Silica & Silicates

Amended Safety Assessment of Silica and Silicates as Used in
Cosmetics
Status: Draft Amended Report for Panel Review

Release Date: November 9, 2018
Panel Meeting Date: December 3-4, 2018
The 2018 Cosmetic Ingredient Review Expert Panel members are: Chair, Wilma F. Bergfeld, M.D., F.A.C.P.;
Donald V. Belsito, M.D.; Ronald A. Hill, Ph.D.; Curtis D. Klaassen, Ph.D.; Daniel C. Liebler, Ph.D.; James G.
Marks, Jr., M.D.; Ronald C. Shank, Ph.D.; Thomas J. Slaga, Ph.D.; and Paul W. Snyder, D.V.M., Ph.D. The CIR
Executive Director is Bart Heldreth, Ph.D. This safety assessment was prepared by Christina L. Burnett, Senior
Scientific Analyst/Writer.
© Cosmetic Ingredient Review

1620 L St NW, Suite 1200◊ Washington, DC 20036-4702 ◊ ph 202.331.0651 ◊fax 202.331.0088
◊ cirinfo@cir-safety.org
Commitment & Credibility since 1976
Memorandum
To: CIR Expert Panel Members and Liaisons

From: Christina L. Burnett, Senior Scientific Analyst/Writer
Date: November 9, 2018
Subject: Draft Amended Safety Assessment of Silica and Silicate Ingredients
Enclosed is the Draft Amended Safety Assessment of Silica and Silicate Ingredients as Used in Cosmetics. (It is identified as
silica122018rep in the pdf document). In 2003, the Panel published a safety assessment on the following 17 silicate and clay
ingredients, with the conclusion that that these ingredients are safe as used in cosmetic products:
Aluminum Silicate Magnesium Aluminum Silicate
Attapulgite Magnesium Silicate
Bentonite Magnesium Trisilicate
Calcium Silicate Montmorillonite
Fuller's Earth Pyrophyllite
Hectorite Sodium Magnesium Silicate
Kaolin Zeolite
Lithium Magnesium Silicate Zirconium Silicate
Lithium Magnesium Sodium Silicate
At the June 2018 meeting, the Panel considered a re-review of the above safety assessment, and decided to re-open this report to
add an additional 23 ingredients. The add-on ingredients, listed below, include 9 silica and silicate ingredients that were
previously reviewed by the Panel and 15 ingredients that have not been reviewed by the Panel.
Aluminum Calcium Sodium Silicate* Aluminum Iron Calcium Magnesium Zirconium
Aluminum Iron Silicates* Silicates
Hydrated Silica* Ammonium Silver Zinc Aluminum Silicate
Magnesium Aluminometasilicate* Ammonium Silver Zeolite
Potassium Silicate* Calcium Magnesium Silicate
Silica* Gold Zeolite
Sodium Metasilicate* Silver Copper Zeolite
Sodium Potassium Aluminum Silicate* Sodium Magnesium Aluminum Silicate
Sodium Silicate* Sodium Silver Aluminum Silicate
Activated Clay Titanium Zeolite
Aluminum Iron Calcium Magnesium Germanium Tromethamine Magnesium Aluminum Silicate
Silicates Zinc Silicate
Zinc Zeolite
*Ingredients previously reviewed by the Panel.
In this amended safety assessment, the Panel will find that CIR staff has merged the safety assessment on Silica (final 2009) into
this new amended document and has heavily edited the document to conform to the current CIR report format. This reformatting
effort is still a work in progress, with additional tables planned for incorporation. CIR staff welcomes any additional suggestions
for this report reorganization effort.
According to 2018 VCRP data, Silica has the most reported uses in cosmetic products, with a total of 8024; the majority of the
uses are in leave-on eye makeup preparations and makeup preparations. Kaolin has the second most reported uses in cosmetic
products, with a total of 1794; the majority of the uses are also in leave-on eye makeup preparations and makeup preparations.
-1-
The reported numbers of uses for the remaining ingredients in this report are much lower. The uses for both of these ingredients
have greatly increased since the original safety assessments were finalized: in 2009, Silica was reported to have 3276 uses and in
1998, Kaolin was reported to have 509 uses. The results of the concentration of use survey conducted in 2018 by the Council
indicate Silica has the highest reported maximum concentration of use; it is used at up to 82% in face and neck products and 50%
in mascaras. Kaolin is used at up to 53% in “other” manicuring products and up to 35% in rinse-off “other” skin care preparations.
According to the original safety assessments, the maximum use concentration for Kaolin was 100% in leave-on “other” skin care
preparations and the maximum use concentration for Hectorite was 100% in rinse-off skin cleansing preparations (the maximum
leave-on concentration was 15% in makeup foundations). Silica was reported to be used at up to 44% in eye shadows.
Since the June Panel meeting, CIR has received the concentration of use survey for Silica ingredients (both original and add-on
ingredients), an updated concentration of use survey for Silicate ingredients (both original and add-on ingredients), and a notice
from the Council that Aluminum Calcium Magnesium Potassium Sodium Zinc Silicates has been deleted from the INCI
Dictionary (identified as silica122018data_1 through silica122018data_5 in the pdf document). Because this ingredient is no
longer in the Dictionary, it has been deleted from this report. Comments provided by the Council prior to the June meeting on the
re-review document have been addressed (silica122018 pcpc).
The previous silicate reports are attached for your use:

