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This article was downloaded by: [Murphy, Tom]On: 2 December 2009Access details: Access Details: [subscription number 917025991]Publisher Taylor & FrancisInforma Ltd Registered in England and Wales Registered Number: 1072954 Registered office: Mortimer House, 37-41 Mortimer Street, London W1T 3JH, UK Human and Ecological Risk Assessment: An International Journal Publication details, including instructions for authors and subscription information: Mercury Contamination of Skin Whiteners in Cambodia Thomas Murphy a; Darell G. Slotton b; Kim Irvine a; Kom Sukontason c; Charles R. Goldman ba Department of Geography/Planning, Buffalo State, State University of New York, Buffalo, NY, USA bDepartment of Environmental Science and Policy, University of California, Davis, CA, USA c Facultyof Medicine, Chiang Mai University, Chiang Mai, Thailand Online publication date: 19 November 2009 To cite this Article Murphy, Thomas, Slotton, Darell G., Irvine, Kim, Sukontason, Kom and Goldman, Charles R.(2009) 'Mercury Contamination of Skin Whiteners in Cambodia', Human and Ecological Risk Assessment: An International Journal, 15: 6, 1286 — 1303To link to this Article: DOI: 10.1080/10807030903306877URL: This article may be used for research, teaching and private study purposes. Any substantial orsystematic reproduction, re-distribution, re-selling, loan or sub-licensing, systematic supply ordistribution in any form to anyone is expressly forbidden.
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Human and Ecological Risk Assessment, 15: 1286–1303, 2009Copyright C Taylor & Francis Group, LLCISSN: 1080-7039 print / 1549-7860 onlineDOI: 10.1080/10807030903306877 Mercury Contamination of Skin Whiteners
in Cambodia

Thomas Murphy,1 Darell G. Slotton,2 Kim Irvine,3 Kom Sukontason,4
and Charles R. Goldman5
1Department of Geography/Planning, Buffalo State, State University of New York,
Buffalo, NY, USA; 2Department of Environmental Science and Policy, University of
California, Davis, CA, USA; 3Department of Geography/Planning, Buffalo State,
State University of New York, Buffalo, NY, USA; 4Faculty of Medicine, Chiang Mai
University, Chiang Mai, Thailand; 5Department of Environmental Science and
Policy, University of California, Davis, CA, USA
ABSTRACT
Eleven of 41 brands of skin whiteners that were collected in Phnom Penh, Cambodia, and processed with a screening kit contained more than 2000 µg/g mer-cury. Risk analysis indicates that these 11 brands were toxic. Nine of 19 of these skinwhiteners analyzed with cold vapor atomic absorption (CVAA) spectrophotometryexceeded Association of Southeast Asian Nations (ASEAN) guidelines for cosmeticgood manufacturing practice limit on mercury of 1 µg/g. The most contaminatedwhitener analyzed by CVAA had 12,590 µg/g mercury. The mercury-containingproducts were labeled as produced in Thailand, China, Taiwan, Vietnam, the UnitedStates, and an unidentified country. Eight other products (antifungal, steroids, andantibiotics) were sold as additives to be mixed into whitener concoctions. In the 19samples analyzed with CVAA, there was a significant association between the mer-cury content and a label “for export only.” Labeling of sampled products varied from Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 detailed to slight, with none containing Khmer instructions. Variability in mercurycontent of some products appeared to reflect copying of brand names with verysimilar packaging.
Key Words:
women, export, trade, cosmetics, mercury, skin whitener.
INTRODUCTION
The global concern over mercury toxicity has fueled new legislation by every major government to control the trade in mercury. Recent projections of exten-sive monitoring predict a doubling of mercury concentrations in the North Pacific Received 22 September 2008; revised manuscript accepted 5 May 2009.
Address correspondence to Thomas Murphy, Department of Geography/Planning, Buffalo State, State University of New York, 1300 Elmwood Ave., Buffalo, NY 14222, USA. E-mail:tompatmurphy@gmail.com Mercury Contamination of Skin Whiteners in Cambodia
Ocean from 1995 by 2050 (Sunderland et al. 2009). Combustion of fossil fuels isthe greatest anthropogenic source of mercury. Important local sources of mercurycontamination have often been the pulp and paper, battery, and mining industries(Parsons and Percival 2005). Direct mercury toxicity has also come from a variety ofunexpected sources such as cosmetics and folk medicine (Glenn 2008).
One of the first cases of mercury contamination in Cambodia was associated with an illegal shipment from Taiwan of 2700 metric tons of industrial wastes containinga high concentration of inorganic mercury (Hess and Frumkin 2000, p. 331). Theauthors stated that “at least six deaths and hundreds of injuries have been associatedwith this incident.” Hess and Frumkin stressed the importance of prevention andpreparedness in containing emergencies in developing countries.
