Reflective Memo If I would have had an extra 24 hours to work on this project I probably would have tried to add

some more information and evidence to back up my main points. I feel that I have a lot of that in my letter but would have tried to include more to have more of a persuasive and evident hook for my reader to be able to really fully engage. I feel like in this paper I had a bit of a struggle in the beginning because in the paper that led up to this one I hadnt really used an argument in my discussion. Before I could start this paper I had to find an argumentative article and figure out how I wanted to respond to it where as other people who had already chosen a side in the previous paper could start right one it. It was a struggle to find an article to respond to but once I finally found one I felt like everything started falling into place. For this project I think that you should focus the most on all the points that I brought up and the evidence that I used to back them up. I also feel I did a good job engaging the reader and making them feel like they were a part of this too. Some of the weaker points of mine would probably have to include probably the conclusion, I dont feel like I was as affective in my conclusion that I could have been, but I do feel that I still was able to effectively end my letter. Overall, I really could feel and see a huge difference in how well I could put this letter together. I can definitely see a huge improvement in myself and my writing abilities compared to the beginning of the year and now, and I am so proud of myself.

Staley 2 Meghan Staley Mr. Borrero ENGL 1102 11 April 2013 Dear FDA, It is apparent now more than ever that the cosmetic industry is becoming more and more prevalent in conversation, and not necessarily in a positive way. More and more cases are surfacing about serious reactions caused by make-up products, and the question I have for you is where are you when this is going on? Why havent you done more to stop companies from putting harmful chemicals into their products? If manufacturers are allowed to mandate and test their own products then how do we as buyers know that the products are not harmful to us? It is now more and more common that we see serious reactions caused by make-up products, as well as cases where harmful ingredients have been included into what women including myself apply to our faces. I ask that you please take the time to read this letter, as it is very important to take action and help the cosmetic industry maintain a safe environment. It is time for you to take part in the regulation of what goes into our make-up, to ensure the safety of your buyers, as well as yourselves. The current standards and regulations in the make-up industry allow the manufacturers of each make-up product to test their own products. How do we know that companies are sending in reports on all parts of their trials? You as the FDA currently have no authority over premarket approval of cosmetics. The only thing you can do is pursue enforcement action against violated products. You are also not required to put out a recall on products that are causing harmful effects. This is a huge

Staley 3 concern for me and many women using these make-up products because we are unaware of what we are using on our faces, and you are just sitting back and watching without any concern or attempt to stop this from happening. (FDA 1) There have been many cases that have surfaced about serious reactions to products as well as harmful ingredients being placed in these products. For example, in over 400 shades of lipstick, lead was found as an active ingredient. What did you do about this? You claimed that it wasnt going to hurt us enough to take it off the market. How can you sit there and let lead be a common ingredient in something women wear on there lips, where its so easy to enter the mouth? Wouldnt you think that time after time of using that same product the amount of lead the person would intake would increase sufficiently enough to cause a serious problem? The Campaign for Safe Cosmetics argue that lead builds up in the body over time and lead-containing lipstick applied several times a day, everyday, can add up to significant exposure levels. (Sifferlin 1) They have been pushing for you to mandate a limit on the amount of lead a product can have in order to be put on the market, needless to say you havent budged. Lead can cause serious learning problems, as well as behavioral. It can also affect the development of a fetus in pregnant women. Are you willing to live with that? Knowing that you could be the cause of an unborn childs death or even the cause of learning/behavioral problems after they are born? (Sifferlin 1-2) Due to your lack of concern, the state of California is now taking matters into their own hands. This state has come up with a bill called the Assembly Bill, which would ban certain ingredients from being included into make-up products that are sold in that state. This bill was based on the European Unions ban on cosmetics containing

Staley 4 anything on Annex II of their own cosmetic directive. This bill was not passed but they later came up with The Safe Cosmetic Act that focused on the negligence of federal regulations and the statement that these products could cause cancer or reproductive health problems. They also said that an allotment of $100,000 per year would be able to enforce this act. The state was then to come up with a list of chemicals that they agreed to ban from being allowed in products sold in that state. A total of 783 chemicals were banned from being used including titanium dioxide, black 2, cocamide DEA, and retinol. With these guidelines they hope to stop the serious reactions caused by harmful products in make-up. They are also aiming to push for you to have required approval of all ingredients before being allowed on the market. Why arent you the ones passing these bills? Whats it going to take to get you to start doing something? (Steinberg 1) Although California is passing its bills, the industry is taking a toll on this as well. The Personal Care Products Council issued its Consumer Commitment Code that contains six parts. The first part states that companies should market products only after the safety of each ingredient and the finished product have been confirmed. This will help in preventing products that are harmful to us from being allowed on the market. The second part of this code is that if a company puts a product on the market with an ingredient that goes beyond the limits set by the Cosmetic Ingredient Review, it should be able to offer enough data to be able to confirm the safety of the ingredient being used, and give that information to you. This will help to provide some clarity to us as buyers as well as can cause companies to ensure safer products with the evidence to back it up. Third on the list makes a company that markets a product with an ingredient on the Cosmetic Ingredient Review be able to produce relevant and sufficient data to prove the

