My FDA complaint – Ava Anderson NonToxic

US Government Regulation of Hand Sanitizer

The U.S. Environmental Protection Agency does not regulate hand sanitizers. While EPA regulates a wide range of antimicrobial products, it does not regulate products used directly on humans or animals.

Topical antimicrobial products are regulated by the Food and Drug Administration (FDA). FDA published a proposed rule on topical antimicrobial drug products for human use in the form of a ‘‘Tentative Final Monograph’’ in 1994. http://www.epa.gov/epp/pubs/guidance/fr73no94.pdf

All products that are marketed as over-the-counter (OTC) drugs must either receive pre-approval through the New Drug Application (NDA) process or they must comply with FDA’s OTC Monographs.*

A Cosmetics & Toiletries article “Comparatively Speaking: US FDA Categories of Hand Sanitizer Actives” gives an easy to follow explanation of the Monograph for the OTC drug, Hand Sanitizers:

“Hand sanitizers are considered drugs and regulated by the FDA under the 1994 Tentative Final Monograph (TFM).”

“The 1994 TFM classifies only two active ingredients as Category I (GRASE) for hand antiseptics: alcohol 60–95% and povidone iodine 5–10%. Since povidone iodine typically is not used in hand sanitizers, alcohol is identified as the only active ingredient the FDA currently recognizes as GRASE for hand sanitizers.”

“No natural product active ingredients, such as thyme, etc., currently are listed in the Monograph. Thus, natural antimicrobials are precluded from legal use in the United States, unless an approved New Drug Application (NDA) is obtained. At present, none have been granted.”

http://www.cosmeticsandtoiletries.com/regulatory/region/northamerica/60657047.html

Last year the FDA announced that they had sent a number of warning letters and corresponding press releases about these warnings, directed at some companies that were selling illegal hand sanitizer.

Hand Sanitizers Carry Unproven Claims to Prevent MRSA Infections

“FDA is cracking down on companies that break federal law by promoting their products as preventing MRSA infections and other diseases without agency review and approval.”

“Examples of unproven claims found on product labels are

• kills over 99.9% of MRSA (methicillin-resistant Staphylococcus aureus)

• helps prevent skin infections caused by MRSA and other germs

• is effective against a broad spectrum of pathogens, including MRSA”

http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm251816.htm

I asked the Clean Well Company on their Facebook page, whether they had any plans to submit an Application for their formula as a New Drug. My question was deleted and I was blocked.

UPDATE: Clean Well addressed the FDA WARNING: http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2011/ucm313996.htm

I personally find it ridiculous and short sighted and even dangerous that ingredients like triclosan and benzalkonium chloride, benzethonium chloride and parachlorometaxylenol (Category III ingredients) are allowed to be used as active ingredients in Hand Sanitizers by law, while essential oils are not…but that is the law.

“Since the monograph currently is in a tentative state, manufacturers are able to market hand sanitizers based on Category III ingredients.”

Seriously?  Since 1994 there MUST be sufficient scientific data to remove triclosan and at LEAST move some essential oils to Category III! (Triclosan…Why It Should Be Banned)

http://www.cosmeticsandtoiletries.com/regulatory/region/northamerica/60657047.html?page=2

THIS is yet another reason why I don’t think the FDA should have MORE control over the safety of cosmetics – look how far they’ve come with just ONE category of OTC drug in 18 years!  NO WHERE!

But…that’s the law…so companies should either follow the law or work to get it changed.

From the FDA: Advice for Consumers – Don’t buy over-the-counter hand sanitizers or other products that claim to prevent infection from MRSA, E. coli, Salmonella, flu, or other bacteria or viruses. If you find products on the Internet that you believe make false or unproven claims, tell FDA by following the instructions at Reporting Unlawful Sales on Internet.

http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm251816.htm

I reported the company Ava Anderson NonToxic because they have been selling “Hand Sanitizer” that does not follow the FDA Monograph…in fact…they promote that it contains no alcohol!  Their salespeople have even pushed this product at nurses in hospitals and tried to convince them to use it instead of the FDA-approved alcohol hand sanitizer. Well when I read that…I wrote to the FDA and filed an official complaint.  People DIE of bacterial infections…and for salespeople to mislead health care workers about the safety and efficacy of this product is criminal.