Cambodia also has a growing number of artisanal miners discharging mercury (Murphy et al. 2009). It is difficult for a developing country to stop poor people fromusing mercury to extract gold. Organizations like the United Nations DevelopmentProgramme (UNDP) have tried to control the sale of mercury and some progress isbeing made. The UNDP also has encouraged use of retorts to recycle mercury andif the price of mercury were higher, miners would more readily use retorts (Spiegelet al. 2006; Veiga et al. 2006).
Agusa et al. (2005) examined levels of mercury in hair samples from Cambodia and found high levels from individuals in Phnom Penh and nearby Kean Svay.
Phnom Penh is the capital and largest city in Cambodia. Although Kean Svay stillhas rural elements, the rapid growth of Phnom Penh has spilled into Kean Svay,which is now basically a satellite district of Phnom Penh. Agusa et al. (2005) found10 of 60 hair samples from urban areas had more than 10 µg/g of mercury andthree of 60 samples in the urban settings had extreme levels of mercury (190, 70,and 60 µg/g). There was a gender-related trend to higher levels of mercury in KeanSvay but no obvious trend in rural samples. The 34 hair samples from other moreremote villages did not contain more than 10 µg/g mercury. Fish analysis by Agusaet al. (2005) indicated that fish could not be the source of mercury contamination inPhnom Penh. The mean mercury concentration of 99 ng/g found in 160 fish samplesfrom the Mekong River by Murphy et al. (2009) would not require any restriction of Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 fish consumption in Canada (http://www.ene.gov.on.ca/cons/590b12 intro.pdf)and could not produce the extremes of mercury found by Agusa et al. in hairsamples. Agusa et al. also dismissed the mercury wastes from Taiwan as the cause ofcontamination in Phnom Penh and they were unable to identify the source.
Assessments of mercury associated primarily with gold mining by Murphy et al. (2006) differed from those of Agusa et al. (2005) in a few ways. Murphy et al.
(2006) processed 38 hair samples from men in Phnom Penh and found none withmore than 10 µg/g mercury. Nine of these men were goldsmiths; no women weregoldsmiths. The other 29 men were methylamphetamine addicts; female addictswere not available. In some locations, mercury is used to make this drug but notapparently in Phnom Penh. Second, none of 49 women Murphy sampled in remotevillages of northeast Cambodia had >10 µg/g of mercury in their hair. Third, innortheast Cambodia the eight hair samples (of 119) containing >10 µg/g wereassociated with gold miners working with mercury. The results of Agusa’s team andMurphy’s team suggest there was a regional and gender-linked source of mercuryindependent of gold processing. The most commonly reported source of mercury Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 T. Murphy et al.
contamination that is strongly gender-linked and urban is mercury in skin whiteners(Glenn 2008).
Mercury is one of the ingredients in skin whiteners used to block production of melanin. Al-Saleh et al. (2004) demonstrated with mice that mercury in a skinwhitener was readily absorbed through the skin as evidenced by its accumulationin the brain, kidney, and liver tissues with the kidney having the highest mercurycontent. Women from many parts of the world often use these whiteners to looklike a richer class or to satisfy someone’s perception of beauty (Rondilla et al. 2007;Glenn 2008). Few men use these products. In one survey in Texas, near the Mexicanborder, the users were 96% women (Weldon et al. 2000). In a clinical review in HongKong 99% of respondents using skin creams were women (Sin and Tsang 2003). Inanother survey in Nigeria 72.4% of users were women (Adebajo 2002). Althoughthere has been no quantification of skin color, it was apparent that women in theremote Cambodian villages were much darker than women in and near PhnomPenh. Potential explanations for the colour difference include a different geneticpopulation in the city, more exposure to sun in the country or skin whiteners thatare readily available in Phnom Penh and Kean Svay but not available in the remotevillages we sampled.
The purpose of this article was to test the hypothesis that women in Phnom Penh are using skin whiteners contaminated with mercury.
In July 2007, 19 skin whiteners were purchased from Boeng Keng Kong and Cen- tral (Thmei) markets in Phnom Penh. Samples collected in 2007 were then analyzedin the United States at the University of California, Davis, Department of Environ-mental Science and Policy. Samples were analyzed for total mercury by standardcold vapor atomic absorption (CVAA) spectrophotometry, using a dedicated PerkinElmer Flow Injection Mercury System (FIMS) with an AS-90 autosampler, followingdigestion under pressure at 95◦C in a mixture of concentrated nitric and sulfuric Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 Analytical quality assurance/quality control (QA/QC) samples were subjected to the same acid digestion, physical and chemical treatment, and detection as analyti-cal samples and included: blanks, aqueous standards, continuing control standards,standard reference materials with certified levels of mercury, laboratory split sam-ples, matrix spike samples, and matrix spike duplicates. Performance was trackedwith control charts. QA/QC results were all within control limits. However, due tothe extremely high mercury levels of some of the samples, re-analysis with smallersample aliquots was necessary to bring those sample results into the linear range ofthe detection unit.
