Definition Feedback Workshop

First Paragraph

The cosmetic industry has been struggling to regulate harmful ingredients from the market in the past and even in the modern-day.

“has been struggling” makes it sound as if the cosmetics industry is conscientious and in favor of regulation, whereas the Author’s actual thesis is that the industry is sloppy about health hazards and resists regulation.

Skincare items with dangerous ingredients should be identified as drugs due to their excessive amounts of side effects and future problems they have caused consumers to go through.

“due to their side effects” suggests that skincare products are drugs because of side effects, whereas the Author’s actual thesis is that they are drugs because their ingredients enter the body through the skin.

Together with “in the past and even in the modern day,” the mention of “future” is the third unnecessary time signal.

Drugs can be absorbed by the skin, swallowed, injected, and even sprayed to enter the human body.

This sounds like a throwaway claim, but in fact it’s the primary definition argument: that drugs should be DEFINED by their characteristic of entering the body.

As a comparison skincare products are also absorbed into the skin.

What sounds like a throwaway comparison is actually the DEFINITION claim: that skincare products ARE DRUGS because they are absorbed into the body through the skin.

Joseph C. DiNardo and Craig A. Downs on the Centers of Disease Control website claim that “97% of the people tested have oxybenzone present in their urine.”

This valuable statistic has is wasted on readers haven’t been prepared for its significance. We don’t know that oxybenzone is dangerous; we don’t know that it’s contained in sunscreen; we don’t know that the “people tested” were all sunscreen users.

What seemed like an industry producing harmless products just showed how much of an effect these creams, essence, and makeup products have on our body internally.

The conclusion does not follow from the evidence. We never thought of the industry’s products as harmless. We don’t know that oxybenzone comes from creams. We don’t know what makeup products have to do with our bodies internally.

First Paragraph Revised

The cosmetic and skincare industry should be regulated for selling dangerous drugs. To cite just one example, the known carcinogen oxybenzone, a common ingredient in sunscreen creams, was found in the urine of 97% of sunscreen users tested by Joseph C DiNardo and Craig A. Downs of the Center for Disease Control. Illogically, and tragically for its victims, sunscreen creams are unregulated by the Food and Drug Administration because of a flaw in the definition of the word “drug.” Chemicals that can be absorbed through the skin should be considered drugs just as much as medicines that are swallowed or injected.

Second Paragraph

The article, “Dermatological and environmental toxicological impact of the sunscreen ingredient oxybenzone/benzophenone-3” from the Wiley Online Library raised concerns that the “negative health and environmental effects . . . of personal care products containing oxybenzone” are being ignored.

Now that the Author has established that the sunscreen ingredient is dangerous, the citation about the dangers being ignored has more heft.

Everyday products that consumers use to protect their skin from the harmful rays of the sun are known as sunscreens that in many cases, in fact, contain harmful ingredients that have been “reported to produce contact and photo contact allergy reactions.”

We don’t need a definition for sunscreens here, and we’ve already established their carcinogenic nature. Here we just want to add that they’re ALSO a cause of allergies.

Not only are these products leading to concerning allergic reactions but also have been linked to causing “Hirschsprung’s disease.”

We also don’t need a separate sentence for “Hirschprung’s disease,” but it would help to know if it’s a real health threat.

The ingredients that are being put into skincare are in fact causing us to face health problems and are still not considered to be associated with drugs which are shocking. 

There’s nothing new in this sentence. Its vague claim that skincare products are “not associated with drugs” is actually more confusing than helpful.

Second Paragraph Revised

No one is denying the benefits of sunscreens, but their hazards should not be ignored just because they’re not considered drugs. The article, “Dermatological and environmental toxicological impact of the sunscreen ingredient oxybenzone/benzophenone-3” from the Wiley Online Library raised concerns that the “negative health and environmental effects . . . of personal care products containing oxybenzone” are not regulated or disclosed. Sunscreens contain harmful ingredients that have been “reported to produce contact and photo contact allergy reactions” and are thought to cause Hirschsprung’s disease, the cure for which is to remove all or part of a child’s colon.

