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Background Information on Ingredients in So-Called "Natural" BodyCare Products

from http://www.terressentials.com

* = organic or certified organic designation for ingredient

Here is a link to the EPA report "PPCPs as Environmental Pollutants
Pharmaceuticals and Personal Care Products in the Environment: Overarching Issues and Overview" by Christian G. Daughton:

http://www.epa.gov/esd/chemistry/pharma/book-summary.htm

The words "synthetic" and "natural" are defined by the USDA below:

{From http://www.ams.usda.gov/nop/NOP/standards/DefineReg.html }

Synthetic: A substance that is formulated or manufactured by a chemical process or by a process that chemically changes a substance extracted from naturally occurring plant, animal, or mineral sources, except that such term shall not apply to substances created by naturally occurring biological processes.

Nonsynthetic (natural): A substance that is derived from mineral, plant, or animal matter and does not undergo a synthetic process as defined in section 6502(21) of the Act (7 U.S.C. 6502(21)). For the purposes of this part, nonsynthetic is used as a synonym for natural as the term is used in the
Act.

Synthetics are generally not permitted in products regulated as
"organic."

Regarding the "organic" claims of the products you purchased:

In the vast majority of "organic" personal care products where a percentage of organic ingredients is specified, the allegedly organic content is mostly water, and most of the remaining content is synthetic. For more information about what is called "the hydrosol issue," see...

/old_articles/bodycare/040603_organic_standards_hydrosol_natural_cosmetics.cfm

Often a product label will read "with certified organic ingredients" or even "with 100% certified organic ingredients," sometimes with an official-looking seal. Although this leads the consumer to assume that the entire product is certified organic, there is often just a small amount of truly organic material in the product, but technically the "made with" claim is true, if misleading. (The "100%" claim may refer to a single ingredient, which is in itself "100% organic," even if other ingredients are non-organic or synthetic.)

In some cases, little in the way of actual organic claims are made for a product or its ingredients, but the company name features the word "organic" prominently, leading consumers to assume that the product is in some way organic. Such an assumption is unfounded. Here's what the USDA National Organic Program has to say about the use of the word "organic" in company names:

"Organic in Company Names: Many commenters stated that the term, 'organic,' must not be used as part of a company name if the company does not market organically produced foods. They are concerned that the term in a company name would incorrectly imply that the product, itself, is organically produced.

"While we understand commenter concerns, we do not know the extent of the problem. We do not believe those concerns require such a prohibition in the regulations at this time. These regulations may not be the best mechanisms to address the issue. Section 6519)b) of the Act provide the Secretary with the authority to take action against misuse of the term, 'organic.' USDA will monitor use of the term, 'organic,' in company names and will work with the FTC to take action against misuse of the term. These determinations will be made on a case by case basis. The proposed rule did not specifically address this issue."

The phrase "100% Natural" is, unfortunately, meaningless. Everything in existence, including all manmade substances and objects, is ultimately derived from natural sources.

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allantoin -- a component that does occur in plants; however, when it is sold as a cosmetic ingredient, it meets the USDA definition of
"synthetic" as it
has been chemically isolated and refined or synthesized from chemical sources.

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aloe barbadenis -- incorrect spelling of the latin name for the common "aloe" aloe barbadensis gel*/aloe barbadensis* -- also known as aloe or aloe vera. aloe vera -- see above aloe vera gel* -- see above aloe vera* -- see above

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apricot kernel oil -- a botanical oil used in cosmetics. Not considered an edible oil. May be solvent-extracted or cold-pressed.

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aqueous (water) extract = infusion -- when you make a cup of tea or coffee, this is an infusion. Have you ever made a cup a tea or coffee that was crystal clear? Often companies load up a label with an ingredients label that lists many herbs, usually as extracts or infusions, yet the product is crystal clear or white. In the cosmetic industry, this is known as "window dressing" or "fairy dusting." There are no regulations that stipulate how much of an ingredient actually needs to be in the product to be included on the label, so many companies use miniscule, perhaps even infinitesimal, quantities of herbs.

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ascorbyl palmitate -- synthetic, according to the USDA definition. A salt or ester of ascorbic acid that is used as part of a preservative system in cosmetic and food products that contain oils.

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beeswax -- a natural wax produced by bees. It is FDA approved for use in foods and cosmetics. Most beeswax commercially available for use in cosmetics is refined, bleached, deodorized and may have additional chemical treatments. Organically produced beeswax is available, but few "organic" companies use it.

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biotin -- one of the B vitamins. Often referred to as B7. It is water soluble. It is often included in personal care products for the hair, although the European Journal of Dermatology reports that there are no clinical studies to substantiate its use for hair growth.

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bis-diglyceryl polyacyladipate-2 (vegetable oil) -- this ingredient is not simply vegetable oil. It is a synthetic oleochemical of the glyceryl ester family.

According to the European Union it is defined as follows: BIS-DIGLYCERYL POLYACYLADIPATE-2 Adipic acid, oxybispropanediol diester, esters with mixed caprylic, capric isostearic, stearic and hydroxystearic acids

According to the US EPA, Adipic acid (C6H10O4) is a white crystalline solid used primarily as the main constituent of nylon (nylon-6/6), representing about half of the nylon molecule. It is also used in the manufacture of some low-temperature synthetic lubricants, synthetic fibers, coatings, plastics, polyurethane resins, and plasticizers, and to give some imitation food products a tangy flavor and as an acidity regulator.

It is produced in 4 facilities in the U.S. Worldwide and demand for adipic acid in 1989 was nearly 2 billion tons, with growth continuing at a steady rate. The U.S. is the world's major producer, with three companies in four locations accounting for approximately 40 percent of world production.

Adipic acid production is the largest potential source of industrial N2O emissions. {Nitrous oxide is generated as a by-product of the nitric acid oxidation stage and is emitted in the waste gas stream.)

The EPA states that N2O is a potent greenhouse gas (GHG) and that "two large industrial sources of N2O emissions are adipic and nitric acid production."

Adipic acid historically has been manufactured from either CYCLOHEXANE
(a
petrochemical) or PHENOL (extremely hazardous chemical), but shifts in hydrocarbon markets have nearly resulted in the elimination of phenol as a feedstock in the U.S. This has resulted in experimentation with alternative feedstocks, which may have commercial ramifications.

Process Description: 1,4-5 Adipic acid, HEXANEDIOIC ACID; 1,4-BUTANEDICARBOXILIC ACID also known as DIBUTYL ADIPATE or Adipic acid dibutyl ester, is manufactured from CYCLOHEXANE in two major reactions. The first step is the oxidation of CYCLOHEXANE to produce cyclohexanone (a ketone) and cyclohexanol (an alcohol). This ketone-alcohol (KA) mixture is then converted to adipic acid by oxidation with nitric acid in the second reaction. Following these 2 reaction stages, the wet adipic acid crystals are separated from water and nitric acid. The product is dried and cooled before packaging and shipping. Adipic axid is freely soluble in methanol, ethanol; soluble in acetone.

Cyclohexane has NOT been evaluated for carcinogenicity by the United
States Environmental Protection Agency or the International Agency for Research on Cancer (U.S. EPA, 1995a).

Here is a chemical industry link for additional uses of Dupont's Adipic
Acid:

http://www.dupont.com/intermediates/products/adipure.html

According to Dupont, Adipic acid, like other dibasic carboxylic acids, undergoes typical reactions such as amidation, reduction, halogenation, dehydration, neutralization to form salts, and esterification.

Adipic acid may be an irritant to the eyes and upper respiratory tract and a mild irritant to the skin. Effects of exposure to adipic acid may result in skin irritation, evident by a rash or skin discomfort, and/or eye irritation, indicated by tearing, discomfort, or blurred vision. Slight to moderate corneal injury may also result from contact with adipic acid. Irritation of the mucous membranes and the upper respiratory tract are also possible when adipic acid is inhaled or ingested.

