Controversy Around Nano Not All Cleared Up By Friends Of The Earth Guide

A newly issued "consumer guide" from Friends of the Earth (FOE) may serve only to complicate the issue of nanotechnology in personal-care products for consumers faced with an absence of consensus among industry, public interest groups and other stakeholders.

Friends of the Earth released results Aug. 14 from a survey of 120 sunscreen manufacturers on their use of and policies regarding nanotechnology, which the organization maintains is under-regulated and potentially hazardous to consumer health.

"Sun worshippers beware," FOE says. "While slathering up with sunscreens to block dangerous [UV] rays, you may be exposing yourself to a new danger. Sunscreen manufacturers are adding nanoparticles to sunscreens ... without labeling and reliable safety information."

The group's "Consumer Guide for Avoiding Nano-Sunscreens" identifies nine sunscreen brands as nano-free, according to their manufacturers - Alba Botanica , Aubrey Organics , Avalon , Black Opal , Blistex , Bull Frog , M.D. Forte (Allergan), Schwarzkopf & Henkel and Tattoo Goo .

Twenty-four brands/products are cited as containing nanoparticles, including Applied Therapeutics , Blue Lizard and offerings from Banana Boat , Coppertone , Burt's Bees , SkinCeuticals and Innovative Skincare , among others.

Meanwhile, 95 brands "have policies and ingredients that were unclear or chose to not respond to our survey," the report notes.

"This underscores the need for labeling requirements and regulation, and for consumers to pay attention to which sunscreens they wear," FOE asserts.

In May 2006, FOE - along with The International Center for Technology Assessment, Greenpeace and the Center for Environmental Health - filed a petition with FDA urging the agency to exclude products containing engineered nanoparticles from the OTC final sunscreen monograph and to require instead that such products be regulated as "new drugs" (¹ (Also see "Nanomaterial Sunscreens Should Be Designated “New Drugs” – Petition" - HBW Insight, 22 May, 2006.), p. 3).

The group's position essentially is that the same properties unique to nanoparticles that allow for novel commercial applications - "tiny size, vastly increased surface area to volume ratio, high reactivity" - also create the potential for "unique and unpredictable human health and environmental risks."

FOE notes that "the jury is still out on how readily and how deeply nanoparticles penetrate skin. The ability of nanoparticles to be taken up through the skin and to access the bloodstream remains poorly understood."

If indeed their uptake is a threat, nanoparticles have the potential to enter vital organs "where they may disrupt normal cell activity," the organization says, adding that acne, eczema or shaving wounds could facilitate the entry of such particles.

In its Nanotechnology White Paper released in October 2006, the Cosmetic, Toiletry and Fragrance Association (CTFA) maintains that "there do not appear to be any dermal studies reporting differences in toxicity as a result of particle size."

According to FOE, titanium dioxide - used in nanoparticle form in many sunscreens and other personal-care products - has been classified by the International Agency for Research on Cancer as a possible carcinogen.

A June 2006 study conducted in conjunction with the Environmental Protection Agency linked nanosize titanium dioxide to oxidative stress damage in the brain (² , p. 10).

CTFA holds that available dermal studies "clearly indicate that nanoscale titanium dioxide remains on the skin surface or within the outer layers of the stratum corneum and does not penetrate into or through the viable skin."

In response to the petition filed by FOE and other public interest groups last year - which called for a recall of all sunscreens formulated with titanium dioxide and zinc oxide nanoparticles - CTFA contended in its comments to FDA that pulling such products from the market could actually harm consumers (³ , p. 3).

"These products provide a broad-spectrum protection not found in other sunscreens," the agency said. "It would be unnecessary and unwise for FDA to limit access to these safe, health-promoting products."

But in its consumer guide, FOE asserts that nanoparticles being used in sunscreens "are not necessarily more effective at blocking radiation from the sun," citing a Consumer Reports study released in June that found "no correlation between effectiveness and the presence of those ingredients."

The use of nanoparticles may in fact have more to do with marketing, FOE says. "The size-dependent optical properties of nanoparticles make the sunscreens transparent, or 'cosmetically clear,' and therefore presumably more desirable for consumers."

The Environmental Working Group (EWG) has a different take on the issue. In discussing its analysis and ranking of 823 name-brand sunscreens in June, EWG noted that "micronized and nano-scale zinc oxide and titanium dioxide in sunscreen provide strong UVA protection and are contained in many of our top-rated products."

For instance, Keys Soap - flagged by FOE as a nano-containing brand - markets the No. 1 and No. 2 safest items evaluated by EWG.

The group also pointed out that "repeated studies have found that these ingredients do not penetrate healthy skin, indicating that consumers' exposures would be minimal." Nevertheless, EWG recognized that studies on other nano-materials have raised concerns about their uniquely toxic potential.

EWG advocates for mandatory sunscreen safety standards, including UVA standards, development of which has been pushed back repeatedly by FDA.

Friends of the Earth is pursuing "an immediate moratorium on the commercial release of all nanotechnological materials and products" until they are regulated as new substances and clearly labeled "to allow consumers to make an informed choice about product use."

An FDA task force recently determined that special labeling for nano-products is not necessarily appropriate, as nanosize particles do not necessarily pose unique risks compared with their macro counterparts (⁴ , p. 4).

- Ryan Nelson ([email protected])