Chapter 173-339 WAC Cosmetic Products Restrictions rulemaking preliminary language
Comment From:
Anne Newcomb
8/13/24 @ 9:12 PM
Thank you for this opportunity to comment on Chapter 173-339 WAC Cosmetic Products Restrictions rule-making. Toxic chemicals in products like cosmetics has caused much unnecessary suffering for many throughout the years. I have friends who worked as ...↓hair stylists in a salon that also was a nail salon and had repeated exposure to formaldehyde from nail polish and possibly other nail polish chemicals. Now they suffer from migraines which is very debilitating. Please make your rules very strong to ensure the protection of both humans and aquatic life from toxic chemicals.
Hopefully we can work on removing fragrance from products like laundry detergent soon. It is designed to stick to fabric, is difficult to get out and causes breathing issues and migraines for many people.
See letter from Toxic-Free Future, Afghhan Health Initiative, Clearya, Cometologist, EarthMinistry, Washington Interfaith Power & Light, Hairstylist, Latino Community Fund of Washington, Pursue PFAS Free, Somali Health Board, Washington Conservation ...↓Action, WE ACT for Environmental Justice, and Zero Waste Washington.
I am writing to ask that the rule making process focus on protecting consumers from toxic products that negatively impact health. I myself and many of friends and loved ones are extremely sensitive to many chemicals currently used in many of the cosm...↓etic and self-care products. Please look to examples like Vetiver Hair Spa in Issaquah that have been successful in implementing a toxic-free (or super low-toxic) hair coloring, styling, and cutting business. With strong, consumer-focused rules, Washington State can lead the country in eliminating toxic chemicals from consumer cosmetic and self-care products. Thank you for the opportunity to comment and we will stay engaged with the process.
John Sherwin
Issaquah, WA↓
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Comment From:
D'Arcy Harrison
8/11/24 @ 5:01 PM
We write on behalf of Cosmetologists of Washington United, a 501c6 trade association advocating on behalf of WA state professional licensees and small business cosmetologists, barbers, hair design, esthetician, nails, massage, permanent makeup/tattoo...↓, and instructors/Schools in those areas.
We have had direct meetings to give feedback on this law following the webinar with Dept of Ecology as well as engagement on the original legislation in the state legislature with the bill's sponsor. As service providers who work with products that sit on or in the skin, nails & hair– it is even more important that they be as safe and non-toxic as possible to protect not only clients but also professionals who use it multiple times a day for numerous years.
When we engaged on the bill, we recommended that the legislature should err on the side of aligning with the European Union as those standards are already higher than current US standards. There is potential to return to the legislature to more clearly align with that recommendation regarding the 1ppm limit on lead. In the European Union it is 2ppm and we do not want WA state to become its own category of cosmetic type products for manufacturers. There already exists a standard that is manufactured that is safer. There are natural impurities in clay and bright pigments that cannot be removed nor synonymously replaced. We already suffer inflation and global supply chain issues in the wake of the pandemic- we hope WA state knows that safety should be balanced with available ingredients. Additionally, COWU knows it is an undue burden on small business to require a letter of certification from the manufacturer for 100s of products and from every company on the lead limits. Additionally, Small businesses cannot afford financially nor timewise to independently test 100's of products used in their shop.
We understand that we are in the rulemaking period for just the Formaldehyde releasing agents and the definition of "Intentionally Added Chemical". Our concern is specifically for any chemical that contains any natural impurities that cannot be replaced. If the impurities are present in an ingredient that is needed for the function of the product- even these trace elements could trigger enforcement of the law. Let's not be the enemy of good by expecting safer products to be 100% perfect and pure.
Finally, we have concerns with enforcement of these Rules, specifically with the inclusion of cosmetologists and cosmetology businesses as entities that must comply with these regulations and therefore subject to enforcement. We recognize that there is language in RCW that states no one can "knowingly sell" products that contain these chemicals. However, it would be near impossible for the small businesses and self employed individuals in our industry to verify that the products we use are in compliance. We rely on the manufacturers and distributors for information on the products we use, and assume that they are following the appropriate regulations.Many of us use over 100 different products in our salons and we simply do not have the time or skill set required to review each and every product ingredient list. We urge you to take this into consideration when implementing this new law.
We are neutral on extending the deadline for compliance schedules.
Please get this law passed ASAP. I'm am � for holding manufacturers accountable for toxic ingredients, they Should provide lists. Please align with the European Union on this. They have banned these toxic chemicals for years. I do not agree that more...↓ time is need for formaldehyde releasing products. Manufacturers have long known what they are putting in their products, they have been sent numerous letters from OSHA and the FDA and made no changes. It is time to hold them accountable and that time is now. There are products that Do Not contain these chemicals and work wonderfully. It just takes a little research. Please step up and ban these chemicals from products, they are literally killing us.↓
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Comment From:
Avantika Bandopadhya
7/24/24 @ 8:46 AM
I would like to comment on the proposed definition of intentionally added ingredient, "Intentionally added chemical means a chemical that serves an intended function in the final product, or in the manufacturing of the product or ingredients"
Most s...↓tate laws and FDA consider ingredient as intentionally added if it serves an intended function in product only and not in raw material or ingredient. I would request you to update your definition of intentionally added ingredient to match with FDA's definition of incidental ingredients.
Thank you↓
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Comment From:
William Lider
7/23/24 @ 7:46 AM
I fully support Ecology's efforts to remove toxics from cosmetics.
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Comment From:
Kristine Nevitt
6/06/24 @ 4:52 PM
When I ask for forbearance, it is to the scorers of this survey/comments, because I know you would prefer that I have read the proposed rule. I have not. I can only reinforce the need to act. I am appalled at the number of shampoos that have no welco...↓me footprint in my home; set aside to use on a carpet or whatever, because they are so fragrant and seem dangerous to my skin and the water treatment center. I buy what's on sale. They are selling toxic waste as a new variety of shampoo in the worst of the worst packaging that not even AI can give us an upcycling clue. "On sale."
In my opinion there should be an unannounced raid on the warehouses known to be associated with the manufacturing of shampoo. Do not allow them to continue to use what they have stockpiled.
Be a hero and stop the exporting of bad behavior because it always comes back as products that we must be vigilant as in "Buyer beware!" This is the one concept I believe should go away. I am asking parents about the moment we teach greed.
Twenty years ago, I confided in my then mentor, that we should bankrupt industry criminals in the US before an impacted country use our system of redress to fund injuries overseas. Either way Industry must pay.
Wall Street will not like insurance, banking, pharmaceuticals, oil and gas, going bankrupt as we try to get from them as a whole nation class action suit.
This new stream of resources that hits our nation as taxes do could be called the fourth sector. Perhaps those funds are dedicated to encouraging awesome behavior in humans. Much like the Third Sector, non-profits.
Thank you so much for your important work that somehow was glossed over by industry before unleashing so many screw-ups that my grandchildren are teething on!
Kristie
Citizen advocate, feeling that governance of our community requires forbearance. As we achieve transparency and all that.
Certified Public Accountant,
Ecological Economist
↓
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Comment From:
Mary Coon
6/04/24 @ 3:24 PM
Please pass this to make cosmetics safe for women. Besides formaldehyde, I am concerned about PFAS in long-wearing make-up. https://www.sciencenews.org/article/cosmetics-makeup-pfas-chemicals
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Comment From:
Tia Livingood
5/22/24 @ 1:12 PM
is it possible to ban shipment into WA state for online retailers and induce penalties? Can you work with companies like Amazon to require them to disclose where the cosmetics are coming from and require ingredient lists on sites?
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