Why am I such a fan of essential oils as a potential safe ingredient but not this product that  claims it does contain essential oils?

Simple…look at the ingredients: Organic Barbandenis Leaf (Aloe Vera) Extract, Carboxylmethylcellulose Sodium (Cellulose Gum), Organic Citrus Aurantium Dulcis (Sweet Orange) Essential Orange Oil, Organic MeleleucaAlternifolia (Tea Tree) Extract, Organic Azadirachta Indica (Neem) oil, Organic Citrus Medica limonum (Lemon) Essential Oil, Organic (lavandula Angustifolia (Lavander) Essential oil, Yucca Schidigera (Mojave Yucca) Extract, Geogard Ultra.

Note the mislabeled ingredients: Geogard Ultra is not a legal ingredient name; it’s a Brand Name for a synthetic preservative. The correct INCI-Name: Gluconolactone (and) Sodium Benzoate. A product that will kill germs on hands contaminated with bacteria would not need to have a preservative.  It would not itself, grow germs.  And yet this product contains preservatives.  That is a red flag!

Here is a copy of my complaint:

8/24/2011
NAME REMOVED
Food & Drug Administration

Dear Ms. NAME REMOVED,

You may remember me from my complaint against the cosmetic company “100% Pure“. I believe at that time I also expressed concern about another company, Ava Anderson Nontoxic.  Earlier this year, Ava Anderson announced her new product, a non-alcohol Hand Sanitizer made with essential oils.  On Facebook, her salespeople are sharing how they are promoting this product to nurses in hospitals, to use instead of that “drying alcohol” hand sanitizer!

A few years back, when my Father was in the hospital, he contracted all kinds of bacterial infections.  When he was in a coma in the intensive care unit, we learned how important it is to use the FDA recommended hand sanitizers to avoid spreading these germs to other family members and most importantly, patients.  My Father might be alive today if everyone in that hospital had followed recommended sanitization procedures.  He’s not…he died when his body was unable to continue to fight off those infections. So this issue is personal to me, but I also was made aware of the FDA’s increased attention to the issue of misbranded and illegal hand sanitizers recently.

Ava Anderson makes many of the same claims for her products as the Clean Well Company is accused of making in their FDA Warning Letter.  I have included some quotes from various Ava Anderson Nontoxic websites and the websites of their salespeople.  In addition, the company continues to make drug claims for their cosmetic ingredients, also a violation of the FDA cosmetics regulations. This company is not a local, Farmers Market-type company; this company is among the five national finalists in Entrepreneur magazine’s “Entrepreneur of 2011” awards competition.  They are outspoken critics of the FDA, saying they are not doing enough to keep cosmetics safe, and have been featured more than once on the Campaign for Safe Cosmetics Facebook page as an example to other companies and consumers.

This company deserves to be exposed for all the laws they break! (And this does not even include all the USDA National Organic Program regulations they break with their false claims of having 100% Organic products, and organic ingredients in their products. They are NOT USDA Certified Organic and neither are their ingredients.  But that is a separate battle.) I apologize for how disorganized the following information is, but I just copied and pasted and saved a bunch of web addresses.  Please follow up on this company!!  A warning letter to them would serve the entire industry as being on notice that the FDA DOES care about the safety of cosmetics, and are working to make sure companies follow the laws!!

Violates FDA regulations for hand sanitizer

Ava Anderson Hand Sanitizer 16 oz: “Organic Barbandenis Leaf (Aloe Vera) Extract, Carboxylmethylcellulose Sodium (Cellulose Gum), Organic Citrus Aurantium Dulcis (Sweet Orange) Essential Orange Oil, Organic MeleleucaAlternifolia (Tea Tree) Extract, Organic Azadirachta Indica (Neem) oil, Organic Citrus Medica limonum (Lemon) Essential Oil, Organic (lavandula Angustifolia (Lavander) Essential oil, Yucca Schidigera (Mojave Yucca) Extract, Geogard Ultra”

“Hand sanitizer set – When soap and water are not available, use our alcohol free hand sanitizer to promote clean, healthy hands without exposure to harmful chemicals. Organic essential oils work together to cleanse and moisturize hands naturally and safely. Leaves hands silky soft. No parabens, no phthalates, no triclosan, no sulfates, no synthetic fragrance or dyes. [HSA01] 16 oz bottle with pump and two, 2 oz purse/backpack sizes. Refill available”

“Non-Toxic Alcohol-Free Hand Sanitizer, with organic aloe and organic essential oils! Independent tests done show it kills 99.99% of germs!”

