The estimated dietary exposure to aluminium was based on national food consumption surveys for various age groups and the aluminium concentration in food on the Norwegian market.

The additional contribution from the use of cosmetics was estimated as the systemic exposure dose (SED) from topical application of cosmetic products in different age groups.

Lipstick/lip gloss, antiperspirants and a few brands of whitening toothpaste were considered the relevant sources of Al through cosmetics.

For estimations of exposure to Al in the Norwegian population from cosmetics, occurrence data from cosmetic products on the Norwegian market were used. Dermal absorption of Al was based on the on skin penetration data from a human in vitro study by Pineau et al. (2012).

In its opinion in 2014, SCCS concluded for studies on dermal /percutaneous absorption that

“The available studies are of poor quality and have not been carried out according to the current requirements. In the absence of any better data to estimate skin penetration of aluminium, the SCCS considers that aluminium absorption after dermal exposure is still very poorly understood. A conclusion on internal exposure to aluminium following cosmetic use cannot be drawn”.

This statement also included the study by Pineau et al. (2012) used by VKM in their risk assessment.

In VKM’s experience with risk assessments there is often a lack of good quality data or even lack of data at all, to perform one or more steps in the exposure or hazard characterizations.

Whether the data are of sufficient quality to perform a risk assessment or not is a question to be discussed and decided upon in each case. In this assessment of exposure to aluminium from cosmetics,

VKM decided that the study by Pineau et al. (2012) was of sufficient quality. Further, in VKM’s view, it would be more useful to the risk managers and provide a better consumer protection to err on the side of caution than not to perform a risk assessment at all because of lack of data on skin absorption fulfilling all of SCCS’s requirements.

At any time point the best available data should be used in risk assessments. If regarded necessary, risk assessments should be repeated when better data becomes available.

VKM welcomes any new high quality data that can provide better estimates of human skin absorption of Al.