In June 2008, 17 skin whiteners were collected in the O’Russei market in Phnom Penh. In December 2008, 24 skin whiteners were purchased from Boeng KengKong, Central, and Russian (Toul Tom Pong) markets in Phnom Penh. In April2009, two replicates of whiteners known to have high mercury levels were collectedfrom both Central and Boeng Keng Kong markets. The products of these fourmarkets are representative of the beauty supplies used by most Khmer woman but Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 Mercury Contamination of Skin Whiteners in Cambodia
not of the more expensive products available in some shops that are not affordableto most Khmer women. The samples collected in 2008 and 2009 were analyzedwith a less precise but potentially more widely accessible new mercury screening kitdeveloped by the Department of Medical Science (DMSC) of Thailand and marketedby JSP Pharmaceutical Manufactory (Thailand) Co. Ltd. The ASEAN (Associationof Southeast Asian Nations) suggested in January 2008 to use screening kits for skinwhiteners containing mercury (ASEAN 2009). The distributor reports that thesekits detect mercury above a threshold level of 1500 µg/g. The method involvesformation of ammonia that then reacts in the head space of a test tube with litmuspaper. There is an obvious gradation in color development of the litmus paper.
We used the results of the 19 samples processed by CVAA to segregate samples intothree classes: low mercury (brown), >2000 µg/g of mercury but less than 8000 µg/gof mercury (green), and >8000 µg/g of mercury (blue). Note that although thesupplier of kits states that the detection limit is 1500 µg/g, they supplied no standardsor colour scale for calibration and we chose to use the results of our CVAA analysisfor calibration. The supplier currently only provides the method in Thai, but atranslation is available from this article’s senior author.
First attempts by the senior author to purchase skin whiteners resulted in hesita- tions, higher prices, and a different communication. In 2007, samples were collectedby a young Khmer lady posing as if she was about to use them. In 2008, some vendorssaid they were afraid to sell our Khmer lady “customer” copied products and wouldonly sell the first-grade products. At these times, we did not purchase the first-gradeproducts but we cannot know if other vendors suspected our intentions and only soldlegal products. Limited reviews of similar products in the Mahboonkrong (MBK)shopping center in Bangkok, Thailand, were restricted by vendors not cooperatingwith the senior author.
Mercury in Samples Collected in 2007
Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 Nine of 19 sampled skin creams collected in Phnom Penh contained mercury exceeding ASEAN Guidelines for Cosmetic Good Manufacturing Practice (2008) of1 µg/g. The U.S. Food and Drug Administration’s (USFDA’s) limit on mercury incosmetics is the same (USFDA 2000). Five of the 19 skin creams contained more than2000 µg/g of mercury (Table 1). There was a significant trend among the productsthat were labeled “for export only.” A Mann-Whitney U Test of the concentrationranked creams indicated that the creams that were marked “for export only” weresignificantly (α = 0.03) more contaminated with mercury than those without thisdistinction. The most contaminated cream contained 12,590 µg/g of mercury. Thatparticular cream was labeled from mainland China, but products apparently fromThailand and Vietnam also contained very high levels of mercury.
Mercury in Samples Collected in 2008 and 2009
A mercury screening kit was used to detect levels greater than a threshold of 2000 µg/g in 11 of 41 brands of skin whiteners (Table 2). Agreement between the Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 T. Murphy et al.
Skin cream samples from Phnom Penh, 2007, analyzed by CVAA.
ASEAN guidelines for cosmetic good manufacturing practice limit on mercury incosmetics is 1 µg/g.
(http://www.bfad.gov.ph/ACCSQ%20COSMETIC/converted%20files/Appendix%20VICosmeticGMP.pdf).
U.S. Food and Drug Administration limit on mercury in cosmetics is also 1 µg/g(http://www.cfsan.fda.gov/∼dms/cos-210.html).
results of CVAA spectrophotometry and the kit was excellent in all 19 samples thatcould be compared. Moreover duplication of subsamples was consistent. Eight ofthe 11 brands contaminated with more than 2000 µg/g mercury were labeled “forexport only.” Six of these eight contaminated whiteners contained >8000 µg/g Hg.
Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 Only 3 of 30 brands without the label “for export only” had detectable mercurywith the screening kit. Comparison of the dataset with the label “for export only”and the dataset without this label with a Kolmogorov-Smirnov test indicates thatthe differences are highly significant (p = .002). There was some inconsistency inthe presence of mercury in replicated products (Table 3). Ideally statistical analysiswould be done with a larger dataset that also measured other illegal additives such ashydroquinone and retinoic acid. However the current analysis does suggest covertproduction and exporting. International trade in these products should be evaluatedusing government officers. In December 2008, a small review of skin whiteners inthe Mahboonkrong (MBK) shopping center in Bangkok identified four Thai skinwhiteners marked “for export only.” The Thai government has been enforcingtheir new regulations for mercury in skin whiteners but the vendors were veryuncooperative.
Since the screening kit is only able to detect mercury in samples with more than 1500 µg/g of mercury, we first used the results of CVAA analysis to pick five sets of Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 Mercury Contamination of Skin Whiteners in Cambodia
Skin whiteners from Phnom Penh, 2008, analyzed by screening kit.
Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 Hg is µg/g, Export* = for export only, Price in Riels and 4000 Riels = 1 USD, Bar is barcode, Size in grams.
Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 T. Murphy et al.
# Replicates is number of replicates, # with high Hg is thenumber of replicates with >2000 µg/g Hg.
replicates within the screening kit’s detection limit (Table 3). Using identical splitsof samples collected in 2007, the kit and CVAA results were consistent, indicatingthat the test kits were accurate within the listed range. However, some of the resultsof replicated products collected in 2008 indicated some heterogeneity. In two setsof Thai whiteners (Th1, Th2) processed in triplicate, only the samples collectedin 2007 tested positive for mercury (Th1 >8000 µg/g, Th2 >2000 µg/g). In fourreplicates of Th3, the sample from 2007, and two from 2008 had >2000 µg/gmercury while one from 2008 did not appear to contain elevated mercury. Likewise,in a set of five samples of C1 (the 2007 sample apparently from China with the veryhighest mercury), the sample collected in 2007 had >8000 µg/g mercury, only oneof two collected in 2008 had >2000 µg/g mercury and the two collected in 2009 didnot have detectable mercury. However, four of five samples of V1 (apparently fromVietnam) contained >2000 µg/g Hg.
In the samples collected in 2008, one packaging (T1) looked very much like V1 (Vietnam), but the label claimed it was produced in Taiwan so in 2009 we collectedand processed it in triplicate; all three samples tested as >8000 µg/g mercury. The“American” whitener with high mercury (A2) was also suspicious in that the labelingwas written in weak English. These were the only examples of suspicious labeling Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 that might indicate copies. In a study of medical drugs in this region, packagingof counterfeit drugs was very professional and difficult to distinguish from legalproducts (USAID 2008).
The quality of the labeling of the skin whiteners varied greatly. The only consis- tency was the lack of any Khmer. English is used as a second language, but therewas often too little English on these labels. A few gave detailed warnings of potentialproblems and provided advice on their use. None of the creams collected in 2007reported mercury content. In 2008, one cream said it did not contain mercury andit indeed did not contain detectable levels of mercury. Bar codes were not usedconsistently. There was no relationship between the use of a bar code and mer-cury content. Five of the 16 skin whitening products without bar codes contained >2000 µg/g Hg (31%) and 6 of the 25 skin whitening products with bar codes con-tained >2000 µg/g Hg (24%). Note that some of these inexpensive creams likelyalso contained hydroquinone or retinoic acid (Farrell 2007), other toxic whiteners,but they were not listed on the labels either. These creams were collected fromfour popular public markets. Similar products at the major department stores or Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 Mercury Contamination of Skin Whiteners in Cambodia
boutiques selling mainly to foreigners or richer Khmers were not sampled, but ourresults apply to most Khmers who shop in inexpensive markets.
The skin creams that were purchased were almost always in jars containing 3 to 6 grams. The small size enables the vendors to sell these creams for an average priceof 1990 riel (±1390) or about $0.50 U.S. The modest price makes these creamsaffordable to many women in the city. Mercuric compounds are relatively cheap atabout $24 a kilo (Farrell 2007). Thus the cost of mercury in sample C1 with the mostmercury was less than $0.0014 U.S. The mercury whitening ingredient in these skincreams cost less than 0.4% of the retail price.
Skin Concoction Supplements
It is a common practice in Cambodia to mix different skin whiteners into a personal concoction. In 2007, one product sold as a whitener (C2, Table 1) wasactually an antifungal treatment and only had one word that was not Chinese—“ketoconazole.” In 2008, seven vendors sold us five products containing powerfulsteroids (sometimes containing antibiotics) to mix with skin whiteners to enhancethe whitening effect (Table 4). In 2008, another six vendors sold three productswithout steroids that contained antifungal or antiseptic properties to mix with skinwhiteners (Table 4). The antibiotics and corticosteroids would require a prescrip-tion in many countries. The products with English gave ample warnings such as “themost powerful corticosteroid in combination with the antibiotic Neomycin” andrecommended medical supervision. Some products had very little English. None ofthese products had any labeling in Khmer and it did not seem that most of the ven-dors or customers knew what these non-whitening products were. They respondedto word-of-mouth advice that these products should be added to concoctions to getbetter whitening.