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borage oil -- extracted from the seeds of the Borage (borago officinalis) plant. It may be extracted with toxic petrochemical solvents or cold-pressed. It is used as a dietary supplement and as a topical cosmetic oil. Borage leaves, flowers and stems contain trace amounts of toxic pyrrolizidine alkaloids (PA's), linked to cancer and liver damage. REFINED borage oil can contain small amounts of pyrrolizidine alkaloids.

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bulgarian rose water* -- a by-product of essential oil steam distillation. May also be called a "hydrosol" or "floral water."

It is very important to note here that there are NO STANDARDS for the creation of hydrosols. Because there are no standards, a company could (and probably does) use, perhaps, 1 pound of lavender flowers in a distiller and run 500,000 gallons of water through it and call the resulting waste water a "hydrosol."

For some background on this issue, and to see the Formal complaint filed to the California State Organic Program from Organic Consumers Association, regarding Avalon's misleading labeling practices go to this web page: /old_articles/bodycare/avalon_complaint.cfm

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C12-14 olefin sulfonate (coconut derived) -- Also known as alpha olefin sulfonate, this is a synthetic chemical surfactant/detergent and it is often represented as "derived from coconuts," but in fact, according to the report
HOUSEHOLD CLEANERS by the University of Tennessee's Center for Clean
Products and Clean Technologies, olefin sulfonates may contain contain traces of benzene, which is a carcinogen or reproductive toxin, and may also release it into the environment during the manufacturing process (as it is created using petrochemicals).

According to the Swedish Society for Nature Conservation's* LIST OF
SURFACTANTS (June 21, 2001), olefin sulfonate is a category 4 surfactant and is NOT approved for use in eco-labelled products. Olefin sulfonate contains 50% or more petroleum derivatives and is not considered to be a readily biodegradeable or nontoxic to aquatic organisms.

The Swedish Society for Nature Conservation is an internationally recognized source of the cosmetic chemical industry for environmental standards.

http://skarv.snf.se/pdf/dok-bmv-tensidlista.pdf

According to the LABORATORY OF FORMULATION, INTERFACES RHEOLOGY AND PROCESSES (FIRP) at the UNIVERSIDAD DE LOS ANDES in Venezuela, the
alpha-olefin resulting from polymerization is used as an alkylate in a Friedel-Crafts reaction that ends in an alkyl-benzene. By sulfonation and neutralization, an alkyl-benzene sulfonate of the detergent type is produced at a low cost, much lower than a soap from natural oil and fat origin.

http://www.firp.ula.ve/cuadernos/E300A.pdf

2.4.2. ETHOXYLATED ALCOHOLS

Linear alcohols in C12-16 are used to prepare the alkyl-ester-sulfates used as detergents or foaming agents in shampoos, toothpastes and hand dishwashing products. Ethoxylated alcohols tend to displace ethoxylated alkylphenols, which are fading away because of their toxicity. Alcohols can be made by controlled hydrogenation of natural fatty acids. However, this is a costly way and in most cases they are produced by one of two available synthetic routes, as follows:

The first one consists in oxidizing the Ziegler tri-alkyl aluminium complex (see section 2.3.2) and hydrolysing the resulting ether. This is called the ALFOL (alpha-olefin-alcohol) process.

3.4.2. DODECYL BENZENE SULFONATE AND SYNTHETIC DETERGENTS. During
WWII, the catalytic cracking processes were developed to produce high octane aviation gasoline. The cracking of a paraffin results in the formation of a shorter paraffin and an alfa-olefin, in the present case a propylene molecule. Thus it was possible to manufacture a cheap alkylbenzene sulfonate by a series of "easy to carry out" reactions.

3.4.4. ALPHA OLEFIN SULFONATES. Since most linear alkylates are often alpha olefins, which can be sulfonated, it is worth asking the question: why have alpha olefin sulfonates not displaced alkyl benzene sulfonates, since the latter exhibit an expensive and potentially toxic benzene ring?

The principal problem is that the sulfonation of an alpha olefin results in various compounds, such as the alpha olefin sulfonate (60-70 %), the hydroxy-alkane sulfonate (20 %), and even some amount of beta-olefin sulfonate and sulfate of hydroxy-alkane sulfonate.

Alpha-olefin sulfonates display a better hard water tolerance than LAS, but they are not as good detergents; they are used as additives, particularly in low phosphate formulas : C12-14 in liquids, C14-18 in powders.

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canola oil -- a vegetable oil, often highly refined. Although it is promoted as an edible oil, it is a controversial oil. It is extracted (solvent extracted with hexane, a toxic solvent) or cold-pressed from rapeseed, a member of the mustard family. Originally, the seeds contained high levels of erucic acid, an acid that can be potentially toxic to humans, but the plant was hybridized decades ago to reduce the toxic erucic acid levels. Some groups insist that the levels of erucic acid are not low enough for the oil to be considered a daily use oil, while others recommend it for daily use and high heat cooking.

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caprylic acid -- see below caprylic/capric triglyceride -- A synthetic oleochemical, it is often listed as being derived from coconut oil. It is a fractionated, waxy-feeling component of coconut oil and contains only small, saturated, or lower fatty acids without the C12 and C14 (lauric and myristic) acids. It is used in cosmetics as an emollient because it provides manufacturers with a long shelf life without requiring anti-oxidants and gives a waxy, less oily feel to a product.

The esterified form of this ingredient is known as caprylate. The acid form is caprylic (acid).

Many oleochemicals, esterified ingredients and fatty acid esters involve the use of toxic ingredients such as amyl alcohol or fusel oil in their manufacture.

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carrot seed extract -- the question here is how this "extract" is made and why is it not organic? See also "natural carrot flavor" below.

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castor seed oil -- The oil has been used as an industrial lubricant, lamp oil, hot compress, laxative, body care product, etc. The plant material, stalks and leaves, when dried after a harvest, are a highly potent allergen/sensitizer and cause severe, disabling allergic asthma in workers who handle the material. The mash that remains after the oil has been pressed or solvent-extracted is toxic to many animals. The majority of castor oil that is produced today is produced in the Middle East, India and Africa. Curiously, there are no significant scientific studies that can strongly document skin healing properties or other therapeutic effects.

There are two interesting things that can be reported about this oil:
1) it has never been used as a food for humans and 2) when you type the words "castor oil army ricin" into the search engine "google," there are 1950 results linking to the potential use of ricin (a deadly component of castor beans) being used in biowarfare terrorist attacks to kill U.S. citizens and many listings for our government's and the military's concerns about ricin's ease of manufacture, and the virtually unlimited quanitities of castor beans available for processing ricin.

For an enlightening report on castor beans and ricin production visit the article (link below) from the Harvard Independent magazine titled
"Iraq Sharpens Weapons Disguise."

http://www.harvardindependent.com/main.cfm/include/smdetail/synid/6388
4. html

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ceramide 3 -- A synthetic N-acylated sphingoid chemical base that is identical to any one of the many constituents of the natural ceramides (as found in human skin) and will have an INCI (International
Nomenclature of
Cosmetic Ingredients) labelling name using the term ceramide followed by a

number (e.g. Ceramide 3) or a number and Roman numeral (e.g. Ceramide
6II).

The term ceramide as part of the INCI name will only be assigned to a SYNTHETIC-N-acylated sphingoid base that contains, as the predominant component, the erythro isomer of at least one of the many natural ceramides..

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cetearyl glucoside -- A synthetic oleochemical. Many oleochemicals are created in environmentally-unfriendly industrial processes. This oleochemical is often referred to as a "vegetable emulsifying wax" and is derived from corn (not organic -- so GMO?) and coconut.

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cetyl alcohol -- A synthetic oleochemical often derived from coconut in products labeled as "natural." It may also be known as cetyl stearyl alcohol or emulsifying wax, which is a mixture of cetyl and stearyl alcohols, and it may be animal, vegetable or petrochemical derived. It is used in cosmetics as an emulsifier, emollient and thickener in creams, lotions and conditioners.