• Final Report on the Safety Assessment of Aluminum Silicate, Calcium Silicate, Magnesium Aluminum Silicate,
Magnesium Silicate, Magnesium Trisilicate, Sodium Magnesium Silicate, Zirconium Silicate, Attapulgite, Bentonite,
Fuller’s Earth, Hectorite, Kaolin, Lithium Magnesium Silicate, Lithium Magnesium Sodium Silicate, Montmorillonite,
Pyrophyllite, and Zeolite (2003) [silica122018origrep]
• Final Report on the Safety Assessment of Potassium Silicate, Sodium Metasilicate, and Sodium Silicate (2005)
[silica122018_silicates2005]
Minutes from the original deliberations of the original review, the original deliberations from the other reports named above, and
the minutes from the June 2018 meeting have been included:
• September 1999 and February 2000 - Aluminum Silicate, Calcium Silicate, Magnesium Aluminum Silicate, Magnesium
Silicate, Magnesium Trisilicate, Sodium Magnesium Silicate, Zirconium Silicate, Attapulgite, Bentonite, Fuller’s Earth,
Hectorite, Kaolin, Lithium Magnesium Silicate, Lithium Magnesium Sodium Silicate, Montmorillonite, Pyrophyllite, and
Zeolite [silica122018min1_origsilicates]
• December 1999, May 2000, December 2000 and June 2001 - Potassium Silicate, Sodium Metasilicate, and Sodium
Silicate [silica122018min2_saltsilicates]
• June 2009 and September 2009 - Silica and Related Cosmetic Ingredients [silica122018min3_silica]
• June 2018 – Re-review discussion for this current report [silica1221018min4_current review]
If no further data are needed, the Panel should formulate an updated Discussion and issue a Tentative Amended Report. However,
if additional data are required, the Panel should be prepared to identify those needs and issue an Insufficient Data Announcement.
__________________________________________________________________________________________
1620 L Street, NW Suite 1200, Washington, DC 20036
(Main) 202-331-0651 (Fax) 202-331-0088
(Email) cirinfo@cir-safety.org (Website) www.cir-safety.org
RE-REVIEW FLOW CHART
INGREDIENT/FAMILY____Silica and Silicates _____________________
MEETING _______ December 2018_______________________________________________________
Public Comment CIR Expert Panel Re-Review Rpt Status
New Data; or
announce 15 years OR request
since last
review
IJT 22 (Suppl 1): 37-
102, 2003
Re-review
to Panel
PRIORITY LIST June 2018
Are new data cause to reopen?
YES
NO
DRAFT AMENDED
DAR REPORT Dec 2018 Are new ingredients
appropriate for
inclusion/re-open?
Table
Table IDA TAR 9 potential add-ons from
other reports (IJT 24(Suppl
1): 103-17, 2005; CIR
Yes No 2009)
15 proposed add-ons not

