- 6.1 What characteristics increase the probability of confusing a product with food?
- 6.2 What are the most common effects observed when those products are ingested?
- 6.3 What product ingredients could harm health when swallowed?
- 6.4 What circumstances increase the risk of serious poisoning?
6.1 What characteristics increase the probability of confusing a product with food?
The SCCS opinion states:
This opinion assesses only the risk from accidental ingestion of food-resembling or child- appealing cosmetic and liquid household products by consumers, specifically children and the elderly.
1. What are the elements of a product which are likely to increase the probability for confusion with foodstuffs or that make a product more child-appealing? If possible, a ranking of such elements should be given.
(a) Elements of CPRF
Consumer products resembling food (CPRF) are a sub-set of consumer products, such as cosmetics and liquid household products, which possess a colour, shape, packaging, imagery, taste, flavour or other characteristic that resembles food and could be accidentally ingested by children or the elderly. Although examples of food-resembling characteristics of products can be given, there are no studies that tested directly whether the likelihood of poisoning or ingestion with regard to cosmetics and liquid household products increases, given that the characteristics are present. Nevertheless, the above-mentioned characteristics can serve as proxies to evaluate whether products are more or less food- resembling, until more specific data are available.
(b) Elements of CAP
Child-appealing products (CAP) can also be defined as a sub-set of normal consumer products that are appealing to children by design or presentation and may therefore be consumed by children by mistake. There is an overlap between CPRF and CAP (e.g. some consumer products resembling food may be particularly child-appealing), but the two categories are not identical. It should be noted, however, that the appeal of a product for children cannot be defined objectively, but only in relative terms (this is different to CPRF, where it is possible to describe the extent to which a product imitates a food by comparing it to that food). Children can be attracted to nearly anything within their reach, depending on the number and type of other attractors in their environment, their situational and dispositional inclination to explore, and many other factors.
Research shows that children have a preference for sweet, fatty and fruity tastes and odours. Children also prefer product packages that display familiar cartoon or other characters from TV. There is no evidence for stable colour preferences in children up to 5 years of age, and results on product colour preferences in children generally seem to be highly dependent on the type of product and choice set of colours used. To the best of our knowledge, there is also no evidence that the shape or consistency of cosmetics and liquid household products make such a product relatively more child-appealing, or that the presence of product labels or warnings will have an effect on children up to 6 years old.
The use of bittering agents as “aversives” has been advocated as a possible method of preventing toxic ingestions by children. Some controlled studies have shown that this approach may be useful, but in real situations its effectiveness seems to be more questionable.
These characteristics of CAP were mainly identified in studies about children’s food preferences. There are no studies, for any of the characteristics mentioned, that tested children’s preferences or the likelihood of ingestion with regard to cosmetics and liquid household products. Thus, to the best of our knowledge, there are no data available that show directly that, for instance, cosmetics with a sweet smell, strong colours or cartoon characters displayed on the packaging are ingested more often than others. Nevertheless, the above mentioned characteristics can serve as proxies to evaluate whether products are more or less child-appealing, until more specific data are available. In particular, more systematic research should be carried out on children’s reactions to non-food products to better understand how children may react in front of a package and label design.
A ranking of the characteristics is not possible, given that there are no data available that allows for a direct comparison of the impact of the features on the risk of poisoning or ingesting the product.
However, in order to be able to better compare products and product designs with regard to their food-resembling or child-appealing properties, a simple summary score for each of the characteristics mentioned above could be obtained. A product that has a food-resembling shape, colour and smell, with a packaging that displays food-imagery, is probably more likely to be mistaken for a food than one that has only a food-resembling colour. Similarly, a product that displays cartoon characters on the package, tastes and smells sweet is probably more child-appealing than a product that just tastes sweet. However, given the limited data basis, and given that the appeal of a product for children cannot be defined objectively, both CPRF and CAP scores would have to be interpreted cautiously and only have heuristic value until more systematic research is available.
6.2 What are the most common effects observed when those products are ingested?
The SCCS opinion states:
4. What are the most common adverse health effects observed in humans if such products are ingested?
The majority of accidental ingestions reported in children were not serious (death rate reported in around 0.026% of the intoxicated children). For example, in the UK, less than 5% of all exposures to household chemical consumer products resulted in symptoms.
Only limited data are available on adverse health effects of accidental ingestion of CPRF and CAP. On the basis of the available data from poison centres on the adverse health effects by accidental ingestion of cosmetics and liquid household products, it has been observed that initial symptoms reported by parents, whose children were admitted a paediatric emergency care unit, were mainly gastrointestinal (vomiting, abdominal pain,) or neurological (impaired consciousness, hypotonia, ataxia, seizure), although cutaneous (rash), respiratory (dyspnoea, cough) or dysphagia were also reported in some children. Aspiration of vomited material may damage the lung tissue, particularly the alveoli due to the acidity of the stomach content. Such material can, on its own, cause inflammation of the lung tissue, but this is usually transient. However, if the vomited material contains accidentally ingested xenobiotics, such as surfactants and emulsifiers, chemical pneumonia may develop as a result of further inflammation and damage of the lung tissue. This can also be induced by aromatic oils as their low viscosity increases the chance of inhalation rather than swallowing. Chemical pneumonia is a particular problem with children and the elderly and has resulted in deaths. Exposure to corrosive substances may also be of concern since minimal ingestion can cause severe oesophagogastric burns.