It is most often manufactured using toxic chemicals such as methanol or sodium methylate along with a catlyst like copper chromate (a
CARCINOGEN) under extreme temperature and pressure.

Many methods of producing fatty alcohols or other oleochemicals create TRANS-Fatty acids in the final product as a result of their manufacturing process. Trans-fats or trans-isomers can have detrimental effects on human skin because of their ability to inhibit prostaglandins. Prostaglandins are manufactured by the human body and are found in cell walls and tissues and are essential for maintaining healthy cell walls. If prostaglandins are inhibited, serious skin disorders can occur. Trans-fats can also create free radicals which can contribute to cellular mutations.

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citric acid -- A synthetic chemical that is derived primarily from conventionally-grown corn and corn glucose. It is often used in cosmetics as an acidifier, for color retention and as part of a preservative system.

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clary sage floral water* -- a by-product of the steam distillation of essential oil production. clary sage oil* -- an essential oil

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cocamidopropyl betaine (CAPB) -- A synthetic surfactant (detergent) made with petrochemical amines and fatty acids (sometimes coconut fatty acids).

CAPB does not appear to have undergone any studies of reproductive or developmental toxicity or neurotoxicity or chronic studies of systemic effects. The single carcinogenicity study employed CAPB in a formulation. Without any remarkable response, its results suggest that CAPB does not increase systemic tumors above background, but are not enough to be conclusive. Although no dermal subchronic toxicity testing appears to have been performed, results of a 28-day oral test suggest a CAPB potential for irritation, which is consistent with outcomes from a collection of patch and ocular animal tests.

Absorption/Metabolism -- No studies were found on the absorption, distribution, metabolism, and excretion of CAPB. It is unclear whether the amide bond of CAPB can be hydrolyzed to yield the fatty acids and 3-aminopropylbetaine. No metabolism data are available on the latter compound.

Acute Toxicity -- Humans -- No studies have been located discussing acute effects of CAPB in humans by any route of administration.

Neurotoxicity -- No studies have been located discussing neurotoxic effects of CAPB in humans or animals.

Developmental/Reproductive Toxicity -- No studies have been located discussing reproductive or developmental effects of CAPB inhumans or animals.

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cocoamphocarboxyglycinate -- A synthetic surfactant (detergent).

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collagen protein -- may be synthetically derived from plants, but usually derived -- chemically isolated, denatured, refined and stabilized from slaughterhouse by-products -- often bovine sources. It is included in creams and lotions and claims are made for tissue repair although it is doubtful that topical applications can have any actual effect on skin tissues.

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cucumber extract -- most often extracted, refined, stabilized and preserved with synthetic chemicals.

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dimethicone -- A synthetic chemical of the silicone family. They are created using petrochemically-derived methanol -- a toxic alcohol. They are used in personal care products as lubricants, and foam suppressants in household detergent products.

Researchers have investigated silicon materials/compounds in association with several different illnesses: lupus, scleroderma,
A.D.D. and cancer. Some researchers speculate that silicon may be linked to allergies, fibrocysts and irritable bowel syndrome. (Remember the silicone breast implant controversy?)

Silicon-containing chemicals and polymers create environmental hazards in their manufacturing which relies on high-temperature processing that can generate byproducts such as hydrochloric acid.

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dl-panthenol (lecisome-p) -- synthetic Pantothenyl alcohol (B vitamin)

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ergocalciferol (vit. d) -- synthetic acccording to the USDA definition.

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essential oil of bergamot -- Why is this not a certified organic oil? It IS commonly available.

essential oil of lavender -- Why is this not a certified organic oil? It IS commonly available.

essential oil of lemongrass -- Why is this not a certified organic oil? It IS commonly available.

essential oil of ylang ylang -- Why is this not a certified organic oil? It IS commonly available.

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eucalyptus -- This is a VERY vague and non-compliant ingredient listing. Is it an essential oil? A powder? An extract? A hydrosol? From the leaf? The root?

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extra virgin olive oil* -- Excellent for the skin and delicious on pasta!

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See also "aqueous (water) extract = infusion" above.

THE FOLLOWING EXTRACTS COULD ALL BE LEGITIMATE EXTRACTS. TRUE ORGANIC EXTRACTS WOULD BE EXTRACTED USING ONLY CERTIFIED ORGANIC ALCOHOL.
Non-organic extracts may use toxic petrochemical solvents such as hexane, methanol or acetone.

extract of anthemus nobilis (chamomile)* extract of chamomile* extract of echinacea* extract of gardenia florida extract of ginkgo biloba* extract of green tea* extract of lavender* extract of lemon balm* extract of rosemary* extract of symphytum officinale (comfrey)* extract of yucca schidigera

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SEE BULGARIAN ROSE WATER ABOVE

floral water of chamomile* floral water of echinacea* floral water of lavender*/lavender floral water* floral water of lemon balm* floral water of rosemary*

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germall -- registered trademark. The INCI name is DIAZOLIDINYL UREA. This is a synthetic chemical preservative.

According to author Ruth Winter, this chemical may release formaldehyde which is a potent sensitizer. She also stated that the National Cancer Institute reported that formaldehyde is involved with DNA damage and may react synergistically with other chemicals to produce mutagenic and carcinogenic effects and, as a result, should be investigated further.

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glycerin (vege) -- This oleochemical is identified on the National Organic Program's National List of Prohibited and Allowed substances as a synthetic material. It is used as a humectant in moisturizers for its ability to draw moisture into itself. It is also used as a carrier for herbal extracts.

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glyceryl stearate/glyceryl stearate SE -- These are synthetic esterified oleochemicals that may be derived from animal, vegetable or petroleum sources. They are used in cosmetics as emollients and as emulsifiers. They are industrially-produced using toxic alcohols, acids and catalysts, and may contain trans-fats in the final product.

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glycine -- A synthetic amino acid that is used as a "texturizer" in cosmetic products.

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grapefruit seed extract/grapefruit seed (citrus derived) -- GSE is a synthetic quaternary ammonium compound that is not permitted in organic food products.

According to the USDA's Agricultural Research Service's study on grapefruit seed extracts ("IDENTIFICATION OF BENZETHONIUM CHLORIDE IN COMMERCIAL GRAPEFRUIT SEED EXTRACTS"): "Confirming an earlier study by researchers in Germany we found that some commercial grapefruit seed extracts contain benzethonium chloride, a synthetic antimicrobial agent commonly used in cosmetics and only approved for topical use, at relatively high levels of
8%."

The Institute of Pharmacy, Ernst Moritz Arndt University, in
Greifswald, Germany in a study found that "The antimicrobial efficacy as well as the content of preservative agents of six commercially available grapefruit seed

extracts were examined. Five of the six extracts showed a high growth inhibiting activity against the test germs Bacillus subtilis SBUG 14, Micrococcus flavus SBUG 16, Staphylococcus aureus SBUG 11, Serratia marcescens SBUG 9, Escherichia coli SBUG 17, Proteus mirabilis SBUG 47, and Candida maltosa SBUG 700. In all of the antimicrobial active grapefruit seed extracts, the preservative benzethonium chloride was detected by thin layer chromatography. Additionally, three extracts contained the preserving substances triclosan and methyl paraben (synthetic petrochemical preservatives). In only one of the grapefruit seed extracts tested no preservative agent was found. However, with this extract as well as with several self-made extracts from seed and juiceless pulp of grapefruits (Citrus paradisi) no antimicrobial activity could be detected (standard serial broth dilution assay, agar diffusion test). Thus, it is concluded that the potent as well as nearly universal antimicrobial activity being attributed to grapefruit seed extract is merely due to the synthetic preservative agents contained within. Natural products with antimicrobial activity do not appear to be present."

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grapeseed oil -- an oil extracted from seeds of conventionally-grown grapes.. It is not an oil with a history of human consumption. Pesticides, herbicides, fungicides, etc., tend to accumulate in fatty tissues, thus, an oil extracted from grape seeds might contain high concentrations of agricultural petrochemicals used in conventional grape farming.

