Slip, slop, slap: exposing the great sunscreen cover-up
Chain Reaction #115, August 2012, www.foe.org.au/chain-reaction/editions/115
In July this year, Friends of Earth and a range of other organisations launched ACCC complaints accusing two Australian manufacturing companies – Antaria Limited and Ross Cosmetics − of misleading and deceptive conduct. The complaint accuses the companies of deliberately marketing sunscreen ingredients as 'non-nano' or ‘nanoparticle-free’, when in fact they are nanomaterials.
Some of Australia’s biggest sunscreen brands have been duped, affecting sunscreen products such as Cancer Council Classic, Invisible Zinc Junior and Body sunscreens, Coles Sports and Woolworths Clear Zinc.
The scandal creates a crisis in confidence in sunscreen safety, with the responsibility falling firmly in the lap of the Therapeutic Goods Administration − if the TGA had properly regulated and labelled nano ingredients in sunscreen, we would never be in this mess.
The 'Slip, Slop, Slap' campaign reached almost every Australian through widespread advertising in the 1980s. And with the highest rates of skin cancer in the world, most Australians know it's wise to limit our exposure to the sun's harmful UV rays, particularly in summer months. However, the 'Slop' part of the Cancer Council's famous message is compromised due to a growing public crisis in confidence in sunscreens, now made worse by new revelations. And tragically, even the Cancer Council − one of Australia's most trusted brands – is caught up in the scandal along with others.
So how did we end up in this mess?
Slippery product information
If you look on the back of a bottle of sunscreen, you'll see a list of active ingredients. It's there because active ingredients are highly reactive by their very nature and government regulators believe it's important that the public has access to this information. But where does the nano fit in?
Two increasingly popular nano-ingredients used in sunscreen are the metal oxides – zinc oxide (ZnO) and titanium dioxide (TiO2). Nano forms of these chemicals are used in sunscreen because they are transparent – whereas bulk forms of the same chemicals leave a white residue on the skin.
However, there are growing concerns around the health risks of using nano-scale versions of these metal oxides in sunscreens. Alarmingly little research has been conducted into the health risks associated with nano-ingredients in sunscreen. And from the little research that has been performed, we know that surface area plays a key role in the toxicity of nanomaterials, especially through the production of powerful free radicals. So, as we reduce the size of particles, the more potential there is for free radicals to damage proteins and DNA. Accordingly, leading Australian scientists have warned that in a worst-case scenario, nano-ingredients in sunscreens could increase the risk of skin cancer.
Some people are satisfied with the superficial benefits of clear sunscreen, and focus only on preventing the known risks of skin cancers. Many others, however, prefer not to take the risk while the scientific jury is still out and would rather choose nano-free sunscreens.
Given this widespread public concern over nano-content of sunscreens, ingredient manufacturers and brands have moved to fill the demand. Most notably, in 2007 an Australian company − Antaria Limited − moved to position its flagship product ZinClear IM as a 'non-nano' alternative to other zinc oxide sunscreen ingredients.
European regulators have passed laws requiring the safety testing and labelling on nano-ingredients in sunscreens from 2013. However, here in Australia the TGA has made it clear it has no intention of requiring safety testing or labelling of sunscreen nano-ingredients.
Since the nano-ingredients in our sunscreens aren't labelled, information about which brands are nano-free is difficult to determine. In order to help consumers make an informed choice, Friends of the Earth has created the Safe Sunscreen Guide every year for the past few years. Previous guides have surveyed over 100 sunscreen and cosmetic sunscreen brands and were based on signed statements from companies declaring if their products contained nano-ingredients or not.
Demand for our guide has been growing and growing, with over 50,000 guides downloaded last summer, and the Australian Education Union distributing hard copies to many Australian schools in early 2012. Increasing numbers of Australian sunscreen brands have moved to position themselves as nano-free and market this safe option to consumers – on sunscreen bottles, websites and in our guide.
Pioneering new research from the National Measurement Institute reveals that four Australian sunscreen brands that were listed as 'nano-free' in our Safe Sunscreen Guide actually contained nano-ingredients in their products. Ironically, the only company that turned out to be nano-free in this study – Banana Boat (Sports) – was one of the brands that had refused to respond to our survey and was therefore listed in the 'May Use Nano' section of the guide.
