Rating Sunscreen Below SPF 15 products
To rate a personal care or household chemical product, GoodGuide considers the following attributes:
- A health hazard rating based on the number of product ingredients categorized as low, medium or high health concern;
- Indicators that the product exhibits other negative aspects (e.g., does the product contain ingredients that have been banned or subjected to regulatory restrictions);
- Indicators that the product is among the best on the market in its category (e.g., has the product been certified as safe or healthy by a credible third-party);
- Indicators of data gaps that preclude evaluation of the product (e.g., no or inadequate disclosure of product ingredients).
Categorizing Ingredients by Levels of Health Concern
Defining Levels of Health
In order to identify ingredients of health concern, we utilize the science of health hazard assessment and rely on lists of chemicals labeled hazardous by various authoritative organizations. GoodGuide tracks whether chemicals are recognized or suspected of causing any of twelve major types of human health problems, ranging from cancer to endocrine toxicity to skin or eye toxicity. We combine this hazard data with chemical potency, human detection frequency and toxicity testing information, in order to assign ingredients to four levels of health concern: none, low, medium and high.
An ingredient raises no health concern if:
- It is not on any of GoodGuide's lists of toxic chemicals which cause suspected or recognized health effects;
- It has not been detected in human tissue or urine; It is not a high production volume chemical that lacks safety data.
An ingredient raises a low level of health concern if:
- It exhibits two or less suspected health effects; and/or
- It has a relatively low toxic potency for inhalation and ingestion exposures; and/or
- It is only occasionally detected in human tissue or urine; and/or
- It lacks at least half of the six basic toxicity tests required to assess chemical safety.
An ingredient raises a medium level of health concern if:
- It exhibits three or more suspected health effects; and/or
- It has a relatively moderate toxic potency for inhalation and ingestion exposures; and/or
- It is regularly detected in human tissue or urine.
An ingredient raises a high level of health concern if:
- It exhibits one or more recognized health effects; and/or
- It has a relatively high toxic potency for inhalation and ingestion exposures; and/or
- It is frequently detected in human tissue or urine.
The Difference Between Recognized and Suspected Health Effects
Chemicals are identified as recognized toxicants based on hazard identification efforts of authoritative national and international scientific and regulatory agencies.
To date, such efforts have been focused on only a few types of toxicity. GoodGuide utilizes California's Proposition 65 lists of chemicals in order to identify recognized carcinogens, reproductive toxicants, and developmental toxicants. Chemicals are listed on Proposition 65 following a scientific peer review process and regulatory rulemaking, which incorporates the hazard identification efforts of a variety of other authoritative bodies, including the International Agency for Research on Cancer and the National Toxicology Program. Hence, a substantial weight of toxicological or epidemiological evidence supports the decision to list a chemical as a recognized health hazard under Proposition 65. Stakeholders that believe a chemical does not cause a recognized health effect have the opportunity to argue that the evidence does not support identifying the chemical as a hazard. If a chemical is listed under Proposition 65, such arguments failed to convince neutral scientific and regulatory experts. We also rely on a peer-reviewed article in the medical journal Lancet to identify recognized neurotoxicants.
Chemicals are identified as suspected toxicants based on reports in the scientific or regulatory literature, or on information abstracted from major toxicological databases.
Lists of suspected toxicants are linked to twelve health effects. Suspected toxicants possess evidence that they can cause specific adverse health effects. However, no authoritative hazard identification process is currently conducted by regulatory agencies or scientific organizations for these health effects. It is important to consider a chemical on a “suspected” list as a preliminary indication that the chemical may cause this effect, rather than a definitive finding that it does. In order to identify suspected toxicants, information is abstracted from the principal toxicology text books (such as Casarett and Doull's Toxicology), medical journal articles, regulatory actions, and international chemical hazard resources (such as the European Union). The weight of toxicological or epidemiological evidence supporting suspect hazard identification can vary significantly between chemicals. For example, evidence from two different laboratory species indicates that acetonitrile can cause cardiovascular toxicity. In contrast, overwhelming evidence indicates that carbon monoxide causes cardiovascular toxicity in humans. These disparate data lead to designation as a “suspected” toxicant as an authoritative agency has yet to compile lists of cardiovascular toxicants. Identifications developed by regulatory agencies or scientific references often undergo peer review, but an administrative process that allows for debate over and conclusive resolution to the toxicity designation of a chemical has yet to be put in place.
GoodGuide separates ingredients into two categories — “ingredients of health concern” and “controversial ingredients.” Only the former contribute to a product’s rating.