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guar -- a botanical gum from seeds of guar plant, grown in India.

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helianthus annuus (sunflower oil)* -- An edible oil crushed from sunflower seeds.

sunflower oil*

sunflower seed oil -- Why is a non-organic sunflower oil being used in a product that is labeled as "organic" when sunflower oil is easily obtainable?

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henna extract -- Henna is also known as Lawsonia inermis -- a shrub that grows in Africa and near East. It sold as dried, ground herb to be mixed with water to make a thick paste for home hair coloring use.

A henna extract is an uncommon ingredient and makes one wonder how it is extracted AND, if it is in an "organic" product, why the henna is not certified organic, as henna is available as organic.

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high oleic safflower oil* -- An edible oil crushed from safflower seeds.

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honeysuckle extract -- This ingredient could be a legitimate natural extract, depending upon the method of extraction. Honeysuckle flowers are not widely available as organic.

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hydroxypropyl methylcellulose -- a thickener, binding agent, viscosity adjustor, emulsion stablizer. It is created with petrochemicals.

It is also known as propylene glycol ether of methylcellulose, 2-hydroxypropyl methyl ether or modified cellulose.

According to the Organic Materials Review Institute, HPMC is
considered to be part of the group of compounds know as cellulose ethers. Various reaction products with methyl chloride are known as the methyl celluloses. This group includes carboxymethylcellulose (CMC) or cellulose gum; hydroxypropylmethylcellulose (HPMC) or carbohydrate gum; and methyl cellulose (MC, INS no. 461) or modified vegetable gum (Whistler, 1997).

Methlycellulose is derived from alkali cellulose reacted with methyl chloride that adds methyl ether groups. The MC is then also reacted with propylene oxide to form HPMC. Other methyl cellulose derivatives include hydroxyethylmethylcellulose (HEMC), and hydroybutylmethylcellulose
(HBMC)
(Whistler 1997, Kirk Othmer 1993).

The cellulose ethers are manufactured by a reaction of purified cellulose with alkylating reagents (METHYL chloride) in presence of a base, typically sodium hydroxide and an inert diluent. The addition of the base in combination with water activates the cellulose matrix by disrupting the crystalline structure and increasing the access for the alkylating agent and promotes the etherification reaction. This activated matrix is called alkali cellulose (Kirk-Othmer, 1993). During the manufacture of HPMC, alkali cellulose reacts with methyl chloride to produce methyl cellulose and sodium chloride. Side reactions of the methyl chloride and sodium hydroxide produce methanol and dimethyl ether by-products. The methylcellulose is then further reacted with the staged addition of an alkylene oxide, which in the case of HPMC is propylene oxide (Kirk Othmer, 1993; Dow, 2002).

Methlycellulose cannot be produced from a natural source and has no organic ingredients as substitutes. HPMC is derived from cellulose which itself was determined to be a synthetic by the NOSB. There is no known way to produce HPMC naturally.

METHYL chloride (CH3Cl) is colorless gas with a faint, sweet odor that is not noticeable at dangerous concentrations. Synthetic forms are a chlorinated hydrocarbon derived from petroleum, and a suspected CARCINOGEN (Lewis, 1992; NJ 1998). It is also generated from incineration of municipal and industrial waste; though natural sources, primarily oceans and biomass burning, constitute most of the global release into the environment (WHO,
2001). Propylene oxide is also a petroleum derivative, with a large volume and importance in the polyurethane and surfactant industry (Kirk-Othmer,
1996). There are two principal processes used: the traditional chlorohydrin process and indirect oxidation by the hydroperoxide process that uses a molybdenum catalyst. Both processes start with propylene (propene) derived from cracking of petroleum.

Methyl chloride is considered hazardous and is regulated by OSHA, NIOSH, DOT, DEP and EPA. It is highly flammable. It has been the subject of increased regulation for worker exposure (KSU 2002). It is released in the atmosphere during production and incineration, and naturally from the ocean.. It is considered an ozone depleting substance and estimated to contribute 15% of the total equivalent of effective stratospheric chlorine. It has less effect than other ozone depleting compounds (CFCs) and is not thought to be a significant contributor to global warming. The main degradation path in the environment is through volatilization, as it is slowly hydrolyzed in soil and groundwater, but little information is known about biodegradation (WHO 2001). Methyl chloride is readily absorbed in human lungs and causes neurotoxicity, lung irritation, dizziness, drowsiness, blurred or double vision, and may damage liver and kidneys (NJ 1998, WHO
2001). Animal studies show carcinoma and mutagenic effects, and it is a suspected human carcinogen and weak mutagen (WHO, Lewis 1992).

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ALL OF THE FOLLOWING COULD BE LEGITIMATE TEAS. If one or more is included on a product label and the teas were truly organic AND in the product, that product would absolutely NOT be clear or bleached white. The product would really need to be a golden to brown color.

infusion of bilberry* -- These fruits are in the blueberry family. Does the product that contains this infusion have a dark blue color? If not, why not? infusion of birch leaf oil* (does this mean infused in oil versus water?) infusion of calendula* infusion of chamomile flowers* infusion of chamomile oil* (does this mean infused in oil versus water?) infusion of chickweed* infusion of clary* [should say clary sage] infusion of cleavers* infusion of coltsfoot leaf* infusion of comfrey root* infusion of echinacea* infusion of golden seal* infusion of gotu kola* infusion of hops* infusion of horsetail oil* (an infusion in oil?) infusion of lavender* infusion of lemongrass* infusion of licorice root* infusion of mallow* infusion of marshmallow root* infusion of nettle oil* (an infusion in oil?) infusion of nettle* infusion of olive leaf* infusion of red clover* infusion of rose hips* infusion of rosemary oil* infusion of sage* infusion of slippery elm* infusion of thyme oil* (an infusion in oil?) infusion of witch hazel* infusion of yarrow oil* (an infusion in oil?) infusion of yellow dock* infusion of yucca*

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jojoba butter*/jojoba wax* -- According to the article "Trans Isomers in Cosmetics" in Soap & Cosmetics magazine (May 2001) by James Brown and Robert Kleiman "the CTFA includes a listing for 'Jojoba Butter' a transisomerized (synthetically-processed form) of Jojoba oil containing about 50% trans isomers."

Brown and Kleinman also reported that "Trans fatty acids have been implicated in the inhibition of and desaturation of polyunsaturated fatty acids; i.e., the metabolic pathway to prostaglandin formation. Prostaglandins are important mediators of skin metabolism. Topical introduction of trans fatty acids may disrupt normal prostaglandin formation." The article goes on to say that "Trans isomers of lipid
(oil) materials occur infrequently in nature. Non-natural trans isomers are usually formed when lipid materials are subjected to various chemical transformations such as partial hydrogenation, oxidation, transisomerization, or certain enzymatic reactions." (These transformations are used to create some fatty acids, fatty alcohols, "emulsifying waxes" and
"butters.")

jojoba oil -- If this is in a product that is labeled as "organic," why is this oil not certified organic? It is readily available as organic.

jojoba oil* -- This is an oil that, if organic, is crushed from the seeds of the jojoba plant. It is remarkably similar to human sebum and is used in many skin care products. It is readily available as organic.

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lauramide DEA -- A synthetic chemical surfactant that was identified in the FDA Report: "Diethanolamine and Cosmetic Products." The
National Toxicology
Program (NTP) completed a study in 1998 that found an association between the topical application of diethanolamine (DEA) and certain DEA-related ingredients and cancer in laboratory animals.

