Some years ago, when one of us (Dr. Henry Miller) was an assistant to Dr. Frank Young, the head of the U.S. Food and Drug Administration, a woman approached Dr. Miller after she had heard Dr. Young give a lecture about the importance of regulation. She was quite appreciative of the FDA's efforts because, "My entire family and I are allergic to all known chemicals."
While that statement may sound like a bizarre and isolated incident, it was not then, nor is it today -- nearly four decades later. Confusion and ignorance about science, especially chemistry, have long been with us. The anti-vaccine movement was fueled by spurious concerns about a patently false relationship between a mercury preservative in vaccines and autism, and chemical additives are increasingly being cited as the reason for parental resistance to vaccination, which has led to the reemergence of serious preventable infections, such as measles. Measles infections increased by more than six-fold between 2010 and 2014.
Another example is the continuing sporadic controversy over the fluoridation of public drinking water, a hugely successful intervention for dental health. And while DDT was being vilified as highly toxic (it is not), millions of Africans died from malaria because the chemical was banned.
It seems that these lessons have gone unheeded. An example is the recently-introduced, updated Personal Care Safety Act introduced by Senator Diane Feinstein (D-CA). In some ways what is contained in the bill isn't terribly different from vaccine and fluoride scares. Nonetheless, in spite of the absence of any scientific evidence to justify the vast scope and huge expense of her pending legislation, Sen. Feinstein persists, beginning with an anecdote about an unsafe hair product which left a young girl bald, and then attempting to link this unfortunate incident to the trace amounts of chemicals we are exposed to every day.
What would the Act do? It would establish a "review process for ingredients used in personal care products. . . The FDA would be authorized to look at all available information on particular chemicals to determine whether they are safe and, if so, what the appropriate levels in products should be." In addition, "the FDA would be required to review at least five chemicals or categories of chemicals per year, chosen based on input from consumers, medical professionals, scientists, and companies" and "would also look at cumulative and aggregate exposures to ingredients as part of their safety analyses whenever such data are available."
Those new responsibilities would be a herculean task, and one based on overly risk-averse assumptions. Extrapolation of the effects of one harmful chemical to supposed risks from thousands of safe ones is the hallmark of the anti-chemical movement, which does significant harm. At its most benign, chemophobia has manipulated consumers to spend more for products in which one harmless chemical has been replaced by another. But the real victim is the erosion of the public's already-shaky understanding of even the most rudimentary concepts of toxicity and pharmacology.
Perhaps no chemical illustrates the consequences of public misinformation than formaldehyde, which is used in miniscule quantities to prevent bacterial growth in many vaccines. Sen. Feinstein wrote in a commentary, "Formaldehyde has been suspected to cause cancer since 1981, and has been listed as a known human carcinogen by the National Toxicology Program since 2011. Nonetheless, formaldehyde is still found in hair-straightening salon products." This statement is highly misleading for a number of reasons.
Chemicals are neither inherently good nor bad. They can be either or both depending on their inherent toxicity, level of exposure and method of use. Botulinum toxin can be a deadly contaminant of food, a drug or a commonly used cosmetic called Botox.
The science of toxicology tells us what quantity (dose) of a substance will be beneficial or harmful. This principle applies to the medicines used by Americans hundreds of millions of times a day to help relieve symptoms or to treat illnesses; for example, the right dose of aspirin or an over-the-counter cold remedy can be a therapeutic godsend, but consuming too much can be lethal. The same principle also applies to foods: Large amounts specific chemicals in nutmeg and licorice are notoriously toxic, yet we are perfectly safe consuming them because the normal amount of these chemicals in food is very low.
The same holds true when comparing the toxicity of industrial exposure to formaldehyde to the small amounts found in hair products. The two are not even remotely comparable. Undue concern over small amounts of formaldehyde implies that it is a foreign substance that our bodies are not prepared to handle. Not only are we routinely exposed to minute quantities of the chemical every time we eat fruit or drink fruit juice, but formaldehyde is an essential component for humans' metabolism. It is biosynthesized in our bodies as a building block for amino acids and DNA. We are not only constantly exposed to formaldehyde, but we actually need it.
Some of the other chemicals that Sen. Feinstein cites -- for example parabens and phthalates -- have been in common use for decades. "Concerns" about these chemicals are typically based on long-term, high-dose animal feeding experiments, which have not been shown to be relevant to human exposure.
Another misconception cited in the bill is that "parabens were found in the breast tissue of patients with breast cancer," which tells us nothing about the levels present and in no way implicates the chemicals in the cancers. Given the power of modern analytical techniques, vanishingly small quantities of thousands of chemicals can be detected almost anywhere. They have been around all along; only now are we able to "see" them.
Our water and air are cleaner, and our consumer products are of higher quality than ever before. Regulation has its place, to be sure, but it is intended to protect us from unreasonable risks, not speculative ones hyped-up by activists and pandering politicians.
Henry I. Miller, a physician and molecular biologist, is the Robert Wesson Fellow in Scientific Philosophy and Public Policy at Stanford University's Hoover Institution. He was the founding director of the U.S. FDA's Office of Biotechnology. Josh Bloom, who holds a Ph.D. in Chemistry, is the Senior Director of Chemical and Pharmaceutical Sciences at the American Council on Science and Health.