Third Paragraph

The FDA seems to get away with not regulating skincare ingredients since they have limited power from the legislation.

This claim places blame on the FDA for NOT EXCEEDING THEIR AUTHORITY to regulate food and drugs. The Author does not make clear who is responsible for the flawed definition of what qualifies as a drug. Either way, it’s the cosmetics industry that “gets away with” being unregulated.

It has been proven that of the “thirteen thousand chemicals that are used in cosmetics, only 10%” are tested for safety before being placed onto shelves.

A startling quote, nicely placed. Its origin is unclear, but it should make all users of cosmetics a little nervous.

The FDA clearly does not have strict enough regulations for products that most women and men use on a daily basis. 

Again vague about who’s at fault. Does the FDA MAKE regulations? What does it mean for them to HAVE regulations? I found a source: https://www.fda.gov/drugs/fda-drug-info-rounds-video/transcript-definition-drug-april-2017

It says, in part: Lieutenant Commander Lindsey Wagner of the FDA: A product may be both a drug and a cosmetic if it has both intended uses. For example, a shampoo is a cosmetic because its intended use is to cleanse hair. An antidandruff treatment is a drug because its intended use is to treat dandruff. Therefore, an antidandruff shampoo is both a cosmetic and a drug. Other examples of products that are both a cosmetic and a drug are deodorants that are also antiperspirants and lotion, creams, and makeup marketed with sun-protection claims. Such products must comply with the requirements for both cosmetics and drugs. 

Third Paragraph Revised

To be clear, the FDA is empowered and required to regulate the safety of food (F) and drugs (D), not cosmetics. It’s unfair, therefore, to blame the FDA for the disturbing fact of the “thirteen thousand chemicals that are used in cosmetics, only 10%” are tested for safety before being placed onto shelves. But the FDA does recognize that some skincare products qualify BOTH as cosmetics and drugs depending on the purpose for which they’re used. A typical “two category” product, dandruff shampoo, has both cosmetic use (cleaning the hair) and a therapeutic or healing purpose (treatment of dandruff).

Fourth Paragraph

The idea that drugs have a specific definition that is not altered is frightening.

This claim is unclear. What’s frightening is that chemicals that ACT as drugs are not REGULATED as drugs.

Technology is advancing every single day and there are new ingredients being used in cosmetics.

Technology is irrelevant here, but it IS frightening that the number of UNREGULATED ingredients keeps increasing.

Consumers tend to lack education when it comes to cosmetics but rely on what influencers and trends communicate to them.

It’s best to IDENTIFY with readers, not PREACH to them. We’re all consumers, so be kind to readers by admitted that WE’RE mostly uninformed about the dangers of cosmetics and rely on THE MARKET or THE GOVERNMENT to protect us without taking any personal responsibility.

Being exposed to these harmful cosmetics can result in allergic reactions, chemical burns, and even unrecoverable side effects that can be detrimental. 

These are good, but “unrecoverable side effects” is both vague and not as impressive as it would be if we knew what the side effects were.

Morgan G. Egebers explains that the FDA, on the other hand, defines drugs as, “articles intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease.”

This FDA definition comes quite late in the essay and will likely be introduced earlier in a revised draft.

Even though these might be good categories that drugs fall into there should be subcategories.

This Proposal Claim doesn’t appear to be justified by anything that’s been said so far. However, in the FDA source I cited above, the FDA does perhaps satisfy this proposal by treating some substances as BOTH cosmetics and drugs.

When we think of drugs we think of not only medications but narcotics, certain types of foods, and alcohol.

The heart of any good Definition Argument is to INSIST ON YOUR OWN DEFINITION. Here it’s essential to NOT identify with the Common Knowledge definition of drugs by saying WE.