To view the FDA report: http://www.cfsan.fda.gov/~dms/cos-dea.html

**********

lavender hydrosol (lavandula officinalis)* -- SEE BULGARIAN ROSE WATER ABOVE

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methyl paraben (other forms are: propyl, ethyl, and butyl) -- The following information is excerpted from the EPA report
"Pharmaceuticals and Personal Care Products in the Environment: Agents of Subtle Change?" by Christian
G.
Daughton and Thomas A. Ternes:

"Parabens (alkyl-p-hydroxybenzoates) are one of the most widely and heavily used suites of antimicrobial preservatives in cosmetics (skin creams, tanning lotions, etc.), toiletries, pharmaceuticals, and even foodstuffs (up to 0.1% wt/wt). Although the acute toxicity of these compounds is very low, Routledge et al. (112) report that these compounds (methyl through butyl homologs) display weak estrogenic activity in several assays. Although the risk from dermal application in humans is unknown, the probable continual introduction of these benzoates into sewage treatment systems and directly to recreational waters from the skin leads to the question of risk to aquatic organisms. Butylparaben showed the most competitive binding to the rat estrogen receptor at concentrations one to two orders of magnitude higher than that of nonylphenol and showed estrogenic activity in a yeast estrogen screen at 10-6 M."

Following is an excerpt from an article in the September 2002 issue of Happi (Household and Personal Products Industry) -- a chemical industry trade journal "Cosmetic Product Preservation" by Jabbar
Mufti:

"Typical preservatives used in the cosmetic industry include methyl paraben, ethyl paraben and propyl paraben and their derivatives. They disable `` activity in the bacterial wall to prevent fungal contamination. This action continues when the product is on the skin and may be absorbed into the skin tissue, taken up by the blood stream and ultimately reside in the major organs. The preservative action is so stable, it continues to work while inside the body, limiting the normal enzyme activity of the body. How do we know this? Autopsies performed on cancerous tumours have shown residues of methyl-, ethyl- and propyl parabens."

Scientists have found new evidence to show you why you should think carefully about using products that contain methyl paraben. "Their experiments show that xenoestrogens in a mixture can have a very significant effect in the presence of estrogen. The additive impact of a collection of xenoestrogens, each of them at concentrations beneath their individual "no effect" level, was to more than double the effect of natural estrogen by itself."

Here's the link to read the report on "weak" estrogens:

http://www.ourstolenfuture.org/NewScience/synergy/2002-08rajapakseetal
.h
tm

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multi-fruit enzymes -- These are synthetic acids which are controversial because of their skin damaging potential and their photo-sensitivity effects. The FDA investigated these chemicals because of numerous consumer complaints of severe skin irritation.

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NaPCA -- The sodium salt of pyroglutamic acid (The sodium salt of 2-Pyrrolidone-5-Carboxylic Acid). A synthetic humectant that is often used in skin conditioners and moisturizers that can cause strong allergic reactions and can severely dry out skin by absorbing moisture from the skin..

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natural carrot flavor -- The only truly natural carrot flavor that I know of is carrots and carrot juice. Because the "natural" flavor is in a lip balm, an oil-based product, and because oil and water don't easily mix (and stay mixed) my suspicion is that this is a propylene glycol-based, rather than a water-based, carrot flavor that may actually be a "reaction" flavor. The term "reaction" is used to describe these flavors because of the reaction that they are designed to generate -- which is usually a "burst" of flavor when the product hits the tongue.

Reaction flavor components are created when a protein (often a hydrolyzed protein) is broken down through a manufacturing process that includes heating at high temperatures along with a sugar to create the flavor enhancing effects of free glutamic acid. Dr. John Olney states that glutamic acid can be considered a neurotoxic endocrine disruptor (and has linked it to obesity problems). Regarding hydrolzyed proteins, mono and dichloro-propanols are included in the contaminants created when proteins are hydrolyzed with acids. Although enzyme hydrolysis does not produce the propanol contaminants, it is not as cost-effective as acid hydrolysis. Propanols are known to be carcinogens.

(You may wish to check out the section on "natural flavors" in Eric Schlosser's book "Fast Food Nation" to get some additional great, easy to assimilate, background on these chemicals.)

Most "natural" flavors are not simple things like vanilla extract, which, if organic, is a very simple extraction process of steeping vanilla beans in grain alcohol. The reality is that most "natural" flavors would meet the USDA definition of the word "synthetic" and are chemically-synthesized, isolated or standardized, highly-processed and manipulated extracts that usually are extracted with the petrochemial solvent propylene glycol.

Propylene glycol is also a humectant (a substance that draws moisture into itself or whatever it is blended into), used in deodorant sticks, lotions, creams, etc. It is in the same family of chemicals as automobile anti-freeze.

Congress passed an act that resulted in flavorings being considered proprietary and, thus, their manufacturing is considered confidential trade secret information.

The following question and answer is an excerpt from the USDA Food
Safety and Inspection Service's Office of Policy, Program Development
and Evaluation Labeling and Consumer Protection Staff (March 17,
1995):

http://www.fsis.usda.gov/OPPDE/larc/PMC_QA.htm

Question: Can fruit (or vegetable) juices, purees, powders, and similar ingredients be designated as "flavors?"

Answer: No, with very few exceptions, these ingredients are foods that have nutritional value and may not be designated as "flavor" and must be listed by their common or usual name, e.g., tomato powder and lemon juice. However, powdered onion, powdered garlic and powdered celery, as specifically cited in the regulations (9 CFR 317.2 (f) (1) (i) and 381.118 (c) (2)), may be labeled as "flavor," "natural flavors," or similar terms. Onion juice and garlic juice, according to FDA, may also be termed "flavor," etc.

*********

natural fragrance -- Scientists developed a technology called "head space technology," where they are able to create synthetic petrochemical versions of botanical essences. These "nature identicals" are identified on labels as "natural fragrance" or "fragrance." Many of these synthetic chemical compounds have been shown to have detrimental neurological, endocrine and pulmonary effects and some are persistent environmental pollutants.

In May 2002, a coalition of environmental and public health organizations contracted with a major national laboratory to test 72 name-brand, off-the-shelf beauty products for the presence of phthalates, a large family of industrial chemicals linked to permanent birth defects in the male reproductive system. The laboratory found phthalates in nearly three-quarters of the products tested (52 of 72 products), including nine of 14 deodorants, all 17 fragrances tested, six of seven hair gels, four of seven mousses, 14 of 18 hair sprays, and two of nine hand and body lotions, in concentrations ranging from trace amounts to nearly three percent of the product formulation.

Here's a link to the report:

http://www.nottoopretty.org/report.htm

A great report "Fragrance: emerging health and environmental concerns" from the Flavour and Fragrance Journal, 16 Apr 2002, that outlines the serious health problems (migraines, asthma, endocrine problems) caused by chemical fragrance:

http://www.fpinva.org/FragranceReview.htm

Why are synthetic fragrance compounds being used in products that are labeled as organic?

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niacin -- a synthetic B vitamin

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octyl methoxycinnamate (sunscreen) -- A synthetic chemical sunscreen that has been identified by the EPA as an endocrine disruptor. It is persistent in the environment and has now been found in fish and in human breast milk.

The EPA identified the following sun screen agents in US waterways: methybenzylidene camphor, avobenzene, octyl methoxycinnamate.

The EPA made the following statement about these chemicals:

"Significantly, many of these compounds have no published aquatic toxicity data; some might have the potential for significant effects (e.g., antiepileptics, antineoplastics). Conversely, some PPCPs (such as the SSRI antidepressants, calcium-channel blockers, and efflux pump inhibitors) that do have published aquatic effects data (albeit limited) have yet to be surveyed in environmental samples. Still others have great potential for profound aquatic effects but have neither the aquatic toxicological database nor any occurrence data (e.g., psychoactive agents and street drugs)."

Why is a toxic chemical like this found in products that are labeled as "organic?"

Here are links documenting this problematic endocrine disruptor:

http://www.epa.gov/esd/chemistry/pharma/book-summary.htm
http://www.health.gov.au/tga/docs/pdf/oestrogenicity.pdf
http://www.ourstolenfuture.org/Commentary/News/2003/2003-0305-NJN-comp
le
xmix tures.htm

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olefin sulfonate -- see C12-14 olefin sulfonate above

**********

panthenol (pro-vitamin B5) -- see dl-panthenol above

**********

paprika (natural color) -- virtually all of the paprika coloring that is available as off-the-shelf product has been extracted with chemical solvents and is preserved with a chemical carrier such as propylene glycol.