“Hand Sanitizer from Ava Anderson Non Toxic!!! www.MyNonToxicBiz.com NEW PRODUCT! Hand Sanitizer: As you know, we just launched our Non Alcohol Hand Sanitizer, with organic ingredients. We are so proud to supply you, your families and customer with this fabulous product. Please remember that there are very few competitors in the market (and now we are one of them). Many claim to be natural and use ethanol (same thing as alcohol), some claim to be organic and use benzalkonium chloride — a “6″ (carcinogen) on the database. Most use triclosan, and other harmful toxic chemicals. Here is more information that you should be aware of:

Test results indicate that our sanitizer kills
>99.99% of common household and community germs, including those transferred from person to person, from animal to person and from hard and soft surfaces to person.

The following pathogens were killed at a percentage equal or greater to 99.99% within 15 seconds after exposure to the product:
• Gram-positive bacteria, including Staphylococcus aureus
• Gram-negative bacteria, including E-coli
• Viruses, including Herpes simplex Type 1 & Human Coronavirus
• Fungus, including Trichophyton

Specifically the tea tree and neem in our product and all of the organic essential oils have anti-microbial properties. Some interesting information concerning Alcohol-based hand sanitizers v. Non-Alcohol based hand sanitizers:

Alcohol is notorious for removing oil from skin. This oil is one of the body’s primary natural defenses against bacteria. Tests demonstrate that repeated use of alcohol based hand sanitizers can actually lead to increased bacteria on the skin over time. In other words, ongoing use of alcohol-based hand sanitizers become less effective the more frequently they are used. Not to mention, dry ,cracked, damaged skin.

Subjectively, users of essential oil based waterless hand sanitizers report a far greater level of satisfaction with the condition of their skin and hands. Almost 50% of individuals using alcohol based hand sanitizers report doing so at the expense of comfort and skin condition. Our AVA Hand sanitizer leaves your hands silky soft, form the organic aloe and essential oils. It is an amazing product, and it smells fantastic.”

http://www.avaandersonnontoxic.com

http://mayangelstar.com/2011/04/20/new-non-toxic-alcohol-free-hand-sanitizer/

http://www.maryanndunham.com/maryann-dunham/ava-anderson-launches-hand-sanitizer   http://avaandersonnontoxic.blogspot.com/2011/04/new-hand-sanitizer-from-ava-anderson.html

http://www.mynontoxicbiz.com/

http://avaandersonnontoxic.blogspot.com/2011_01_01_archive.html

In addition her cosmetic makeup claims are OTC drug claims;

“Foundation (light OR medium): French Clay is excellent for remineralization of the skin, absorbs toxins, and also purifies congested, acne-prone skin types. It improves blood circulation and makes the skin look radiant and hydrated, reducing the appearance of wrinkles and broken capillaries. Unlike synthetic powders, talc or titanium dioxide, silk has the unique characteristic of air permeability. Silk is full of anti inflammatory properties to help reduce puffiness; it helps with firmness of the skin and also contains natural sunscreen, protein, and other essential amino acids. Not only does silk act as a natural moisturizer, it assists in renewing old and damaged cells, thus reducing signs of aging, and reduces pigmentation like blemishes. “

“Blush: French Clay has rich mineral content and acts like a magnet for toxins. It improves blood circulation and makes the skin look radiant, hydrated, reducing the appearance of wrinkles and broken capillaries. It also purifies congested, acne-prone skin types. Silk powder has anti-inflammatory properties, helps reduce puffiness, maintains firmness of the skin, renews damaged skin cells, contains natural sun protection, and absorbs excessive oil, leaving the skin quite clear and soft. Reduces pigmentation such as blemishes. Natural anti-bacterial and anti-fungal properties. It relieves dry skin, soothes itchiness, redness and irritation, and improves general skin health and immunity, combating bacterial infections, including acne.”

