on-nicnas-reforms-consultation-paper-2/national-toxics-network-ntn

    Submitted: 1 April 2016
    Submission: Implementing reforms to the National Industrial Chemicals Notification and Assessment Scheme
    Consultation Paper 2

    The National Toxics Network (NTN) attended the Sydney Workshop on Consultation Paper 2 and appreciates the opportunity to make a submission on Implementing Reforms to the National Industrial Chemicals Notification and Assessment Scheme, Consultation Paper 2.

    When the Government first put forward options for reforming NICNAS, NTN supported Option 5, which outlined a pre-market regulatory focus to provide the greatest certainty for industry and the best protections for human health and the environment in the regulation of industrial chemicals.

    The Government however has taken the opposite approach. The reforms as detailed in Consultation Paper 2 aim to ‘cut regulatory red tape’ by exempting ‘low-risk’ new chemicals from pre-market regulatory oversight, relying instead on industry self assessment and post-market surveillance, although few details have been provided about the scope and budget for this work.

    The rationale given for the reforms is that regulatory effort should be better aligned with risk so that a ‘lighter touch’ regulatory approach can be applied to lower risk chemicals, supposedly freeing up resources for NICNAS to work on high risk chemical assessments and the problem of un-assessed chemicals already in use.

    No data is presented to support the assumption that industry will respond by getting safer chemicals to market faster. An analysis of previous initiatives such as ‘low regulatory concern chemicals’ could have provided some useful data.

    What’s hidden from public view in this reform process is the fact that there are already 38,000 un-assessed chemicals listed on the Australian Inventory of Chemical Substances (AICS). By any reasonable assessment this represents a significant and unknown risk to public health and the environment, but little is specified in the reforms as to how this problem will be addressed.

    Consultation Paper 2 at least provides some reassurance that there will continue to be NICNAS initiated assessments that will replace the IMAP and PEC programs, but the scope and budget for this work have not been detailed.

    The Consultation Paper states that, ‘a fundamental principle of the reforms is that health, worker safety and environment protections must be maintained’.

    We say protections that protections should be improved not just maintained. By ‘maintaining’ it implies that what is already occurring is effective and adequate, when clearly it is not.

    NTN would like to make it clear that by making submissions and participating in this reform process, we are not endorsing the Government’s approach to these reforms. We will continue to advocate for a pre-market regulatory scheme that puts the health of the community and environment at the centre of regulatory decision-making as well as addresses the significant problem of un-assessed chemicals already in widespread use.

    Specific points:
    International assessments:

    We do not support industry’s position that the Health Minister’s criteria for use of international assessments be disregarded in order to ensure USEPA risk assessments are accepted. If the USEPA reports don’t meet the criteria established by the Health Minister, then they can’t be used. This pathway can lead to hazardous chemicals being introduced without NICNAS assessment, so criteria must be adhered to.

    We would like to see details of how NICNAS with engage with state and territory risk managers in relation to accepting international decisions and by what mechanisms will the enforcement of any risk management requirements occur? If risk managers don’t step up to the mark, what will happen?

    We are concerned that hazardous cosmetic ingredients in ‘low concentrations’ will be subject to ‘light touch regulatory approach’. In some instances, such as EDCs, low concentrations are still highly hazardous. What about nanomaterials? Why rely only on volume data and not hazard data in this instance? It’s contrary to the approach taken elsewhere.

    We do not support the approach taken by the USEPA for industry to self-assess the public health risks from use of cosmetics and do not support Australia going down that path.

    Exempted and Reported chemicals:

    From the outset, community representatives have raised concerns about the proposal for exempted and reported chemicals to not be publically recorded. What happens down the track if one of those exempted chemicals industry has self-assessed as ‘low risk’ turns out to be a high risk?

    For instance, what if a chemical were later discovered to be an EDC or carcinogen? How would anyone be able to trace back to ascertain any details? If chemicals get used in unintended ways down the track, the risk profile also changes and there would be no way to determine that.

    We do not support the downgrading of requirements for introducers to only declare a limited set of information, as we believe volume, type and use is essential information to record. If a use changes, then exposure risks change and this needs to be reported and recorded.

    If these reforms are adopted it is envisaged that thousands of chemicals will be self-assessed by industry as exempted but no details are given as to the scope and budget proposed for post-market auditing to ensure these chemicals are in fact low risk. Given the track record of industry in the past, it’s understandable that consumers would be concerned about industry self-assessments. Eg – BPA, phthalates, PFCs, triclosan etc etc.

    Transparency and Accountability

    As with all risk assessments the quality of the data will determine the robustness of the outcome. We have serious concerns about industry ‘self assessing’ based on its own data. By allowing this Government will be failing in its commitment to transparency and accountability to the community in regulatory decision-making.

    We want to see a publically available list of registrants on the NICNAS website as well as a list of Exempted and Reported chemicals. If industry is genuinely introducing low risk chemicals then the community has a right-to-know what they are so that they can make informed choices in the marketplace. We see this as positive information that industry would want the community to know about.

    We support the linking of assessment reports/summaries and useful information about risks to entries on AICS. We understand there are issues concerning CBI, but as a principle, the community should have access to as much information as possible. If adequate protections can be found we support the merger of the confidential AICS with public AICS.

    If the Director is to be given the power to amend AICS, then the decision-making process must be public and accountable.

    While not within the scope of the proposed reforms, we would like to point out that it is totally unacceptable that so many products already in the marketplace do not list on their labels what the chemical contents are.

    It would be totally unacceptable to move NICNAS from the Health portfolio to the Industry portfolio, as has apparently been proposed by industry. The National Industrial Chemicals Notification and Assessment Scheme (NICNAS), established in 1990 under the Industrial Chemicals (Notification and Assessment) Act 1989 (the Act) states:

    The objects of the Act are to provide for: aiding in the protection of the Australian people and the environment by finding out the risks to occupational health and safety, to public health and to the environment that could be associated with the importation, manufacture or use of the chemicals.

    Risk Matrices

    The fundamental problem with the proposed risk matrices is that there appears to be no limits to risk. It is not acceptable that a chemical that is PBT, EDC or ozone depleting could even be assessed and theoretically permitted for use, albeit with risk management strategies. There are some hazards the community is no longer willing to wear.

    Nanomaterials need to be treated separately. It is unthinkable there could quantities of <100kg permitted in low bands on the risk matrice for research.

    Direct Releases

    The definition doesn't appear to take into account intentional and direct release to the atmosphere, for instance, in the flaring of gas wells, which contain industrial chemicals used to frack for coal seam gas or the release to the atmosphere of industrial chemicals in wastewaters stored in open evaporation ponds in mining processes.

    In terms of the appropriate treatments mentioned, what happens when there isn't an appropriate treatment? For example, triclosan which is added to products designed to be washed down the drain such as toothpaste and soap, cannot be readily removed by sewage treatment plants. Why is it permitted in products when there is no appropriate disposal method?

    Confidential Commercial Information

    We do have concerns that the process and decision to determine whether a company’s application for confidentiality outweighs public interest would be made entirely ‘in house’ or by the NICNAS Director, without any independent oversight as previously occurred with the NICNAS Technical Advisory Group

    https://www.nicnas.gov.au/about-nicnas/nicnas-reforms/consultation-paper-3/exempted-and-reported-chemicals

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