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PEG-10 sunflower glycerides -- synthetically-reacted sunflower oil -- a synthetic oleochemical. PEG stands for PolyEthylene Glycol. It is used as a lubricant. If this is used in a product that is labeled as
"organic," why
is simple cold-pressed, certified organic sunflower oil not being used?

**********

persea gratissima (avocado oil)* -- an edible oil extracted from the fruit of the avocado -- not widely available in the USA.

**********

potassium sorbate -- a synthetic chemical preservative. It is not permitted in organic food.

**********

powdered corn meal (zea mays) -- Why is this not a certified organic corn meal? Organic corn meal is quite readibly available.

**********

pure essential oils -- There is no legal definition of the word "pure." Why are any non-organic essential oils used in a product that is labeled as "organic?"

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PVP -- Poly VINYL pyrrolidone -- This is an ingredient typically found in hair styling and some hair conditioning products. It is found in products that are labeled as "natural." Does "vinyl" sound like a natural or botanical ingredient to you? Would you like to eat some PVP for lunch? Before you ask someone to pass the hot sauce, it might interest you to know that the International Journal of Pharmaceutical Compounding reported that the FDA proposed that a number of drug products be included on the list of drug products withdrawn or removed from the market because they have been found to be unsafe or ineffective. PVP had been marketed as Povidone or "Polyvinylpyrrolidone in Normal Saline" to doctors as a plasma expander and that it was "found unsafe for use as plasma expander in emergency treatment of shock because povidone (Polyvinylpyrrolidone) accumulates in the body and may cause storage disease with formation of granulomas; also interferes with blood coagulation, hemostasis and blood typing and cross matching." It was recommended to be withdrawn from the market on April 19, 1978. Should this ingredient be in "organic" body care products?

http://www.fda.gov/cder/fdama/fedreg/pcwdrawn.txt

An MSDS for PVP reads as follows: "Strong circumstantial evidence implicates PVP as the causative agent for lung thesaurosis in susceptible individuals with chronic exposure to hairsprays containing
PVP. Although
this effect cannot be reproduced in laboratory animal tests and epidomiologic studies have failed to show excess prevalence to exposed individuals, inhalation exposure to PVP should be kept to a minimum."

Lung thesaurosis is a medical condition in which tiny particles of substance, in this case PVP, become imbedded in lung tissue. Scar tissue can form over the imbedded particles, thus reducing pulmonary (lung) function/breathing capacity. There is the possibility that PVP may aggravate inflamed lung tissues of those diagnosed with asthma or other breathing disorders.

Ruth Winter reported that "Ingestion (of PVP) may produce gas and fecal impaction or damage to lungs and kidneys. It may last in the system (the body) for months to a year."

**********

retinyl palmitate (vitamin a) -- synthetic vitamin. High concentrations of this chemical may be dangerous if taken internally.

*********

roman chamomile -- Natural botanical, but what kind of ingredient is this? Extract? Essential oil? Infusion? Dried flowers? It is widely available as organic -- why is not organic in a product identified as "organic?"

**********

rosa canina (rose hip tea) -- It is widely available as organic -- why is it not organic in a product identified as "organic?"

*********

rose oil -- Many rose "oils" that are in distribution are synthetically adulterated with petrochemicals because of their enormous cost. Also, most commercially-available rose oil is extracted with the toxic solvent hexane. There IS certified organic, steam-distilled rose essential oil available. Why is this not being used in a product that is identified as "organic?"

*********

rosemary antioxidant -- This ingredient is a powerful antioxidant. It is used in place of (or in combination with) vitamin E in many natural foods and personal care products. It is permitted by the USDA in products that are meet the organic standards. The majority of this product that is being sold is extracted with chemical solvents. Interestingly, one of the companies that makes rosemary extract told me that they could easily make their extract from certified organic rosemary, but would need to make a full batch which would be approximately 55 gallons. The question here is: if this ingredient can easily be made as all organic, why isn't it being done? While 55 gallons of the extract would be prohibitive for a small company, it certainly would not be a problem for a large company.

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sage antioxidant -- This is a newer extract that is composed of, primarily, a new abietane diterpenoid, methyl carnosol, isolated from the leaves of sage (Salvia officinalis L.), together with 11 abietane diterpenoids, 3 apianane terpenoids, 1 anthraquinone, and 8 flavonoids. The extracts that were first made were extracted with a toxic solvent, hexane. The sage extract's antioxidant potential has been compared favorably to rosemary extract and vitamin E.

Sage contains thujone, which in high doses is toxic. This is more of a problem with oil and alcohol extracts, but not as much with tea
(infusion).

Why is it not made from organic sage?

**********

saw palmetto* -- This is a traditional herbal extract and Seminole indian food. It has anti-estrogenic and anti-inflammatory properties.

According to:

http://www.inhousepharmacy-europe.com/hair-loss/hair-loss.html

"...Studies have shown that saw palmetto is an effective anti-androgen. It acts in a similar way that propecia does. Firstly it lowers levels of DHT in the body by blocking 5 alpha-reductase. Secondly Saw Palmetto blocks receptor sites on cell membranes required for cells to absorb DHT. Although no studies have been carried out on saw palmetto and its relation to hair growth, studies have been performed on the use of Saw palmetto in the treatment of benign prostatic disease which similar to Androgenetic alopecia
-- it also depends on the production of dihydrotestosterone. All of the studies that have been performed to date show that Saw palmetto is an effective antiandrogen and has shown conclusively to be effective in the treatment of benign prostratic disease. One may assume from this that since Saw palmetto is an effective antiandrogen and is used in the treatment of prostatic disease then it may also be effective in the treatment of Androgenetic alopecia."

**********

sea kelp extract (laminaria digitata)* -- Very few seaweeds are available as certified organic. Many seaweeds are healthful foods providing minerals and much iodine, and can remove radiation from the body. In cosmetic products they are useful for hydrating the skin and can be used to help stabilize lotions.

seaweed extract -- see above

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shikai extract -- This may be a particular manufacturer's name for a proprietary extract. The more common name for the herb is shikakai. The latin name is Acacia Concinna.

The plant parts used for the dry powdered herb or the extract are the bark, leaves or pods. It is a common shrub found in jungles throughout
India. The bark contains high levels of saponins, which are foaming agents that are found in several other plant species. Saponin-containing plants have a long history of use as mild cleaning agents. Saponins from the plant's pods have been traditionally used as a detergent and in Bengal for poisoning fish and are documented to be potent marine toxins.

In commercial extracts, when the plant is hydrolyzed it yields lupeol and spinasterol and acacic acid lactone, and the sugars glucose, arabinose and rhamnose. It also contains hexacosanol and spinasterone. The saponin of the bark has spermicidal activity against human semen.

The leaves have an acidic taste and are used in chutneys. The leaves contain oxalic, tartaric, citric, succinic and ascorbic acids, as well as two alkaloids, calyctomine and nicotine. An infusion of the leaves has been used in anti-dandruff preparations. Extracts of the ground pods have been used for various skin diseases.

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silica -- This ingredient does occur in nature. The "silica" found in personal care products is not "sand" (as it is often represented), but a synthtetic silica known in the industry as "precipitated silica or silicate."

Dimethicone and silicone are also often misleadingly respresented as "sand." There are many different forms of the synthetic silicas/silicates for various applications and new forms are continually being created.

Soluble silicates and their derivatives are some of the most widely used chemicals. They are used in detergents, as catalyst supports for the polymers industry, beer stabilisers, adsorbents in edible oils, cosmetic thickening agents, abrasives and thickeners in toothpastes and absorbent desiccants.

