NCHR Comments on FDA Draft Guidance for Lead in Cosmetics

February 21, 2017. Although we support the FDA’s efforts to provide a recommended maximum level of lead as in impurity in cosmetic lip products and externally applied cosmetics, we reject the FDA’s rationale for the maximum level of 10 parts per million of lead in these products.

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NCHR Comments on Manufacturer Communications on Use of Off-Label Medical Products

January 6, 2017. Based on research showing the clear risks and relatively modest benefits to patients, and the even greater costs to public health when there is inadequate evidence to make informed decisions, we strongly oppose allowing companies to promote medical products for off-label uses. These views are based on evidence and have been confirmed by speaking with hundreds of patients harmed by medical products that they did not know were being used off label.

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