“Lip Balm: Coconut oil is excellent as a skin moisturizer and softener. Beeswax provides soothing, softening, anti-bacterial and antiseptic properties that heal the skin and retain moisture. Sweet Almond Oil is easily absorbed, and helps to leave the skin soft and satiny smooth. Shea Butter has moisturizing and healing properties and is rich in Vitamins A, E, and F, and a number of other vitamins and minerals that help to soothe, hydrate, and balance the skin. They also provide skin collagen which assists with wrinkles and other signs of aging. This product is also beneficial for the treatment of itchy skin, skin rashes, eczema, dermatitis, wrinkles and chapped skin. Shea Butter offers a low level of UV protection (approximately SPF-6).” NOTE: claims SPF 6 but not labeled with active ingredients.

Sincerely, Susan Sawhill Apito

+++ Earlier this year I obtained a copy of the field report via the Freedom of Information Act.

The Complaint is number 2012-1162.  CC#122040.

Initial Evaluation/Initial Disposition
Problem Keyword = labeling
Problem Keyword Details = False Drug Claims
Initial Evaluation = FDA Action Indicated
Initial Disposition = Surveillance Information for Next EI (means – this information would be looked at during the next scheduled inspection)
Disposition Date = 11/14/2011 Initial Disposition Remarks = REDACTED BY FDA

+++ I followed up with the FDA but my follow up questions were never answered.  Am I satisfied with this outcome?  Not so far – that is for sure!

Perhaps other more urgent issues prevented a Warning Letter being sent to Ava Anderson NonToxic.  I don’t know.  It was not clear to me from the documents I received, what, if anything, was done about the fact that Ava Anderson Non Toxic is selling an illegal hand sanitizer.

The FDA has an entire web page and has sent out press releases asking the public to alert them to illegal hand sanitizers.  I did so, following the process that was explained to me.  The product is still being sold and the company and their thousands of salespeople are still marketing this product as a superior alternative to the alcohol hand sanitizers the FDA recommends to consumers.  I want to know why – and I want to know what is being done to stop them.

I filed a complaint, they are investigated…and yet nothing is done.  Why?  If the FDA regulations can be broken so openly and with the knowledge of the FDA agents…why even have laws?

While I am just a blogger with a mission – I do hope my article gets picked up by other websites - I think the public knowing that dangerous and illegal cosmetics are being sold by companies and even after an investigation, that these businesses just carry on business as usual and not even get a Warning Letter, is something the public needs to know!

Ava Anderson’s owners are outspoken critics of the FDA and the job they do.  They regularly say “other” cosmetic companies are selling dangerous cosmetics – that is the centerpiece of their marketing – that “they” are the ONLY nontoxic cosmetic company IN THE USA!  They tell their customers that they are at risk for cancer and other illnesses because the FDA does nothing to protect them…and yet their own company breaks the few laws for cosmetics that here are: they make illegal drug claims, use ingredients that are not FDA-approved as colorants and are selling an OTC drug that does not follow the FDA monograph.

I want to know what the FDA is going to do about this. 

*What is an FDA Monograph? They are FDA regulations which outline specific active ingredients, doses, formulations and labeling for OTC drugs. Here is a link to a copy of the 1994 Tentative Final Monograph (TFM): www.fda.gov/ohrms/dockets/ac/05/briefing/2005-4098B1_02_03-FDA-TAB1.pdf

(1) Clean Well Warning Letter: http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm251979.htm?utm_campaign=Google2&utm_source=fdaSearch&utm_medium=website&utm_term=1994%20monograph%20hand%20sanitizer&utm_content=3

About these ads

18 responses to this post.

  1. Hi Sue, whilst I support fully your mission against Ava Anderson (they are extremely annoying in their position of self-appointed safest cosmetics – a position that is entirely nonsensical), but I would like to make one small point of correction to your assertion that a product that claims to kill bacteria would not need a preservative. Many antimicrobials are quite specific in their spectrum of activity, and some are very specific against bacteria only, with no activity against fungi. Such a product would require an antifungal preservative. Having said that, there are some claims for the product killing fungi, but they are claiming to kill 99.99% within 15 seconds. I find that extremely difficult to believe (unless the inoculum used was very small, in which case the test is invalid), as fungi are simply not killed so quickly by most antimicrobials. It suggests that the test was either not robust, or that the results were falsified.

    • In researching the subject of vitamin c and benzene I ran across a site I have never visited before.

      I just HAVE to share a quote…THIS is the way a company SHOULD respond to being questioned!!

