FDA Meeting – Testing Methods for Asbestos in Talc and Cosmetic Products Containing Talc

Thank you for the opportunity to provide oral comments.  My name is M. Isabelle Chaudry and I am here to speak on behalf of the National Women’s Health Network (NWHN). The NWHN is supported by a national network of individual members. We do not accept financial support from drug- or device-makers or personal care product manufacturers. As the Senior Policy Manager at the NWHN, I lead our organization’s work to ensure the safety of cosmetic and personal care products.  

Cosmetic and personal care products are a disproportionately large source of chemical exposure for women and girls in this country. Talc is found in many cosmetic products that women use in the most sensitive areas of their bodies including baby powder, lipstick, blush, eyeshadow, foundation, and face powders.  Independent labs throughout the country and over the course of several decades have documented the presence of asbestos in consumer talcum products such as Johnson & Johnson’s Baby Powder. With new science and research suggesting that cosmetic products can be a contributing factor to the health crisis many women and girls are experiencing, we believe that testing methods for asbestos in these products are of the utmost importance.

Exposure to talc has been suggested as a causative factor in the development of ovarian carcinomas, gynecological tumors, and mesothelioma. Over the years, several case-control and cohort studies examining the link between talcum powder use and incidence of ovarian cancer have been carried out. The most recent meta-analysis was published in December 2019 and included data from three cohort studies and 24 case-control studies. The 2019 meta-analysis summarized results from “a total of 16,005 cases and 201,881 controls.” Researchers found that regular perineal talc use increased the risk of developing both serous and endometrial ovarian cancers. Researchers also found that post-menopausal women who regularly used talc-based powders and who had taken or were currently taking hormone therapy were at the greatest risk of developing ovarian cancer. Finally, researchers found the greatest incidence of ovarian cancers in women who had regularly used talc for over 20 years, indicating that women who use talc for longer periods of time may be more at risk for developing cancer. 

The FDA has deferred to manufacturers for over 50 years when assessing the safety of talc powders and cosmetics. This practice is dangerous and has put consumers’ health at risk. There have been too many incidences of asbestos contaminated talc. In December 2017, independent testing uncovered possible asbestos contamination in make-up kits sold by Claire’s, a makeup and accessories store for girls. Further, independent testing in 2019 once again found asbestos contamination in certain products sold by Claire’s, Justice, and cosmetics maker Beauty Plus Global. In December of 2019, Johnson & Johnson recalled 33,000 bottles of its baby powder after an independent FDA investigation found chrysotile asbestos in samples from a retailer. Moreover, just this year, high levels of asbestos were found in a children’s makeup kit marketed by IQ toys and sold on the company’s website, Amazon, and eBay. 

Exposure to asbestos kills an estimated 15,000 Americans every year. There is no known safe level of asbestos exposure. Having adequate testing methods for asbestos in talc and cosmetic products containing talc is critical to the health and safety of consumers, who are often not aware that inadequate testing methods may have been used to test the products they use. 

Although the FDA considers asbestos-contaminated talc unacceptable for use in cosmetics, there are currently no U.S. laws prohibiting its use in cosmetics. We hope that Congress will take action and give the FDA authority to regulate cosmetics, including ingredients used in cosmetics in a meaningful way; and we are delighted that the FDA is using the powers it has to take measures to regulate these testing methods. The reconsideration of testing standards and safety parameters for the talc powders and cosmetics used by millions of people is a positive step in requiring adequate testing methods of products containing talc. 

M. Isabelle Chaudry, J.D., is the Senior Policy Manager for the NWHN and an advocate for marginalized communities of women. Isabelle actively lobbies and provides expert testimony before Congress and the FDA for women’s health and cosmetic policies. She is an LL.M candidate in International Human Rights and Humanitarian Law and a Board Member for Women’s Voices for the Earth.

Read more from M. Isabelle Chaudry.

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