Even though these so-called “drugs” are not used to cure a disease or prevent it, they are still considered drugs by the government that in fact have very harsh regulations.

Most readers will be confused at the uncertain boundaries the Author is drawing here. “So-called” drugs are “considered drugs” is very confusing.

When thinking of narcotics, I think of injections, snorting, absorption by the skin, and oral usage.

The goal of a Categorical Argument is to make the essential Categorical claim. There’s no room for “I think of” language. Say the words.

Cosmetics that are absorbed by the skin and have harmful or even more detrimental ingredients in them still are not considered to be at the same level as drugs and should be.

That’s better.

Fourth Paragraph Revised

The idea that cosmetics that function as drugs could be unregulated is frightening, especially considering how rapidly the number of ingredients increases every year. We tend to trust in government to keep us safe from dangerous products and put our faith in the marketplace. Products that can result in allergic reactions and chemical burns, we believe, are regulated, but as Morgan G. Egebers explains, the FDA defines drugs as, “articles intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease.” And that does not describe cosmetics or skincare products! What we need are regulations to protect us from cosmetics that are absorbed by the skin and have harmful detrimental ingredients.

Fifth Paragraph

Both drug store cosmetic companies such as L’Oréal and other higher-end big names such as NARS have been reported to contain lead in their products which has been vocally expressed to the public for years and is still not resolved.

This evidence is undercut by the lack of clarity in its phrasing. Drug store companies and big names don’t CONTAIN LEAD. Their products do. It’s unclear who “vocally expresses” the presence of lead. And it’s unclear what needs to be resolved.

People are still buying these harmful products since they have trust in the FDA that in reality was never there to make an impactful effect on the industry’s regulations.

Unlike the case of sunscreens (about which there MAY be some FDA oversight), cosmetics without therapeutic uses are truly NOT regulated by the FDA, so here we’re describing a different situation than in earlier paragraphs.

The fact that we know that our most favored cosmetic companies contain harmful ingredients shows a lack of transparency from big-name companies.

Again, the COMPANIES don’t CONTAIN harmful ingredients; their PRODUCTS do. This claim still doesn’t resolve the question of who “vocally expresses” the presence of hazards; apparently NOT the cosmetic makers.

In the article, “COSMETICS: A Dermatologist Looks to the Future: Promises and Problems,” Albert M. Kilgman explains how people using these cosmetics have a lack of education with “no premarketing proof of efficacy or safety required.”

It’s odd to blame “people” for not knowing something the cosmetics companies are not required to prove. Where would a consumer look for proof of safety if safety has not been proved?

Manufacturers are also able to make any claims they desire and still be placed on the market.

MANUFACTURERS are not PLACED ON THE MARKET. There is clearly a problem when products can be described as manufacturers choose without any oversight. The Author needs to be clear where the responsibility lies.

This shows how lousy regulated the cosmetic industry is even in a day and age where everything seems to be doubled-checked and approved. 

Granted. And already demonstrated. Can go without saying.

Fifth Paragraph Revised

For years whistle-blowers and consumer safety advocates have reported the presence of lead in cosmetics from drug-store cosmetic companies such as L’Oréal and higher-end big names such as NARS, but to no effect. Consumers shrug off the dangers, falsely trusting the FDA—which has no jurisdiction over cosmetics—to protect them from harm. Our favorite cosmetic companies have no incentive to divulge the dangerous content of their products. In the article, “COSMETICS: A Dermatologist Looks to the Future: Promises and Problems,” Albert M. Kilgman explains that manufacturers are required to show “no premarketing proof of efficacy or safety.” Unlike food producers, drug companies, even toy-makers(!), cosmetic manufacturers can make any claims they like about the products they market.

Sixth Paragraph

People are simple creatures who love to spend money on anything until they experience any negative effects in skincare for example allergic reactions or even health problems in some cases is a beginning for consumers to get concerned.