The most commonly used base materials used to create the synthetic silicas are: silica sand and aluminum tri-hydrate, as sources of silicon dioxide and alumina respectively. The reactive agents that may be used are: sodium carbonate, sodium and potassium hydroxide and sulphuric acid. Sulphur or sulfuric acid is a serious environmental pollutant.

Some examples of synthetic end products are known as: sodium and potassium silicates, non-crystalline (also called hydrated amorphous) silicon dioxides or silicas, and crystalline aluminosilicates or zeolites.

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sodium chloride/sea salt -- Salt may be used as a thickener for detergent products. It is also used in bath salts and body scrub products. Sea salt is natural. Sodium chloride may be a dendritic salt -- a synthetically created salt.

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sodium hydroxymethylglycinate -- a synthetic chemical used as part of a preservative system in cosmetic and household products that is derived from glycine, or aminoacetic acid.

Registration of the New Active Ingredient Sodium Hydroxymethylglycinate, Contained in the Pesticide Product IntegraÆ 44 (EPA Reg. No. 57978-4):

The New York State Department of Environmental Conservation
(Department) has reviewed the re-submission of the application, received September 9, 2002, from Lewis & Harrison, submitted on behalf of ISP Chemicals, Inc., to register the above-mentioned product in New York State. This product contains the new active ingredient sodium hydroxymethylglycinate. The application was originally received November 26, 1997 and deemed complete for purposes of review on March 31, 1998 with a registration decision due by August 28, 1998. At that time the product was denied (see enclosed denial letter dated August 28, 1998).

IntegraÆ 44 is labeled as a fungistat and bacteriostat for incorporation into various products during manufacture. The types of products that can be treated (and some examples) include: household, industrial and institutional products (soaps and detergents, air fresheners, glass and hard surface cleaners); coatings (paints, stains, lacquers, joint compounds); adhesives (for wall and floor coverings, insulation, wood, paper, plastic and leather products); printing supplies (inks, pastes and related products); polishes (for shoes, furniture, floors, automobiles and metals); and other products (liquid houseplant fertilizers, textile finishes, foam insulation, air conditioner coolants).

When toxicology data was submitted to the state of California for this new chemical, the studies were all very short-term studies and no studies at all were submitted for chronic toxicity, reproductive toxicity (endocrine disruption), oncogenicity or neurotoxicity:

Following is a link to the California's ENVIRONMENTAL PROTECTION
AGENCY DEPARTMENT OF PESTICIDE REGULATION -- MEDICAL TOXICOLOGY BRANCH
and their summary of Toxicology data for Sodium
Hydroxymethylglycinate:

http://www.cdpr.ca.gov/docs/toxsums/pdfs/5720.pdf

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sodium myreth sulfate -- a synthetic chemical detergent. The suffix "sulfate" is an indicator that sulfur or sulfuric acid is used in the manufacturer of the chemical. Sulfur compounds used in industrial processes are serious environmental hazards -- in waste water discharge and air pollution.

REMEMBER, the USDA's National Organic Program [ to see the complete version of "The National List of Allowed and Prohibited Substances" go this link:

http://www.ams.usda.gov/nop/NationalList/FinalRule.html ]

states the following:

"The following criteria will be utilized in the evaluation of substances or ingredients for the organic production and handling sections of the National
List:

(2) The substance's manufacture, use, and disposal do not have adverse effects on the environment and are done in a manner compatible with organic handling;

*** Diana's question: Do consumers expect that the process of creating organic products would be monitored for toxic emissions? ***

(3) The nutritional quality of the food is maintained when the substance is used, and the substance, itself, or its breakdown products do not have an adverse effect on human health as defined by applicable Federal regulations;

(4) The substance's primary use is not as a preservative or to recreate or improve flavors, colors, textures, or nutritive value lost during processing, except where the replacement of nutrients is required by law;

(5) The substance is listed as generally recognized as safe (GRAS) by Food and Drug Administration (FDA) when used in accordance with FDA's good manufacturing practices (GMP) and contains no residues of heavy metals or other contaminants in excess of tolerances set by FDA; and

(6) The substance is essential for the handling of organically produced agricultural products.

(c) Nonsynthetics used in organic processing will be evaluated using the criteria specified in the Act

(7 U.S.C. 6517 and 6518).

Here is a description of a detergent manufacturing process:

Fats are split by heating the oil to 500 degrees F and applying 1200 PSI (80 times the pressure of a pressure cooker). The split fatty acids are then converted to fatty alcohols via transesterification. This process involves combining and heating an oil, methanol (a toxic synthetic alcohol) and lye.

Fatty alcohols are reacted with methanol and sulfuric acid, then neutralized with caustic potash or triethanolamine or another agent.

All detergent manufacturing facilities are regulated by the EPA under their toxic release inventory program.

*** Do consumers expect that the process of creating organic products would be monitored for toxic emissions?

There is an additional problem with the manufacture and use of synthetic chemicals: what is deemed safe today (according to studies done by the manufacturers themselves and reviewed by governmental agencies that are friendly with corporate chemical industries, with limited resources and budget constraints) may be found to be problematic tomorrow, as is the case now with the emerging concerns about persistent personal care chemicals in our drinking water.

Who will recognize the small companies who incur substantially higher production costs to insure that their products are truly organic, non-chemically treated and as unprocessed as possible, when they are forced to compete with industrially processed, environmentally-polluting companies and products with larger promotional budgets? ***

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soy lecithin -- A natural emulsifier, not available in organic form due to lack of demand(!), but permitted in organic foods.

**********

soybean protein* -- "Proteins" listed as such in personal care products are not tofu or simple soybeans. They are usually synthetic hydrolyzed protein polymers used for their thickening, coating or stabilizing properties that are commonly derived fom soy, wheat or oats.

The hydrolyzation process creates free glutamate in high percentages in the finished protein product and this synthetic glutamate is controversial because of its potential for neurotoxicity. For more information, see the site: http://www.truthinlabeling.org

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sphingoid -- (ceramide 3 -- A synthetic N-acylated sphingoid chemical base
-- from above) -- The term 'sphingoid' or 'sphingoid base' refers to sphinganine, [D-erythro-2-amino-1,3-octadecanediol (I)], to its homologs and stereoisomers (II, III), and to the hydroxy and unsaturated derivatives of these compounds (IV-VI).

Here is a link on Synthesis of Sphingoglycolipids (with good graphics):

http://www.glycoforum.gr.jp/science/word/glycotechnology/GT-A06E.html

The following is info from a report on ceramide synthesis:

http://www.mdpi.net/ecsoc-5/c0013/c0013.htm

Various synthetic routes to ceramide, or its preparative precursor, sphingosine, have been reported. Many of them lead to protected long chain 2-tert.-butyloxycarbonylamino-1,3-diols. Reaction of urethane-protected b-aminoalcohols, however, with diethylaminosulfur trifluoride (DAST) leads to heterocyclic products instead of a fluorine for hydroxyl exchange and N-acyl- and N-urethane-protected sphingosine derivatives did not give the desired 1-fluoro-derivatives on reaction with DAST.

**********

All of the following are synthetic oleochemicals. Whole vegetable oils are split and or esterified to provide manufacturers with products that are easier to produce and that have a long shelf-life. The processes of fat splitting or esterification or transesterification are ALL industrial processes and change the natural molecular structure of the natural oil into new molecules that do not occur naturally and do not retain the healthful phytochemical properties of the original raw material.

steareth-2 -- The polyethelyne glycol ethers of stearyl alcohol. The number indicates the degree of liquidity from 4 (thin) to 100 (solid). An emulsifier.

stearic acid -- A petroleum or vegetable source oleochemical that is used as an emollient, emulsion stabilizer or conditioner. This fatty acid is used as the basic ingredient to create O/W (oil in water) emulsions in conjunction with triethanolamine (TEA).

stearyl alcohol -- A fatty alcohol, very similar to cetyl alcohol (see cetyl alcohol above). May be derived from coconut oil.

