652 R. J. L. Allen more clearly, and without ambiguity and possibly misleading overtones, the true nature and scope of your discipline. If none of the 163,000 words in the Shorter Oxford Diction- ary are suitable perhaps the so-called dead languages could help out once again? In 1834 Faraday sought the help of Whewell, the Master of Trinity and a scientist and philologist of European reputation, in coining logically impecable names for the phen- omena of electrochemistry which he had elucidated (2), and electrolysis, cathode, anion etc. still serve us well a century and a half later. You may think I am making too much of this, but words are powerful things and in my experience apparently trivial problems of nomenclature often reflect more substantial uncertainties and unresolved tensions lying beneath the surface. Perhaps at the same time, incidentally, you could think about 'chemist' in your title. I do not think it adequately defines responsibilities that now extend far into the fields of biology and physics. What is the general outlook for the cosmetics industry, particularly in this country, in the next 25 years? In broad terms the prospects would appear to be reasonably good. The industry has not so far attracted the suspicious dislike that certain politicians show for the pharmaceutical industry. Cosmetics are not at present used as a major instrument of tax manipulation to anything like the same extent as are alcohol and tobacco. So far as I know, there are not even any proposals to nationalise the industry. But there is no lack of problems that will have to be identified, tackled and solved if the industry is to survive in the form we know. The only way I know of forecasting the future is by extrapolating the past. Tonight, I want to suggest perhaps paradoxically that what we should try to extrapolate is the past not of this industry but of the food and pharmaceutical industries. As a matter of fact, I made a rather similar suggestion in this very room on 5 January, 1967, when you were discussing currents trends in toiletries legislation but as no one took much notice of what I said at the time I have no scruples in making my point again a decade later! In a very short time by historical standards the cosmetics industry has been trans- formed by a rapid growth in the role that science plays in its affairs. It is bad luck, in a way, that this critical change in the internal environment of the industry has coincided in time with a quite remarkable growth in the amount of intervention Newspeak (3) for interference--in the affairs of the industry by governments. Ten years ago the United Kingdom cosmetics industry operated in a singularly relaxed regulatory climate. There were the general provisions of the law but only a minimum of specific legislation. That era has gone. Consumer protection is bi-partisan policy and the excellent--indeed outstanding--safety record of the industry has in no way inhibited the politicians from moving towards the imposition of detailed regulation. It is no longer a question of whether the industry is going to be closely regulated, but how. I believe, therefore, that there is something to be learned from the experience of the United Kingdom food and pharmaceutical industries, which have themselves in the last 25 years suffered a vast increase in regulation and control from outside. in fact, to someone like me who has worked in these industries it is really quite fascinating how history is repeating itself. It is hard to realise the formal control of the safety of pharmaceuticals was minimal before 1 January, 1964 when the Committee on Safety of Medicines was set up with Sir Derrick Dunlop, your 1971 Medallist, as chairman. This admirable and effective system, which depended entirely on the voluntary compliance and co-operation of the pharmaceutical industry, was swept away with the passing of Medicines Act 1968. The small, expert and highly regarded staff of the Committee have been replaced by a vast and growing bureaucracy. These developments have had an
Cosmetics and the future 653 immediate impact on an important class of cosmetic products as defined by the Cosmetic Products Directive that are also 'medicinal products' as defined by the Medicines Act. The trend is to judge and treat them more as medicinal products than as cosmetics in regard to safety, efficacy, quality and good manufacturing practice as well as labelling and advertising. I foresee, moreover, an increasing tendency to bring the generality of cosmetics within the same kind of regulatory framework, and here I think that it is extremely important for you all to be very much on the alert in the years ahead. We live at a time when safety evaluation is a major growth industry worldwide. Large organisations have been established in order to carry out tests prescribed by an army of functionaries and their advisers. A comment by Dr Yale Gressel at the 1976 Cosmetic, Toiletry & Fragrance Association Scientific Conference seemed to me very much to the point: once there was only one kind of toxicology--the science of that name--but now we have several. Consumer toxicology is the art and science of maxi- mising the impact of possibly adverse findings in the supposed interest of the general public and so ensuring an effective ban on any questioned compound or product on minimum or no evidence. The leaders in media toxicology are expert in generating headlines from a minimum of data. The successful grant toxicologist makes sure of a steady flow of funds to his laboratory from a grateful public by following a policy of positive results at all cost. Political toxicologists see 'safety' as a stepping stone to high office. Legal toxicologists thrive on the impossibility of proving a negative. It is not surprising that an increasing number of useful compounds have been banned or made politically unusable on grounds that owe more to emotion than science. I believe that it is the duty of the scientific community to stand up and be counted on this issue when a ban is threatened that is based on inadequate evidence, or on data obtained by in- appropriate test procedures unrelated to ordinary conditions of use. The US National Cancer Institute has several hundred compounds on test for what is called their 'carcino- genic potential'. The extremely high levels of exposure used in this programme are based on the maximum tolerated dose of the compound being investigated, and are calculated to cause so much tissue damage at the cellular and sub-cellular levels that carcinogenic effects are elicited that might never occur in real life. There are scientists in industry as well qualified to generate, handle and interpret toxicological data as any in academic and official life, but all too often in the past they have seemed reluctant to express their doubts and criticisms in public. Last year, with some colleagues, I tried to interest the Society of Toxicology in initiating some public debate on what was going on: I failed. Your Society in particular has a special duty in regard to the relationship between risk and benefit. I urge you all to resist at every opportunity the allegation that there is no 'benefit' from the use of cosmetics. This is how the argument runs: some risk must remain even after the most exhaustive testing benefit by definition -- 0 therefore risk/benefit = infinity. You can put it another way: if the social acceptability of the products of an industry is defined as safety x benefit then if benefit = 0 the future of the industry is to say the least somewhat doubtful. Don't be persuaded, either, that the products of the consumer protection industry are beyond question or reproach and not themselves in need of safety evaluation. In August 1973 an Oklahoma paediatrician reported to the newly established Consumer Products Safety Commission in Washington that there was a higher incidence of damaged chromosomes in ten persons who had used a spray adhesive than in twelve who hadn't. He had also seen two deformed children born to parents who had used the sprays during or shortly before the pregnancies. The Commission acted in a matter of days in a blaze
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