Coal Tar and California Proposition 65

Coal Tar and California Proposition 65

If you don’t live in California, you may not be familiar with the state’s Proposition (Prop) 65. If you are a Californian, no doubt you see Prop 65 warnings several times a day. From coffee shops to theme parks, luggage to nuts, to coal tar skin cream, the evidence of Prop 65 is omnipresent in the state.

Essentially, Prop 65 is a rule that was devised in 1986 by the California Office of Environmental Health Hazard Assessment (OEHHA) to disclose the risks of potentially harmful chemicals used in commercially available products and facilities. By law, products that contain chemicals on the Prop 65 list, and are sold or available in California, must visibly display a warning notifying consumers of potential health risks.

For example, at all entrances to Disneyland, signs are prominently posted that read:
“The Disneyland Resort contains chemicals known to the state of California to cause cancer and birth defects or other reproductive harm. Proposition 65, California Health & Safety Code Section 25249.6 et seq.”

Coal tar—an active ingredient in shampoos and creams to treat dandruff, psoriasis, and seborrheic dermatitis—is on the Prop 65 list of chemicals that pose a potential health risk. As a result, any product that uses any amount of coal tar as an ingredient must disclose a warning or the company that manufactures it is subject to legal and financial ramifications.

Understanding Coal Tar Psoriasis Research

In large doses, significantly more than the amount used to treat psoriasis, such as in an industrial setting, coal tar exposure can be carcinogenic. This is why you will see language like this on MG217 coal tar products: “This product contains coal tar, a product known in the state of California to cause cancer.”

Beyond the law, it is imperative that skin care product makers communicate with their customers about any risks associated with the ingredients they use. It is up to the consumer to make informed buying choices based on their personal assessment of those risks. This can be challenging as it forces the consumer to make sense of large amounts of data and research.

Complicating the situation, OEHAA continues to refine Prop 65. In fact, Prop 65 has been in the news in recent months after a new amendment was passed changing how and when businesses need to provide California consumers with warning information. And, according to the The National Law Review, “The OEHHA has established ‘no significant risk levels’ (NSRLs) for certain chemicals, meaning that if a product has a certain level or less of a particular chemical, no warning is required.” California consumers will likely see the results of these changes more broadly in 2019.

Fortunately, there are a number of accredited and scientific institutions that have analyzed and continue to study coal tar. For example, the American Academy of Dermatology is an excellent resource that shares information and news about coal tar. The Academy reports, “To date, studies fail to show an increased risk of cancer in people who use coal tar to treat psoriasis.” Other useful resources include the U.S. Food & Drug Administration (FDA) and the US National Library of Medicine National Institutes of Health.

Likewise, The National Psoriasis Foundation addresses the Prop 65 issue equivalently, as follows:
“Studies show some of the chemicals in coal tar may cause cancer, but only in very high concentrations, such as in what is used in industrial paving. Anyone using coal tar regularly should follow a regular skin cancer check-up schedule. California requires over-the-counter coal tar shampoos, lotions, and creams that contain more than 0.5 percent coal tar to be labeled with cancer warnings. However, the FDA maintains that over-the-counter products with coal tar concentrations between 0.5 percent and 5 percent are safe and effective for psoriasis, and there is no scientific evidence that the tar in over-the-counter products is carcinogenic.”

You might ask why companies use coal tar in products like MG217. The FDA has approved – through exhaustive testing over several decades – only two chemicals as both safe and effective for topical over-the-counter treatment of psoriasis: coal tar at 0.5 to 5.0 percent and salicylic acid at 1.8 to 3.0 percent. The short answer is, they are proven to work safely, over a long treatment period, without the supervision of a doctor.

If you have any questions about MG217 and how coal tar is formulated to fight psoriasis, please contact us. We look forward to continuing the discussion.