**********

stevia -- Stevia what? Extract? Powder? Stevia (Stevia rebaudiana) is a delicate herb, native to Paraguay, that contains a molecule, steviocide, that is 300 times sweeter than sugar and that is heat stable. It is used in teas, foods and in toothpastes. It is available as organic.

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Sunscreens -- These are ALL synthetic chemicals that would not be permitted in organic food. They do NOT belong in body care products that are labeled as "organic."

Margaret Schlumpf is the head of the group responsible for the research paper [Environ. Health Perspect., 109, 239 (2001)] that indicated that in vitro and in vivo tests suggested that two ingredients in particular -- 4-methylbenzylidene camphor (4-MBC) and octyl methoxycinnamate (OMC) -- have estrogenic activity.

Here's a link to Dr. Schlumpf's report and rebuttal on her study:

http://ehpnet1.niehs.nih.gov/docs/2001/109-8/correspondence.html#res
http://www.sdu.dk/health/IPH/environ/undervising/Gruppearbejde_art.pdf

Here's a link to the Harvard Medical School's web page for their Center for Health and Global Environment's article on Dr. Schlumpf's study:

http://www.med.harvard.edu/chge/qrfall/deGfull.html

The Cancer Prevention Coalition lists the following body care chemicals (and sunscreens) as endocrine disruptors:

http://www.preventcancer.com/CosmeticsToiletries/EndocDisInCosToil.htm
l

Alkylphenol Ethoxylates Benzophenone-3 (Bp-3) Butyl Benzyl Phthalate Butylated Hydroxyanisole (BHA) Butyl-methoxydibenzoylmethane (B-MDM) Dibutyl Phthalate Diethyl Phthalate Homosalate (HMS) Methyl-benzylidene Camphor (4-MBC) Nitro Musks Octyl-dimethyl-PABA (OD-PABA) Octyl-methoxycinnamate (OMC)
Parabens
Polycyclic Musks
Resorcinol

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tetrasodium EDTA -- A synthetic preservative and chelating compound related to ethylenediamine tetraacetic acid. It is made from toxic chemicals: sodium cyanide, formaldehyde and ethylenediamine.

**********

trace minerals -- these would be inert substances.

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triethanolamine (TEA) -- A synthetic chemical made from ethylene oxide and ammonia that is used as a dispersing agent and detergent in body care products. It is an irritant and a sensitizer and caused gross pathology in the intestinal tract of fatally poisoned guinea pigs.

If combined with nitrosamines can become carcinogenic.

TEA is sometimes listed on the labels of "natural" products in lower-case letters to give the impression that it is some kind of herbal tea!

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triticum vulgare (wheat germ oil) -- It is an edible oil and is not available as organic at this time.

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tromethamine -- A synthetic chemical made by the reduction of nitro compounds. It is used to manufacture surfactants and as an emulsifier in lotions and creams.

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vegetable emulsifying wax -- refer to cetyl alcohol above.

**********

vegetable glycerin/glycerine -- It is identified as a synthetic ingredient by the USDA and it may be derived from botanical or petroleum sources.

**********

All manufactured vitamins meet the USDA's definition of the word
"synthetic."

vitamin A vitamin C vitamin E/tocopherol (vitamin E)/tocopheryl acetate (vit. E)

**********

water

water, purified -- There is no standard for this description, so it can mean whatever the manufacturer chooses. It can be tap water that has been just filtered through carbon.

water, steam distilled -- There is a standard for distilled water.

water: "aqua (purified soft water)" -- This is a particular manufacturer's description. There is no standard for purified water. It can mean whatever the manufacturer wants it to mean.

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wheat amino acids -- This is a very vague description of something. My guess is that they actually are using a hydrolyzed wheat protein, that can contain up to 40% of manufactured glutamte. For concerns about glutamates see: http://www.truthinlabeling.org

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wheat germ oil -- See "triticum vulgare" above.

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wheat protein -- See wheat amino acids above. Most likely, this ingredient is being used in a product for the hair as a product thickener or a hair coating agent.

wheat protein* -- The USDA does not permit hydrolyzed proteins in fish emulsions for organic crop fertilizers because they deem them to be synthetic. I can't see how this could be an approved organic ingredient because of the prohibited process.

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wildcrafted shea butter -- Shea nuts are grown in western Africa and the butter is an edible butter, approved for use in chocolates in Europe. The trees do not take well to large, monoculture plantings and, as a result, most of the shea butter that is available is from wild-harvested trees. It is a very emollient butter, contains a high percentage of naturally-occurring vitamin E and is used in many lotions, creams and hair conditioners.

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xanthan gum -- It is considered a synthetic by the USDA. It is a fermented bacterial paste that was originally discovered growing on rotting cabbage. It is used in foods and cosmetics as a thickener and as an emulsion stabilizer.

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zinc gluconate -- This ingredient is synthetic and is a combination of zinc and gluconic acid (a synthetic, derived from corn -- conventionally-grown -- pesticides, GMO's) that is used in deodorants. Because soluble zinc salts are toxic and can penetrate the skin, they are not permitted in formulations at more than one percent of the finished product.

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The Cancer Prevention Coalition lists the following body care chemicals as causing cancer:

http://www.preventcancer.com/CosmeticsToiletries/CarcinogensInCosToil.
ht
ml

Benzyl Acetate* Butyl Benzylphthalate Butylated Hydroxyanisole (BHA) Butylated Hydroxytoluene* (BHT) "Coal Tar Dyes" (and Lakes) D & C Red 2, 3, 4, 8, 9, 10, 17, 19 & 33 Green 5 Orange 17 FD & C Blue 1, 2 & 4 Green 3 Red 4 & 40 Yellow 5 & 6 Crystalline Silica
Diaminophenol
Diethanolamine (DEA) Dioctyl Adipate Disperse Blue 1 Disperse Yellow 3
Fluoride* Formaldehyde** Glutaral Hydroquinone
Methylene Chloride
Nitrophenylenediamine p-Phenylenediamine* (following oxidation)
Phenyl-p-phenylenediamine
Polyvinyl Pyrrolidone*
Pyrocatechol Saccharin Talc
Titanium Dioxide

*Evidence is limited
**Also genotoxic (causing genetic damage)

The Cancer Prevention Coalition states the following:

http://www.preventcancer.com/CosmeticsToiletries/Hidden.html

2. "HIDDEN" CARCINOGENS IN COSMETICS AND TOILETRIES

CONTAMINANTS

1,4-Dioxane*
In: Ethoxylated Alcohols, including PEGs, Oleths, Polysorbates, Nonoxynol

Arsenic* and Lead*
In: Coal Tar Dyes, Polyvinyl Acetate, PEGs (polyethylene glycols)

Crystalline Silica: In: Amorphous Silicates

DDT, Dieldrin, Endrin & related Pesticides:
In: Lanolin, Quaterniums

Diethanolamine (DEA):
In: DEA-Cocamide/Lauramide condensates, Quaterniums,

Ethylene Oxide*
In: Ethoxylated Alcohols, including PEGs, Oleths, Polysorbates, Nonoxynol

Ethylhexyacrylate:
In: Acrylate & Methacrylate copolymers

Formaldehyde*
In: Polyoxymethylene Urea

NITROSAMINE* (NDELA) PRECURSORS
Bromonitrodioxane Bronopol
Diethanolamine (DEA)
DEA-Cocamide, Lauramide & Oleamide condensates DEA-MEA/Acetame
DEA-Sodium Lauryl Sulfate
Metheneamine Morpholine Padimate-O
Pyroglutamic Acid Triethanolamine (TEA) TEA-Sodium Lauryl Sulfate

FORMALDEHYDE* PRECURSORS
Bronopol
Diazolidinyl Urea
DMDM-Hydantoin
Imidazolidinyl Urea
Metheneamine Quaternium-15 Sodium/Hydroxymethylglycinate
____________________________________________________________
*Also genotoxic (causing genetic damage)

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