Closer investigation of product information and patents has since substantiated these results, and it now appears that two Australian manufacturing companies − Antaria Limited and Ross Cosmetics – may have been deceiving their customers, affecting sunscreen products such as Cancer Council Classic, Invisible Zinc Junior and Body sunscreens, Coles Sports and Woolworths Clear Zinc.
These manufacturers only provided basic measurement data of large micrometre-sized 'particles' to their sunscreen brand customers. Critically, they did not mention the fact that the 'particles' they were supplying were manufactured aggregates or agglomerates (clumps) of nanoparticles.
This matters, because definitions of nanomaterials – both here and overseas − describe aggregates and agglomerates of nanoparticles as a nanomaterial. That's because the very high surface area of these agglomerates and aggregates (due to all of the little nooks and crannies) are similar to those of the individual nanoparticles that they are comprised of. And it is this increased surface area that makes them more likely to produce dangerous free radicals when compared to bulk particles of the same chemical.
At least 13 sunscreen brands have provided signed survey responses to Friends of the Earth declaring their sunscreens free of nano-ingredients. Many of these brands have also added labelling to their bottles and websites declaring their avoidance of nano-ingredients. But it seems they were all misled. And ultimately, this means that we've been buying nano-sunscreens for years, while believing otherwise.
A slap in the face for the TGA
If this scandal raises greater public concern around the safety of sunscreens, it is a result of the Therapeutic Goods Administration's (TGA) failure to regulate the use of nano-ingredients in sunscreen. The government has failed to acknowledge the risks, failed to act with precaution, and failed to recognise the widespread public concern on this issue.
The TGA has repeatedly refused to acknowledge the risks (both known and unknown) presented by the nano-ingredients in sunscreens. The sum total of it's efforts in the past few years amounts to a literature review released in 2009, where it concluded "the current weight of evidence suggests that titanium dioxide and zinc oxide nanoparticles do not reach viable skin cells; rather, they remain on the surface of the skin and in the outer layer of the skin that is composed of non-viable cells".
However, the bulk of the skin penetration studies the TGA refers to have serious limitations and do not reflect 'real world conditions'. The vast majority of the studies are short-term, use excised skin and do not assess the role of penetration enhancers (used in some sunscreens).
The European Union's high-level Scientific Committee on Consumer Products ('Opinion on safety of nanomaterials in cosmetic products', 2007) and dermatologists here in Australia (Tran and Salmon, 2011, www.idlc.com.au) have also warned that further studies need to take into account abnormal skin conditions (such as eczema, acne or sunburn) and the possible impact of skin flexion on the penetration of nano-ingredients.
From July 2013, sunscreens sold in Europe will have to declare if the majority of zinc oxide or titanium dioxide particles are in nano-form. While this particular regulation is not perfect, it at least ensures that the nano-ingredients in sunscreen will be measured and have to undergo additional risk assessments. Closer to home, New Zealand will also be introducing a labelling regime for nano-ingredients in sunscreen in 2015.
These precautionary actions begin to address the genuine concerns raised by dozens of individual scientists and high level groups like the Royal Society (UK), which argued in 2004 that nano-ingredients in consumer products like sunscreens should have to undergo safety testing before use.
A recent poll of nearly 1300 Australians, commissioned by Friends of the Earth and carried out by The Australia Institute, found that 85% of those surveyed wanted nano-ingredients in sunscreens to be labelled. Furthermore, 92% of the people surveyed wanted nano-ingredients to undergo safety testing before use in sunscreens. These results show a clear community expectation that new technologies will undergo testing before use and that consumers will have a choice whether to buy them or not. However, the national regulator responsible for sunscreens, the TGA, continues to sit on its hands and reject these calls for labelling.
Paradoxically, the Australian chemicals regulator (NICNAS) has indicated that it intends to start implementing nano-specific regulation of active ingredients in cosmetic (secondary) sunscreens. This includes products such as moisturisers or lip balms with an SPF rating. Once in place, this would potentially create the situation where secondary sunscreens are regulated, while the TGA continues to do nothing to ensure the safety of primary sunscreens.
Please email the Parliamentary Secretary for Health and Ageing, Catherine King MP, and demand the proper regulation and labelling of nano-ingredients in sunscreen. You can email her via our website: nano.foe.org.au
Dr. Gregory Crocetti is a Nanotechnology Campaigner at Friends of the Earth Australia.