DISCUSSION
To manage this mercury problem in Cambodia requires an understanding of the Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 toxicity of skin creams, the potential for control of these products in Cambodia,and how international efforts might mitigate the abuse. The evidence for mercurytoxicity from use of some skin whiteners is comprehensive. Weldon et al. (2000, p.
17) reported on users of a skin cream with elevated mercury showing the followingsymptoms; “fatigue (67%), nervousness and/or irritability (63%), severe headaches(61%), insomnia (51%), memory loss (44%), loss of strength in legs (44%), tinglingor burning sensations (39%), tremors or shaking of the hands (38%), depression(31%), and a metallic taste in the mouth (20%).” The World Health Organiza-tion (WHO) (2003) reviewed publications on skin creams with elevated mercuryshowing nephrotic syndrome or impaired renal function. Counter and Buchanan(2004) expressed their concerns that pregnant women who use skin creams withmercury could cause neurological, nephrological, and dermatological damage intheir fetuses.
In general, renal and nervous system damage is expected from significant expo- sure to inorganic mercury (Clarkson and Magos 2006). WHO (2003) also reviewedother toxicity symptoms from inorganic mercury such as behavioral disorders, Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 Mercury Contamination of Skin Whiteners in Cambodia
irritability, memory disturbances, and suppression of immune system that mightalso apply to skin creams. Psychological evaluations of miners exposed to elementalmercury have potential relevance too. Grum et al. (2004) reviewed emotional andpersonality changes in former mercury miners such as depression, introversion, anda tendency for an interaction with alcohol enhancing depression.
Risk Assessment
Compared to the extensive literature available for risk assessment on oral con- sumption of mercury (primarily in conjunction with eating fish), relatively little dataare available to calculate risk assessment for dermal exposure. The U.S. Environ-mental Protection Agency (USEPA) has published reports on dermal absorption ofmercury from water and soil, but there seems to be no concurrence on the absorp-tion fraction for mercury in soils or skin creams. With respect to dermal absorption,the New Jersey State Department of Environmental Protection states “Additionally,few inorganics, other than cadmium and arsenic, have sufficient data to developreasonable default values” (NJDEP 2008, p. 3).
Mercury and cadmium have the same permeability coefficient for dermal absorp- tion (0.001, USEPA 2001) and although mercury is absorbed more readily orallythan cadmium, a conservative approach for a scoping analysis would be to use 0.001as the dermal adsorption fraction for mercury. However, skin creams are designedto enhance dermal absorption. Many details of skin creams are proprietary, but theU.S. patent office has approved patents based on a “benzoyl peroxide compositionhaving enhanced bioavailability and percutaneous absorption” (Scott et al. 1988, p.
1). Bootleggers of such products start with patent searches and they seem quite effec-tive at their “art.” When lipophilic compounds with the capacity to complex mercuryare added by a producer of a copy-cat whitener using mercury or when mixed witha concoction containing mercury, absorption of mercury is very likely enhanced.
Other uncertainties with copy-cat products or concoctions include the effect of nanoparticles on enhanced absorption of mercury (Little et al. 2007). If nanoparticletechnology were copied from brand-name producers of cosmetics and combined Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 with mercury to enhance whitening, likely nanotechnology would increase mer-cury absorption. Seven vendors sold us five skin cream products containing steroidsincluding corticosteroids and six vendors sold us three products containing antibi-otics and disinfectants to mix with skin whiteners. It is not clear what effect theseingredients in concoctions have on mercury assimilation, but again, these productscontain compounds to help deliver the drugs through the skin and may enhancemercury assimilation. Olumide et al. (2008) observed serious damage to kidney,skin, immune, and endocrine systems and even death as the result of using con-coctions of skin lightening products containing corticosteroids. Mahe et al. (2003)also found that the most serious damage from skin whiteners was associated withpowerful corticosteroids. Until demonstrated otherwise, it is prudent to also con-sider a higher absorption fraction such as has been observed in animals. Friberget al. (1961) and Skog and Wahlberg (1964) observed that 2% to 4.5% of mercurychloride was absorbed through the Guinea Pig skin.
There is uncertainty about the fraction of mercury adsorbed at various doses of mercury, but Iman et al. (2004) who evaluated skin whiteners with 0.316 µg/g and Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 T. Murphy et al.