As mentioned before, a better strategy than insulting our readers is to express our shared failings. So, since we’re all consumers (and suckers for marketing!), the Author should acknowledge we’re in this boat together.

It takes countless products and negative side effects for a consumer to start getting interested in the ingredient list of cosmetics which shows how corrupt the cosmetic industry has been. 

Since lead has already been used as an example, a good idea is to follow that narrative.

Sixth Paragraph Revised

Most of us will use a beloved product even if it causes us small irritations or concerns. We might not make the connection between our skin cream and an allergic reaction, for example, until the side effects are painfully obvious. In the case of lead in our cosmetics, the effects could be life-threatening and the effects never obvious. Lead was known to be hazardous as early as the 1970s, followed quickly by the introduction of unleaded gas. But it wasn’t finally banned until the mid-1990s despite tight regulations imposed by the government. The fact that it’s still a component of popular cosmetics that can be absorbed by the skin is truly terrifying, especially since cosmetic makers aren’t required to divulge its presence.

Seventh Paragraph

The regulations placed by the United States compared to Europe also differentiate.

This promising claim doesn’t go far enough. If regulations are tighter in Europe, and the Author prefers European transparency and safety, NOW is the time to say so.

In the article, “Analytical Challenges and Regulatory Requirements for Nasal Drug Products in Europe and the U.S.,” from the MDPI website, I realized how intricate and precise regulations are placed on the production and testing of nasal sprays and drops.

We are being led aimlessly down a path here. Good guidance requires the Author to let us know WHERE WE’RE GOING before we start. We don’t know yet that the Author is impressed by the European regulations on sprays, or why. If we knew, the evidence would have more power.

A nasal spray is considered a drug even though it is absorbed by the skin.

A little bit confusing. Wouldn’t it be considered a drug if it had therapeutic use (which it surely must) and was introduced INTO the body through a cavity (which it is)?

The skincare industry does not have nearly as much testing and regulations for products that will be released and also for the fact that they are absorbed by the skin.

I’m lost now. Is this the AMERICAN skincare industry we’re talking about?

Things that are taken into consideration when producing a nasal spray include “droplet size distribution (DSD), plume geometry, spray pattern and shot weights of solution nasal sprays.”

Back to the sprays. Are we back to talking about Europe?

These small details are all necessary to make sure a product works accurately and has limited faults.

We don’t know WHY knowing the droplet size is necessary, but we’ll accept it if there’s evidence. Or maybe the Author is just making a deliberate “apples and oranges” comparison.

On the website Science Direct the “COSMETICS” article states that “proof of efficacy or safety” in topical products that are said to be antiaging and brightening.

A confusing sentence. Unclear whether there IS or ISN’T a requirement to show proof of safety for skin brightening products. Certainly there SHOULD BE, right?

This statement alone explains how the cosmetic industry is so large and developed, yet still has no intentions to advance its procedures for safety in order to prevent toxic ingredients that are marketed from getting approved. 

In the final statement about products that threaten human health, we shouldn’t wonder what the Author’s firm position is.

Seventh Paragraph Revised

Europe does a much better job than the US of regulating healthcare products that may or may not be considered “drugs” on either continent. Compare the unregulated US marketplace to how tightly Europe regulates nasal sprays. According to “Analytical Challenges and Regulatory Requirements for Nasal Drug Products in Europe and the U.S.,” Europe considers nasal sprays drugs and regulates not just their ingredients, but even their “droplet size distribution (DSD), plume geometry, spray pattern and shot weights.” These small details are all necessary to make sure a product works accurately and has limited faults. Meanwhile, in the US, as the “COSMETICS” article on the website Science Direct demonstrates, even “anti-aging” and “skin brightening” creams, which much surely be chemical in nature, and which are obviously absorbed through the skin, are not required to show any “proof of efficacy or safety.” The US cosmetic industry has shown no intention of improving its safety record or removing toxic ingredients from its products without regulation. It’s high time they were required to respect the health of their customers.