Consumer Product Toxicology
Consumer product toxicology evaluations involve a wide range of chemical and biological
compounds. With respect to toxicity, the manner in which consumer products are used
can be just as important as the chemicals in the products. For example, ammonia
and chlorine bleach are common in most households but, if combined, will produce
chloramine gas with potential pulmonary toxicity. Unintentional exposure to toxic
gases (such as carbon monoxide from a faulty heater) can also cause significant
adverse health effects or even death. Similarly, most plastics are considered to
be non-toxic; however, certain plastics (such as vinyl) can release lethal hydrogen
cyanide (HCN) vapors as a result of pyrolysis or combustion. Thus, the circumstances
of exposure may have toxicological relevance greater than the product's composition.
This is often a key point in cases involving causation and/or liability.
Our toxicological experience assessing the health effects of consumer products covers
a wide range of product types including cleaning and janitorial chemicals, cosmetic
products, hair and beauty products, herbal products, poison baits, combustion devices
and dozens of others. The following describes a few areas for which TCAS
has been regularly retained for expert consultations and assessments. Please
contact our office for information concerning any type of consumer product
not shown here.
Cleaning and Janitorial Chemicals
Show all results for "Cleaning and Janitorial Chemicals"
Cleaning chemicals have a wide range of toxicological properties that are well-documented
with appropriate warnings based on composition and chemical interactions with one
another and the environment. Acidic washing agents contain strong mineral
acids, surfactants, corrosion inhibitors and chelants which remove inorganic deposits
and scaling. Examples include muriatic acid (for cleaning concrete, swimming pools,
etc.), vinegar (for removing calcium deposits) and sulfuric acid (for dissolving
proteins, greases amd organic substances). Alkaline cleaners typically
contain sodium hydroxide, potassium hydroxide, bleach, ammonia and other alkalis.
These are designed to dissolve oils, fats, grease and protein-based deposits.
Neutral substances are pH-neutral, non-ionic surfactants which dislodge and
disperse dirt. Degreasers are solvent-based compounds primarily designed
to dissolve grease and other petroleum-based substances.
As these chemicals can all be ingested, absorbed or inhaled, there are many well-documented
toxicological endpoints associated with both short- and long-term exposures. TCAS
has significant experience assessing cleaning and janitorial chemical exposures.
recent exposure case in our toxicological case studies illustrates how a plaintiff's
claims of damage resulting from exposure to a chemical stripping agent were disproven
when Dr. Sawyer validated her claims against her medical history and assesed the
toxicological factors. (Dr. Sawyer was retained by defendant in this instance).
Show all results for "Cosmetic Products"
Cosmetic products (including hair and beauty products) are generally either consumer oriented
or applied professionally on a commercial basis. The distinction is sometimes vague but in general, commercial
products tend to have greater toxic potential due to increased concentrations of
certain chemicals and additives. For example, although "home permanent"
chemicals are far more diluted than those applied commercially by hair-care
professionals, both have toxic immunological potential. Similarly, some cosmetic products for consumers can
induce a wide range of toxicological reactions depending on the chemical compounds
present, individual sensitivities, etc.
It should be noted that with few exceptions, the Federal Food, Drug, and Cosmetic
Act does not require cosmetic products and ingredients to be approved by the FDA before
they go on the market. Rather, the FDA has consistently advised manufacturers to use
"whatever testing is necessary" to ensure the safety of their products
and ingredients. This methodology constitutes a somewhat loose set of standards
but regulatory initiatives are increasing. The U.S. EPA recently issued guidance1 concerning the safety of nanomaterials in cosmetic
products which can have chemical, physical, biological and toxicological properties
quite different from their larger counterparts. Thus, cosmetic products constitute
a class of consumer goods in which the technology is evolving exponentially.