71063 µg/g stressed “the potential harm of these mercury containing skin-lighteningcreams regardless of their mercury contents especially for women who apply thesecreams frequently or for extended periods.” Afonne et al. (2002) also discoveredthat low dose oral mercury exposure (i.e ., 4 µg/ml) in mice produced necrosisand widening of the golmeruli. In consideration of the uncertainties associated withenhanced dermal absorption as well as an absorption fraction of 0.001 we will alsoevaluate risk with an absorption fraction of 0.03 similar to that absorption reportedin Guinea pigs.
Another uncertainty is the proportion of the body that is treated with skin whiten- ers. Mahe et al. 2003 reported that in their study 92% of African users (n = 425)covered their entire body with whitening cream. A mean total female body surfaceis 16,000 cm2(Bender 1995). It seems from our simple interviews that most Khmerstreat only their face, which has a surface area of about 9% of the whole body or 1440cm2(Sheng et al. 2003). For simplicity of demonstration only facial treatments wereevaluated.
A reference dose is the U.S. Environmental Protection Agency‘s (USEPA’s) maximum acceptable dose of a toxic substance. The reference dermal dose(RfDABS,USEPA 1995) can be calculated by multiplying the oral reference dose(mg/kg-day) (RfDO) by the fraction of contaminant absorbed in the gastrointesti-nal tract (ABSGI) (USEPA 2001). So with mercuric chloride or similar inorganicmercury compounds it becomes: 0.0003 × .07 = 0.000021 mg/kg-d Although many of the skin whiteners recommend applying in the morning andevening, simple interviews indicate that most Khmers only use the cream in theevening so our calculations are based on one application per day. Thus for thosewho followed the instructions on the packaging, we would under represent the doseby 50%. Also if we evaluated a whole body dose, the risk would be substantially Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 greater. The essential parameters to calculate acceptable concentration of mercuryin skin cream (Ccream) are reviewed in Table 5.
= THQ∗RfD∗BW∗AT∗365/d − yr∗106mg/kg With an absorption fraction of 0.001 and a hazard index of 1.0: 1 × 0.000021∗45∗30∗365∗100000/(350∗370∗6.9∗0.001) = 1158 µg/g or with an absorption fraction of 0.03 and a hazard index of 1.0: 1 × 0.000021∗45∗30∗365∗100000/(350∗370∗6.9∗0.03) = 39 µg/g Thus, using the conservative absorption fraction of 0.001 gives a dermal hazard indexof 1158 µg/g; 11 of the creams we sampled exceeded the associated acceptablerisk. However, it is highly likely that some skin creams and concoctions of skintreatments result in a much higher absorption fraction than 0.001 and the acceptableconcentration of mercury in skin whiteners may be closer to 39 µg/g. If we were Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 Mercury Contamination of Skin Whiteners in Cambodia
a Face surface area represents about 9% of the whole body (Sheng et al. 2003) and totalsurface area of female is about 16,000 cm2 (Bender 1995).
b A typical woman uses about 10 ml of whitening cream a day and we assume only the faceis treated (10000/1440) (http://www.alibaba.com/catalog/101274379/Fv4 HelichrysumNight Cream 50ml.html).
to assess whole body treatment or use of these products in children, the estimateapproaches the 1 µg/g standard for skin whiteners set by the U.S. Food and DrugAdministration and the ASEAN.
Comparisons to Existing Medical Reviews
Although mercury in skin creams is clearly capable of causing various medical problems, it is not clear that the concentrations of mercury in these skin creamspurchased in Phnom Penh did cause significant toxicity. Extrapolation of publishedstudies is limited by aspects such as the more extensive medical evaluations weredone with skin creams with more mercury than we detected (i.e ., 60,000 µg/gHg, Barr et al. 1972; 80,000 µg/g Hg, Weldon et al. 2000). Recently, a woman in Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 New York who had used a skin cream with 6000 µg/g mercury (less than the twomost contaminated whiteners in our study), required medical treatment (Heyward2005; Leighton 2005). Also a woman in Hong Kong was reported to have kidneydamage associated with use of skin whitener containing 2000 µg/g mercury (Sooet al. 2003). Studies by Agusa et al. (2007) suggest that mercury toxicity in PhnomPenh is occurring. Agusa et al. (2007) observed that high mercury levels in hair(0.69–190 µg/g dry wt) and blood (5.2–58 µg/l), in Phnom Penh correlated withincreased serum estrone and estradiol levels. Agusa et al. reported in 2005, three of60 hair samples from urban areas in Phnom Penh contained >50 µg/g, which arelevels associated with neuropathy (WHO 1990) or Minamata disease (Harada 1995).
Another seven of their hair samples from urban areas were greater than 10 µg/g,levels associated with neuropsychological dysfunctions in children (Grandjean et al.
1997, Grandjean et al. 1999). It is quite likely that Agusa’s results reflect use of skincreams. Extrapolation of current data is uncertain and the degree of mercury toxicityin Phnom Penh from skin whiteners is not obvious, but clearly more evaluation ofmercury toxicity in Phnom Penh is warranted.
Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 T. Murphy et al.
Ideally actions should attempt to resolve the problem while analyzing it in more detail. Education associated with medical aid has been effective in both developingand advanced countries. Barr et al. (1972) ran medical clinics in Kenya to treatnephrotic syndrome caused by mercury in skin whiteners. The kidneys of half oftheir patients quickly recovered and much of the treatment effect was related toeducating them to stop using skin whiteners. Medical clinics with similar educationwere also held in the United States when mercury contaminated whiteners werediscovered (Weldon et al. 2000). Protein and mercury analysis of urine could be donein Phnom Penh to resolve if kidneys were being damaged by mercury. Analysis of hairfor mercury would be a small addition that would clarify the uncertainty of mercurycontamination in Phnom Penh, but urine analysis should be the first priority. Thepotential for behavioural disorders from mercury could be resolved with minimalequipment, but the professional evaluation is complex and the educational aspect isless obvious. The immune system is weakened by mercury (WHO 2003), but attemptsto resolve associations between disease and mercury in Cambodia would likely becomplex and expensive although a nice aspiration.
Any medical clinics would have to be simple and education should be a key component. Avoiding the use of any skin whitening is the best treatment. Suchclinics could include analysis of more skin whiteners so that the public could avoidthe most contaminated products. At least for screening purposes, future analysisshould consider using a less sensitive approach than a cold vapor atomic absorptionspectrophotometry system dedicated to mercury analysis. Such sensitive equipmentis best for validation. Contamination by the most elevated of the skin cream sam-ples required extensive cleaning of the instrument. In Dec 2007, ASEAN suggesteda screening method that should enable a more complete analysis of the market(ASEAN Cosmetic Committee (ACC) 2007). The screening kit we used is effectivein detecting the creams with the highest mercury concentrations that would con-taminate equipment and it can provide a focus on the most hazardous creams. Butit is not clear that this kit is sensitive enough to detect all samples with toxic levels ofmercury. Moreover, because it requires a large sample size (3 g), most jars of creamare 3–5 g in size, and mercury concentration is variable, this kit could not provide Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 an individual much screening ability.
International Implications
Like most developing countries, Cambodia is very dependent upon foreign aid and international efforts are required to control mercury (Irvine et al. 2006). Cam-bodia is amongst the poorest countries in the world, ranking 131 of 177 countriesin the 2007/8 Human Development Index (http://hdr.undp.org/en/). The GDPper capita in 2007 was $571 (http://www.state.gov/r/pa/ei/bgn/2732.htm). TheKhmer Rouge killed or forced most educated people into exile. Not only did theKhmer Rouge period exact a heavy toll on the Cambodian population, there alsowere major impacts on institutions and infrastructure within the country. Universi-ties were closed, as were many primary and secondary schools. Phyrun (1996, p. 1)noted that one of the outcomes of the Khmer Rouge (KR) period was the “completedestruction of institutions responsible for management of the country’s resources.”The impact of the KR goes beyond the years when they ruled Cambodia (1975 to Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 Mercury Contamination of Skin Whiteners in Cambodia
1979). To suppress the KR, Vietnam occupied Cambodia from 1979 to 1989. Mur-ders of tourists by KR continued into the mid 1990s, thus forcing a high proportionof government funding to be spent on security. In 2009, Cambodian governmentfunding on health and education was assessed as the lowest observed in an interna-tional review by an international survey funded by Canada (Center for Economicand Social Rights 2009).
The problems in Cambodia go beyond the destruction of medical, educational and scientific agencies by the Khmer Rouge. Problems with accountability, trans-parency, and legal enforcement continue to persist in Cambodia (Lum 2007). InJanuary 2008, Cambodia agreed to adopt the ASEAN cosmetic standards. Moreover,in August 2008, a subdecree was passed banning importation of products not fol-lowing ASEAN cosmetic standards (Chhay 2008). It is essential that ASEAN partnercountries work both within their borders and collectively as an association, to elimi-nate the production of mercury-containing products. This will require a serious andcoordinated effort by responsible governments.
The financial incentive to make counterfeit cosmetics is huge. No surveys exist for Cambodia but regional surveys reflect the market for the producers of the skinwhiteners. In 1999, the Japanese market for skin whiteners exceeded $5 billion(Glenn 2008). Surveys in 2004 and 2007 estimated the proportion of womenregularly using skin whiteners as follows: Japan and Hong Kong 18%, Taiwan 20%,China 30%, and Philippines 50% (Glenn 2008). It is not clear who makes mercurycontaining products sold in SE Asia. However, it seems that production of someproducts labeled “for export only” represents an intentional action to allow pro-duction of products not legal for sale in the country of origin. The Food and DrugAdministration of Thailand (FDA 2002) considers mercury a prohibited substancethat “must not form a part of cosmetic products except under the conditions laiddown” (Thailand Cosmetic Act 1992). Similarly, skin creams with mercury areillegal to sell in the European Union (EU), but in spite of lawsuits, it is very welldocumented that they are made for export there (Glenn 2008). The export of mer-cury and mercury compounds from the EU will be prohibited from March 15, 2011,http://www.europarl.europa.eu/news/expert/infopress page/064-29478-140-05- Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 21-911-20080520IPR29477-19-05-2008-2008-false/default en.htm.