      “Before I end, I want to add that we have a request from you all. Question us, observe us, put us under the same microscope, measure us with the same measuring tool. Do it across the board, do it consistently, do it relentlessly, do it with all of us (in this industry).

      We are coming at you the only way we know how, our goal is to make and sell bodycare products that we love and use. We show you our entire face from how we stumbled upon a company to how we make our products + what is in them. Thank you for allowing us to grow, learn and be better than what we were yesterday.”

      http://www.ecosevi.com/blog/?p=577

      Tomorrow I will definately check out their products!!

      • @Sue – whilst I agree with the majority of your points, I think it is important to include some further points of both context and clarification. I don’t know where you got the quote about the undesirbale chemical reaction, but they need to check up on their chemistry! Sodium benzoate itself has NO antimicrobial activity. It HAS to be converted to benzoic acid to be effective, which is why the pH is such an issue when using this product, so the reaction described in the quote MUST take place! The conversion from sodium benzoate to benzoic acid is wholly pH-dependent – I can provide more details if anyone is sufficiently interested in this. The issue is not the formation of benzoic acid, it is the formation of benzene from the reaction of sodium benzoate/benzoic acid and ascorbic acid.

        This reaction was first observed in Coca Cola, when benzene was detected (in extremely low concentrations). Prior to this, science was unaware of this issue. I have been warning against using benzoic acid in the presence of ascorbic acid since I first learned of this reaction. However, this only really applies to the deliberate addition of ascorbic acid to systems containing benzoic/benzoate. The concentrations of ascorbic acid carried over from other natural ingredients would be too low to cause any real issue. Also, most cosmetic products are not liquids as mobile as the cola drink and, therefore, any reaction would be less likely to take place. Any benzene produced under such conditions would almost certainly be considered to be a zero risk.

        It is not quite accurate to describe sodium benzoate as a preservative that forms benzene without the context I have just described and, whilst Ava Anderson are guilty of many things, I don’t think this is enough of a stick to properly beat them with. There’s plenty more ammunition against them that holds much more weight!

        • I am happy to hear that the BENZENE that many are concerned with when using this preservation method, does not present the risk it seems like it might, when you read about it out of context.

          However…we all know these are the same people who expect “ZERO” risk – and the precautionary principal to be the measure for others – like parabens and lead in lipstick. So when you sit yourself on the Throne of the Nontoxic Cosmetics Kingdom…and proclaim you are “the ONE”…”the ONLY”…as Ava and her mother, Kim, and their followers have proclaimed – you need to expect to be held to a higher standard!

          This company has been paraded throughtout the Nontoxic Cosmetics Kingdom as the one to admire, given Awards, pointed out to the media at every turn as the company leading the way. well the centerpiece of the Campaign for Safe Cosmetics is the lack of publically available toxicity testing on ingredients and products that cosmetic companies are selling. So…where are the publically available tests on Ava’s product line? Pot – Kettle, Kettle – Pot.

          I wish I titled this article “The Emperor’s New Clothes”…

          • I am more than happy to “bash” this company whenever possible, my concern here is that these comments on sodium benzoate may lead to misunderstandings about the potential for benzene formation and lead to scare stories about this preservative, which is the last thing the industry needs, which is why I made my observations! :-)

  2. @ Dene – good point about the fungi issue and preservatives.

    I checked to see if Gluconolactone & Sodium Benzoate (the chemicals in GeoGuard Ultra) to see if they work on fungi, it seems so.

    Important to note, this preservative is “not for use in products which contain ascorbic acid (due to undesirable chemical reaction as a result of the destabilization and oxidation of the ascorbic acid which may convert the sodium benzoate to its acidic state (benzoic acid)”

    I had read warnings for this preservative creating benzene – a known carcinogen. Curious choice for a company that claims to “be” the ONLY nontoxic cosmetics company in the world…choosing a preservative that forms BENZENE!!

    As I have said before – I’m no expert – but doesn’t aloe vera contain Vitamin C (ascorbic acid). What about the citrus essential oils? Do any vitamins carry over from the natural source material (citrus peel) into the essential oil when the method of processing is cold pressing, such as that used to produce these EOs?

  3. Posted by Roman on June 22, 2012 at 6:28 pm

    This article has inspired me to carry on writing on my own blog

  4. Posted by Anonymous on September 14, 2012 at 8:30 am

    so where are you at with this complaint ?