A chemical must be identified as a potential health hazard by a GoodGuide-approved authoritative source (e.g., a regulatory agency like EPA or a scientific group like the National Toxicology Program) in order to be labeled an ingredient of concern.. This system ensures that our ratings are based on the best available scientific evidence. Goodguide labels chemicals as “controversial” ingredients if they have not been identified as hazardous by authoritative sources, but are the subject of current debate regarding potential adverse effects. “Controversial” chemical designations do not contribute to the product rating because the evidence of hazard is inconclusive, however they are flagged in the event a consumer wants to avoid such chemicals.
Core Rating Components
- Health Hazard Rating:
- Based on a count of ingredients of health concern.
- Other Negative Aspect Rating:
- Products that contain an ingredient that is banned from a category by regulatory agencies in the U.S., Canada, Japan or the European Union rate 0. Products that contain an ingredient that is being targeted for elimination by regulatory agencies also rate 0.
- Ratings for products that contain an ingredient that is subject to regulatory restrictions in a category are capped at 8 unless the product label or its manufacturer provides data documenting that the product is in compliance with the applicable restriction.
- Product Management Rating:
- Products that are certified as safe or healthy by a credible third-party (e.g., EPA Design for the Environment) rate 10. If the relevant certification involves a comprehensive evaluation and approval of a product's formulation, those ingredients' contribution to a product's Health Hazard Rating will also be suppressed.
Adjusting Ratings to Account for Data Gaps
GoodGuide adjusts a product's health rating if information is missing that is required to evaluate its potential impact.
Our health hazard evaluation requires a complete list of a product's ingredients (with sufficient detail about chemical identity to allow ingredients to be checked against hazard lists) and information about the percent composition of a product (to characterize potential exposures and evaluate compliance with regulatory restrictions). Unfortunately, manufacturers are generally not required to provide both of these types of information for most consumer products.
Adjustment for products that lack full ingredient data
For household chemical products, there is no current regulatory requirement that companies disclose full ingredient lists. For personal care products, ingredient disclosure is required, although it may include generic ingredient names that are not specific enough to support hazard evaluation. To create an incentive for full ingredient disclosure, GoodGuide caps a product's score if it lacks complete ingredient data or lists generic names that do not support chemical-specific evaluations. The caps applied are described in the following table:
|Rating Cap||Amount of Ingredient Information Available|
|0||No information available|
|4||Some ingredient information available, but list includes generic categories potentially containing high or medium health concern ingredients|
|6||List includes generic fragrance, without further information|
|8||Some ingredient information available, but list includes generic categories potentially containing low health concern ingredients|
|10||All ingredients disclosed, including the constituents of generics like fragrance; or all ingredients reviewed and approved as part of a third-party certification|
Adjustment for products that lack percent composition data
For household chemical products and most personal care products (with the exception of sunscreens), there is no current regulatory requirement that companies disclose percent composition data. This precludes evaluating whether a product is a potentially significant source of exposure to a chemical (e.g., presence of an ingredient at less than 0.1% of a formulation is unlikely to pose a risk, while presence of that ingredient at 10% of a formulation could be a significant source of human exposure). The absence of percent composition data also complicates the evaluation of whether a product is in compliance with applicable regulatory restrictions. Both regulatory agencies and trade associations manage the potential health risks of products by defining thresholds below which an ingredient is deemed safe as used (e.g., use of an ingredient is acceptable provided that it does not exceed 5% of a product's formulation). Unless a product label discloses the percent composition data required to evaluate compliance, GoodGuide caps a product's rating at 8 if it contains ingredients that have been restricted by regulatory agencies or trade associations.
Adjusting Ratings if Ingredients are Granted a “Safe Use Exception”
GoodGuide increases a product's health rating if information indicates that an ingredient does not pose a health or regulatory concern as it is used in a product. This adjustment has the effect of minimizing the contribution of that ingredient to the product's health rating. Such adjustments are indicated in the “Product Ingredient List” section of GoodGuide product pages with a “Safe Use Exception” icon and an explanation of the basis for suppressing an ingredient.
Ratings may be adjusted for the following reasons:
- An authoritative third-party (such as EPA's Safer Choice program) reviewed a product and approved its formulation.
- An authoritative third-party (such as a regulatory agency) reviewed the ingredient and determined that its use in a certain type of product (e.g., rinse-off hair products) does not result in significant exposure or health risk.
- Percent composition data indicate the level of the ingredient is below the most stringent regulatory or trade association threshold level that defines safe use; the applicable threshold is not the subject of substantial critique in regard to its health protectiveness; and the ingredient is not authoritatively linked to a health endpoint expected to pose low dose risk.