In the United States, a bill was passed into law October 2008 by both houses of Congress to ban the distribution and export of mercury. Sponsored by then-Senator Barack Obama, the Mercury Export Ban Act of 2008 will take full effectJanuary 1, 2013. The new law further requires an extensive Report to Congresson “mercuric chloride, mercurous chloride or calomel, mercuric oxide, and othermercury compounds, if any, that may currently be used in significant quantitiesin products or processes.” As export bans take effect in the European Union andthe United States, the world trade in mercury should decrease significantly. It isstill important to restrict trade in other countries that are yet to prohibit sales ofmercury containing cosmetics. Attention must be directed at countries exportingtoxic cosmetics to countries like Cambodia with limited capacity to control suchtrade.
New ASEAN regulations on cosmetics including skin whiteners were implemented January 1, 2008 (Steinberg 2008). Our observations of skin creams in several marketsin Phnom Penh in July and December of 2008 do not indicate compliance of Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 T. Murphy et al.
labeling as required in the new regulations. It is not certain if manufacturers arecomplying with the new regulations or if distributors are selling old stock. It wasnot possible for us to estimate the volume of sales of mercury containing products.
Some vendors admitted they sold counterfeit copies but would not discuss detailsor sell us these products. We can only state that toxic levels of mercury were presentin >27% of brands of skin whiteners in popular markets in Phnom Penh. In thesummer of 2008, similar looking whiteners were observed in many parts of Cambodia(Battambang, Pursat, Siem Reap, Sihanoukville, etc.) and Bangkok, Thailand. In2007 these creams were not available in remote sites such as tribal areas of northeastCambodia (Ratanakirri). It is important to expand upon the work we did in simplemarkets, look for counterfeit creams in more upper class markets and processsamples from other regions.
Two other regional examples illustrate that the chances of export of mercury containing creams to Cambodia being random are very slight. According to officialregulations in Taiwan, mercury salts are forbidden as a bleaching agent in cosmeticproducts. In a sampling of 80 brands of skin whiteners in Taiwan, only one had sig-nificant mercury (Lin et al. 1999). Unlike Cambodia, Taiwan monitors such creamsand vendors avoid marketing mercury containing creams. In another example in2000, a study of 38 skin-whitening creams in Hong Kong showed eight made byglobal cosmetic makers exceeded the U.S. Food and Drug Administration safetylimits for mercury (Chan et. al. 2001). After media attention and official action, twoyears later a 2002 Consumer Council study found that all 32 skin-whitening productstested passed the safety requirement for mercury (Wong 2004).
CONCLUSIONS
Many women in Phnom Penh are using skin whiteners with toxic concentrations of mercury. Unfortunately, official action in Cambodia does not seem imminentlylikely to control this contamination. In surveys of medical drugs in Cambodia any-where from 30% to 100% of products were counterfeit or at least misrepresented onthe labels (USAID 2008). Since very little mercury is required to make skin whiten- Downloaded By: [Murphy, Tom] At: 15:07 2 December 2009 ers, the concept of increasing the price of mercury to suppress use of mercury byartisanal miners does not apply well to skin whiteners. International efforts to restrictproduction and export of skin whiteners should continue. Medical clinics as weredone by Barr et al. (1972) and Weldon et al. (2000), focusing on kidney and otherdamage from mercury, funded with international aid and augmented by educationare likely the most effective strategies.
ACKNOWLEDGMENTS
Thanks go to Shaun Ayers and Ron Weyand, who conducted the CVAA Hg analy- ses at the University of California, Davis. Dr. How-Ran Guo provided information onmercury containing skin whiteners in Taiwan. Ms. Ratchadawan Ngoen-klan trans-lated the methods for the Thai mercury kit. Ms. Siripan Na Jatturat assisted withcommunications with the Thai supplier of the medical kits. The Blacksmith Insti-tute provided support for mercury evaluation of artisanal miners. We appreciate the Hum. Ecol. Risk Assess. Vol. 15, No. 6, 2009 Mercury Contamination of Skin Whiteners in Cambodia
many useful comments from the reviewers of this article. We appreciate the supportfrom the late Dr. Mickey Sampson, who inspired us throughout this project.
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