  5. Posted by Anonymous on August 13, 2013 at 12:04 am

    First off as an Executive with this company I can tell you that Kim and Ava have never said that they are the only company out there that has amazing non toxic products. As others have stated above the issue with geogard ultra is when it is combined with ascorbic acid which our products do not. As for the hand sanitizer it has been tested in the same places that also test other FDA approved hand sanitizer and have rated at 99.9% effective. The FDA will not approve without harmful chemicals like triclosan/alcohol etc.. I think there are so many other harmful toxins and chemicals out there that you should be writing to the FDA about. It makes me sad to see that you would go after a company that is trying to change government policies and make products safer for all of us. Maybe you should take a try at that or start your own company and create safe non toxic product using your own ingredients that you deem safe.

    • Dear “Anonymous” Executive with Ava Anderson Nontoxic. My original post was a while back – perhaps the claims have changed. Your company still claims to be “the first” if not “the only” nontoxic cosmetics company. From one Press Release: “(New York)- Ava Anderson Founder, Chief Executive Officer, Director of Product Development of a new innovative skincare sought out to find a solution to a growing problem she saw in the cosmetics industry. The issues at hand has been swept under the rug and slipped through the cracks. It is the unsafe cosmetics and skincare lines that are available for consumers. Believe or not the mastermind behind the first non-toxic skin and cosmetics line is Ava Anderson, a 15 year old entrepreneur from Rhode Island. ”

      Calling your company “the first non-toxic skin and cosmetics line” is not just arrogant and narcissistic, it is flat out wrong. And disrespectful to every handcrafted soap maker, every herbalist creating salves and creams for her customers, every natural cosmetics maker that came before Ava and her crack team of marketing and advertising executives.

      Instead of being inspired by the very people who already were formulating safe, natural, nontoxic ingredients – some of which happen to be in Ava’s products – you insulted them. You ignored them. You referred to “them” as selling “unsafe cosmetics and skincare lines”. Where exactly do you think the manufacturers you buy from get these formulas from? Because there is NOTHING new or innovative in your products – it’s all been done before by others – they just don’t put billboards with their faces on Times Square!

      And from a press release “Ava Anderson Non-Toxic is a cosmetics and skin care company that has accomplished the seemingly impossible: every single one of their products has a zero hazard score on the Cosmetics Database. Not only that, but each ingredient in each of its products has a zero hazard score!” Which we all know never was true and is not true now. The only reason your products EVER got a zero score was because of data gaps and errors in the database – NOT because your products present ZERO risk! Grinding wintergreen essential oils into your lips is not a safe practice regardless of what SkinDeep may say!

      “As others have stated above the issue with geogard ultra is when it is combined with ascorbic acid which our products do not” – how do you know your products do not contain ascorbic acid? Why don’t you list the FDA required INCI name for this synthetic preservative if you are so proud of it?

      “As for the hand sanitizer it has been tested in the same places that also test other FDA approved hand sanitizer and have rated at 99.9% effective. The FDA will not approve without harmful chemicals like triclosan/alcohol etc.”

      So – you claim to be an executive for this cosmetics company and you are not aware that the FDA does not approve cosmetics or OTC drugs? How is that even possible?

      And since when is alcohol a “harmful chemical”? It can be 100% natural and may even be USDA Certified Organic. Which is more than can be said for any of your products.

      But if you think alcohol is such a “harmful chemical” – why is it the 4th ingredient (after two known hazardous synthetic chemicals) in your shampoo?*

      The problem with your company is you have always been working backwards from the SkinDeep database instead of working forwards from the decades – lifetimes – worth of work done by others who have been creating safe skincare since before Ava was born.

      “It makes me sad to see that you would go after a company that is trying to change government policies and make products safer for all of us.”

      If I actually believed your company claims – like I did when I went to your first Annual Meeting in Rhode Island - I’d be singing your praises. But your company – Ava & Kim – are not motivated by making safe, natural or certified organic products – they are motivated by making money. By misrepresenting their company, their mission, and the truth about the ingredients in their products and by fearmongering regarding the risk of their competitions products.