In keeping with U.S. FDA regulations, TCAS evaluates cosmetics and consumer
products by relying upon standardized testing with internationally-recognized procedures
known as the "Globally Harmonized System of Classification and Labeling
of Chemicals" (GHS). Additionally, TCAS keeps current and reliant
upon the epidemiological and toxicological literature with respect to this complex class
of products. This is a necessary prerequisite to producing an objective, scientifically
credible assessment. TCAS has conducted numerous such assessments and provided
expert testimony concerning many cosmetic, hair and beauty products. Please
contact our office for additional information.
Show all results for "Herbal Products"
Herbal products are most often marketed in the U.S. as "dietary supplements"
in the form of tablets, capsules, powders, teas, extracts and fresh or dried plants.
These can be used for scent, flavor, therapeutic or other purposes. As cited by
the National Institute of Health's Center for Complementary and Alternative Medicine,
"Many people believe that products labeled 'natural' are always safe and
good for them. This is not necessarily true. Herbal medicines do not have to go
through the testing that drugs do. Some herbs (such as comfrey and ephedra) can
cause serious harm. Additionally, some herbs can interact with prescription and/or
over-the-counter medicines." 2
The fact that herbal products are not subjected to the rigorous testing of conventional
pharmaceuticals and the fact that the availability of certain products varies widely
by geographical region has a significant impact on conducting a toxicological assessment.
For example, TCAS has had extensive experience assessing the adverse health
effects of a herbal product banned in Europe and much of the rest of the world,
but still available for purchase in the U.S. This product is strongly associated
with fulminent hepatic (liver) failure and is documented with numerous studies in
the peer-reviewed toxicological literature. However, there are no formal U.S. regulatory
standards covering this particular product as it is classified as a "dietary
Thus, when assessing the toxicological impacts of herbal products, the expert toxicologist
must draw upon a comparatively-smaller base of information while simultaneously
considering multiple exposure factors. A typical case involves a process of investigative
research into reliable case history studies as well as peer-reviewed studies, on-going
epidemiological research and the available body of toxicological literature to produce
a scientifically credible and reliable assessment. Please contact our
office for additional information.
Pesticides and Poison Baits
Show all results for "Pesticides and Poison Baits"
Poison baits are a class of pesticides most commonly used to control rodents and
varmints. Although many products have been on the market for decades, new products
are regularly emerging and regulations governing their use are becoming more stringent.
For example, U.S. EPA recently took action3 to remove
12 D-Con™ brand mouse and rat poison products from the consumer market as they
failed to comply with required safety measures to protect children, pets and wildlife
from accidental exposure to rodent baits. The active ingredients (brodifacoum, bromadiolone,
difethialone and difenacoum) are very toxic and persistent and have been found widely
in non-targeted wildlife.4 Baits containing chlorophacinone,
diphacinone, warfarin, cholecalciferol and bromethalin are less toxic, but any rodent
bait has the potential to harm non-targeted wildlife. Recent regulatory changes imposed
on poison bait products containing persistent pesticide ingredients (previously
marketed to residential consumers) are now available only for commercial use by
TCAS has significant experience in assessing and solving homicide matters
and assessing the toxic health effects of pesticides and poison baits, as well
as providing written reports and expert testimony in accordance with federal, state
and local regulations. A recent pesticide exposure case in our
toxicological case studies summarizes the events relating to the death
of a man with a history of seizure disorder who was fatally exposed to pesticides
in his unventilated basement apartment. (Dr. Sawyer was retained by plaintiff in
Notes and References
- U.S. EPA, "Safety of Nanomaterials in Cosmetic Products," April 2012
- U.S. National Library of Medicine, "Herbal Medicine," National Institute of Health, 2013
- U.S. EPA, "Rodenticide Products for Consumers," March, 2013
- California Department of Fish and Wildlife, "Rodenticide Baits," Office of Communications, 2013
- TCAS report demonstrative (redacted), image sources noted below
- Cleaning product photo courtesy freepik.com
- Cosmetic photo by LotusHead
- Natural remedy thumbnail by Tinpalace
- Poison bait U.S. Forest Service, Silvicultural Methods in Relation to Selected Wildlife Species