Similar effects are seen in the elderly but sometimes these are exacerbated by underlying health status (see Annex II
For children, no fatalities are reported for CPRF and CAP ingestions. In addition, only rare, adverse severe health effects as a result of CPRF and CAP ingestions are reported. These effects are the exacerbation of the symptoms listed above, or consequences of the treatment used. For the elderly, there are a few case histories reported as either serious adverse health effects or fatalities.
Since many accidental ingestions cause mild symptoms of gastric irritation, it is thought that there is substantial under-recording and under-reporting of these incidents.
Additional recording from poison centres, describing in a systematic way circumstances leading to accidental ingestion of household products and cosmetics, should be useful for evaluating future trends and the impact of management measures.
This opinion addresses liquid products ingested by accident, other routes of exposure such as inhalation and skin contact, or exposure to solid materials such as toys or decorative products, are not considered.
6.3 What product ingredients could harm health when swallowed?
The SCCS opinion states:
2. What are the inherent properties and attributes of chemical consumer products that may cause or contribute to adverse health effects upon ingestion?
The common household cleaning products, most frequently cited in poisonings, are dishwashing and laundry detergents, toilet cleaners and bleaches. Sodium hypochlorite, sodium hydroxide, alcohols and hydrogen peroxide were the substances most frequently cited in poisonings.
Injury following ingestion is dependent on both the concentration and the pH of the agent. Tissue contact time, which is related to the physical corrosive properties, is also a determinant in the extent of injury. The corrosivity is primarily determined by the pH of the product formulation. In addition, physical state (liquid/solid), viscosity, and concentration are also important.
The most harmful ingredients are:
- Corrosive substances such as acetic acid, nitric acid, sulphuric acid, hydrochloric acid, sodium bisulphate, sodium hypochlorite and sodium hydroxide.
- Surfactant (depending on types and concentration).
- Alcohols and glycols such as ethanol, isopropanol and butyl glycol.
- Essential oils such as pine oil, wintergreen oil and camphor.
The hazardous properties of the formulations are:
- pH: Single acute exposure to pH >9 or <3. Liquids with a pH of less than 2 are considered to be extremely corrosive. Highly alkaline products, like liquid drain cleaners, also hold a high risk for injury.
- Viscosity: When the product is acidic and the viscosity low, it may cause or enhance damage to the gastro-intestinal tract. When the product is alkaline and the viscosity high, regurgitation increases the chances of lung damage by aspiration due to foaming potential.
There is uncertainty regarding the acute oral toxicity of mixtures of other ingredients (e.g. colorants, polymers, plasticizers). Many of these products, regardless of the acidity and viscosity, may cause gastric upset, feelings of nausea and vomiting effects after accidental ingestion.
6.4 What circumstances increase the risk of serious poisoning?
The SCCS opinion states:
3. What are the circumstances under which exposure to food-resembling or child-appealing chemical consumer products will pose a serious risk to the health and safety of consumers, in particular to children and elderly people, taking into account e.g. volume ingested, taste of the product etc.? In which circumstances may such a risk materialise?
Research on the possible causes for accidental ingestions and poisonings in children between 6 months and 6 years of age is limited, and there are no specific data on CPRF and CAP. However, the available research suggests that three main factors are likely to contribute to increased exposure:
1) Low socio-economic status: The variable most frequently correlated with poisonings is socio-economic status (SES). There are many variables related to SES, for instance family income, education, employment status, stress at home, absence of parent and social support. Low SES is a strong predictor of observed home hazards, unsafe childcare practices, fatal unintentional injuries and, to a lesser extent, of nonfatal injuries. Unemployment and homes needing repair, in particular, appear to be risk factors for unintentional injuries of children at home. However, although SES is the best studied predictor of different injury risks, even affluent families do not undertake safety practices all the time, and most of the variation in the number of safety practices, for instance, is not explained by SES. Thus, further research is needed in this area.
2) Inadequate supervision: Several studies showed that reduced supervision of children may increase the risk of exposure and subsequent accidental poisoning. However, direct evidence linking supervision to child injury is scarce and more research is needed to assess the independent contribution of this factor.
3) Low risk perception: Single studies suggest that low parental risk perception may increase exposure to poisoning hazards in the home, but evidence on the role of this factor is mixed and more research is needed.
Research on the possible causes for accidental ingestions and poisonings in the elderly is scarce. Factors such as reduced olfactory and gustatory perceptions, impaired vision, disorientation or reduced availability of supervision or help are discussed as factors that are likely to increase the risk for accidental ingestions and poisonings, but more research is needed, and there are no specific data on CPRF.
Available information from poisoning centres concerning accidental ingestion of cosmetics and liquid household products indicate that in most cases such ingestions are not serious and the effects are transient. Rare circumstances leading to serious outcomes include large amounts of a product being ingested, toxicity of the product and vulnerable members of the population (elderly and children). However, the limited data on accidental ingestion of CPRF and CAP indicate that there are only rare incidents of serious health risks.
12. MINORITY OPINION
13. COMMENTS RECEIVED DURING THE PUBLIC CONSULTATION
A public consultation on this opinion was opened on the website of the EU non-food Scientific Committees from 20 December 2010 to 11 February 2011.
In total, 7 contributions were received from public authorities and other stakeholders. Each submission was reviewed by the Working Group and appropriate modifications were introduced into the opinion to take account of relevant comments. The literature has been updated with relevant publications. The opinion, however, remained essentially unchanged.
Detailed explanations of the way the comments received were treated by the SCCS are provided in the explanatory notes published together with this opinion.