      I used to believe Ava & Kim were being fooled by the factories that make your products – that your company was a victim of being lied to about the naturalness or safety of ingredients. Now I know it is willful. You market your perfume as being 100% essential oils when many of the ingredients (now that you finally disclosed ingredients) do not even EXIST as essential oils. If you were told otherwise – you should know better.

      I saw first hand how you sold your lipsticks as “lead free”. Where are those lipsticks now? Did you finally realize that just adding a few botanicals to a synthetic, commercial formula for lipstick and coloring with illegal colorants was a problem?

      And finally, your company is hurting every true USDA Certified Organic company – the people who are the “read deal” – with your illegal marketing of your products as organic without following the USDA NOP regulations. That makes your company one of the bad guys…regardless of what “greenwashing” ingredients you throw into your products.

      Sue

      *[Shampoo - Ingredients: aloe barbadensis (organic aloe vera) leaf juice extract, coco glucoside, behentrimonium methosulfate, cetearyl alcohol, carboxymethyl cellulose sodium, dipanthenol, rice bran oil (organic), vegetable glycerin, geogard ultra, mentha piperita (peppermint) extract, yucca schidigera (organic mojave yucca) extract, equisetum arvense, urtica dioica (organic nettle), melissa officinalis (organic lemon balm), citrus sinensis (organic sweet orange) essential oil, citrus medica limonum (organic lemon) essential oil, punica granatum (organic pomegranate) essential oil]

    • The series of claims made by Ava Anderson is unscientific posturing and misleading consumers. The use of “non toxic” in the company name implies that other cosmetics may be toxic. Far too many people don’t understand chemistry or toxicology – there is no such thing as “non toxic” with no further qualification. Almost all substances may be toxic and, almost equally, ALL substances have safe exposure levels (no matter what the origin of the substance, or what it suits you to believe). No cosmetic product is placed on the market to knowingly case harm. Sue is absolutely correct in her accusation regarding Skin Deep – probably the greatest confidence trick played on consumers in the cosmetics industry – it can’t possibly function as a guide to safety because there is NO information on exposure, only hazard. Safety is all about risk assessment, and you can’t assess risk in the basis of hazard alone. I do wish the amateurs would get out of the industry (or just stop telling lies and making it up as they go along). The morality of the Ava Anderson position is untenable – you are not making safer products. If you persist in these claims, you should provide the extensive toxicological data in support. It doesn’t exist for many of your “safe” ingredients. The consumer deserves better.

  6. Posted by Jessica on October 10, 2013 at 11:01 am

    I’m not looking to argue or stay anything. I’m simply researching this company. If I understand correctly, the problems you have stated that you have with this company are the claims they make concerning their cosmetics line and the use of Geogard Ultra in the hand sanitizer (which is not a very good preservative as out has a reliability of about 9-18months – swiftcraftymonkey.globally.com/2010/preservatives:geogard ultra). Please let me know if other problems that you see with their products. Consequently, if the website address doesn’t work, let me know. I’m trying to do this from my mobile phone. Thank you in advance.

    • Oh no…the problems with Ava Anderson Nontoxic are far more serious than the preservative in their illegal hand sanitizer. They sell perfumes which they market as 100% essential oils, but some of the ingredients do not even EXIST as essential oils. They also market their products as organic in violation of the USDA NOP. They have claimed “their” lipstick does not contain lead and is superior to other brands, yet they use illegal colorants some of which are known to contain lead [vegetable pigments which are only FDA-approved for food - not cosmetics - and whose suppliers clearly disclose they may contain lead]. ETC. They also have made claims to be “the first” nontoxic cosmetics company…a slap in the face to all the wonderful natural cosmetics companies who were selling NATURAL cosmetics before Ava was even born. They set lofty goals and then claim to have met those goals when in truth, they fall very short. They are a product line full of man-made, synthetic ingredients made by the same factories and using the services of the same formulators as the companies they claim to be better than! If you want more examples…I have more.

    • Posted by dene62 on October 10, 2013 at 2:03 pm

      With respect, Jessica, the reliability problem is in the link you’ve provided! Some of the chemistry in the main article is a little suspect, and the reference to pH is inaccurate, and not the best advice. If used properly, Geoguard Ultra (produced by a COMPETITOR of mine!) is a perfectly good system. The trick is to understand what you are actualy doing – so many people don’t!

  7. Posted by Kristin on December 12, 2013 at 10:18 pm

    What a weirdo!!!!

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