Staley 5 ingredients safety and show that information to you under inspection. This should help manufacturers keep from being allowed to hide tests that show harmful ingredients. The fourth is one of the most important parts suggesting that companies should participate in your Voluntary Cosmetic Reporting Program to register products manufacturing location as well as ingredient usage. If this actually works it will prevent manufacturers from leaving out the ingredients reports that are bad that they dont report to you. While it is currently only voluntary why cant you take some responsibility and make it mandatory? That way we will know for sure companies arent leaving any reports out. The fifth regulation is that a company should notify you of any serious or unexpected events such as reactions, and make that information also available to you. Lastly the sixth goal is for companies to have safety information about their products documented and within reach for you during inspections. With this commitment code in place, youd think you would catch a hint that if all this is needed maybe it needs more from you too. (Steinberg 2) Not only has California started unfolding a new plan of action, Colorado has now unleashed its Colorado Safe Personal Care Products Act. This model is said to be in place of destroying the cosmetics industry. This act is based off of Californias and prohibits manufacturers from selling, offering to sell, or distributing any product that contains any chemicals that have been proven to cause cancer or reproductive toxicity. This bill also talks of prohibition-the sale of personal care products containing unsafe chemicals. They also lay down that enforcement by private citizens such as a civil penalty could now be enforced. Any person who finds or experiences a violation of this may bring an action against the manufacturer in a court of jurisdiction in the county it occurred. In addition to any other relief authorized by law, the court can order the manufacturer to cease conduct

Staley 6 and order the manufacturer to pay the other parties attorney fees and costs. The penalty they will face can be up to $5,000 for the first offense and $10,000 for the second. If it is a big enough concern in this state to take it into the courts hands, how come you arent big enough to take it into your hands? (Steinberg 2-3) As states take matters in there hands, labeling of ingredients on make-up products is another major problem that is one of the leading causes of reactions to make-up. Many manufacturers decide to ignore regulations on labeling because of your lack of enforcement. It has become very easy for companies to produce labels on their products with lists of ingredients that are misleading and sometimes left out of the list. In an article titled How to Read a Cosmetic Label, a breakdown of what labels may actually mean is put into perspective. This article argues that products that may say they are for instance, alcohol free actually do contain many different types of alcohol. Companies try to get away with it because the term alcohol refers to ethyl alcohol, but there are actually many other alcohols used in these products. Cruelty-free is another term you may see on many product labels. This statement does imply to the buyer that it has not been tested on animals, but at some point almost all ingredients have been tested on animals. Another turn to hypoallergenic cosmetics says that manufacturers claim that these products produce fewer allergic reactions, but in fact there are no federal standards or definitions that govern the use of this term nor do they ensure that they are less likely to cause reactions. You may not realize it, but you are promoting this because you arent providing enough enforcement on these manufacturers. You are allowing them to run the show and put whatever they want in and on these products we are using. (How 1)

Staley 7 Your current authority over the make-up industry is lacking in several aspects. Cosmetic products and ingredients are not subject to your premarket approval, and this is a huge concern when it comes to what manufacturers are able to put out on the market. Since you are unable to approve these products you rely on other people who buy the products to experience the reaction and let you know the results. That is pathetic at all costs. You are setting us up to be the guinea pigs in this situation to risk our health to test a product that may not be suitable for the market, while you get to sit back and wait to hear from us? How can you sit there and live with being responsible for some of the serious reactions people face because you dont regulate their products? Each cosmetic firm is responsible for maintaining the safety of their products and ingredients before marketing, although they do have the right to market a product that they are unsure of the safety of the ingredients with the label WarningThe safety of this product has not been determined. How can products with that kind of a label even be able to be placed on a shelf for purchase? Also not only is that a growing issue, but recalls on products are left in the hands of the manufacturers as voluntary actions. What kind of manufacturer is going to recall its own products? If they were putting them on the market knowing that harmful ingredients are in them then why would they take them off? (FDA 1) Maintaining a safe, and logical environment through out the cosmetic industry is going to require vast changes on your part starting with your authority over cosmetics. We rely on you to keep us safe from harmful products, but when we dont have you to rely on whom then do we have to look to? It is your job, not ours, to be aware of whats going on inside the make-up industry. We shouldnt, nor should you have to question what we are putting on our faces each day. With the regulation of ingredients, required

Staley 8 approval of premarket cosmetics, and you staying on top and mandating these guidelines in the industry, the environment will become safer for us as buyers. There will be no need for states to pass bills regulating what can be sold in their state, and there will be less risk for reactions that are harmful to us. You have to take a stand, and make it happen. Think about it the next time you, your wife or teenage daughter are applying make-up products. What are we really putting on our faces? Then, ask yourself what you are doing to put a stop to it.

Sincerely, Meghan Staley

Staley 9 Works Cited FDA Authority Over Cosmetics. Cosmetics. 3 Mar. 2005: 1-2. Web. 11 Apr. 2013. How to Read a Cosmetics Label. WebMD. n.d. Web. 11 Apr. 2013. Sifferlin, Alexandra. Whats in Your Lipstick? FDA Finds Lead in 400 Shades. Health & Family. 15 Feb. 2012: 1-3. Web. 11 Apr. 2013. Steinberg, David. "From California to Colorado: Three Battles Against Cosmetics." Cosmetics & Toiletries Science Applied. 27 May 2010: 1-5. Web. 11 Apr. 2013.

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