IDA Notice IDA previously reviewed
RE-REVIEW Admin Book
DRAFT TENTATIVE SUMMARY 41 ingredients total
Draft TAR AMENDED REPORT
Table
Table
Tentative
Amended Report
Issue
TAR
Draft FAR DRAFT FINAL

60 day Public comment period AMENDED REPORT
Table
Table Different Conclusion
Final Amended Issue

PUBLISH Report FAR
*If Draft Amended Report (DAR) is available, the Panel may choose to review; if not, CIR staff prepares DAR for Panel Review.
Distributed for comment only -- do not cite or quote
Silicates History
2003– The CIR’s Final Report on the Safety Assessment of Aluminum Silicate, Calcium
Silicate, Magnesium Aluminum Silicate, Magnesium Silicate, Magnesium Trisilicate,
Sodium Magnesium Silicate, Zirconium Silicate, Attapulgite, Bentonite, Fuller’s Earth,
Hectorite, Kaolin, Lithium Magnesium Silicate, Lithium Magnesium Sodium Silicate,
Montmorillonite, Pyrophyllite, and Zeolite in the IJT after the report was finalized by the
Panel in 2000. Based on the available animal and clinical data available at that time, the
Panel concluded that these ingredients are safe as cosmetic ingredients in the practices of
use and concentrations as described in the safety assessment.
2005 – The CIR’s Final Report on the Safety Assessment of Potassium Silicate, Sodium
Metasilicate, and Sodium Silicate in the IJT after the report was finalized by the Panel in
2001. Based on the available animal and clinical data available at that time, the Panel
concluded that these ingredients are safe for use in cosmetic products in the practices of
use and concentration described in the safety assessment when formulated to avoid
irritation.
2009 – The CIR issued a Final Report on the Safety Assessment of Silica and Related
Cosmetic Ingredients, which has not been published in the IJT. Based on the available
animal and clinical data available at that time, the Panel concluded that Silica, Alumina
Magnesium Metasilicate (now called Magnesium Aluminometasilicate), Aluminum
Calcium Sodium Silicate, Aluminum Iron Silicates, Hydrated Silica, and Sodium
Potassium Aluminum Silicate are safe as cosmetic ingredients in the practices of use and
concentrations as described in the safety assessment.
April/May 2018 – Review of the available published literature since 2000 was conducted
in accordance to CIR Procedure regarding re-review of ingredients after ~15 years.
June 2018 - The Panel decided to re-open the 2003 Silicates report and add an additional
23 ingredients, which include 9 silica and silicate ingredients that were previously
reviewed by the Panel and 14 ingredients that have not been reviewed by the Panel.
The Panel noted that for many of the previously reviewed ingredients, uses have
increased significantly.
Silica and Silicates Data Profile –December 2018 – Writer, Christina Burnett
Composition/Impurities
Irritation/Sensitization
Clinical Studies/Case
Reproductive and
Physical/Chemical
Toxicity Studies
Developmental
Other Relevant
Ocular/Mucosal
Repeated Dose
Carcinogenicity
Toxicokinetics
Acute Toxicity
Manufacturing
Genotoxicity
Phototoxicity
- Nonhuman
Properties
Method of
- Human
Toxicity
Toxicity
Reports
In-Use
Aluminum Silicate X X X X X X X X X X
Calcium Silicate X X X X X X X X
Magnesium Aluminum
X X X X X X X X X X X
Silicate
Magnesium Silicate X X X
Magnesium Trisilicate X X X X X
Sodium Magnesium Silicate X X X X
Zirconium Silicate X X X X
Attapulgite X X X X X X X X
Bentonite X X X X X X X X
Fuller’s Earth X X X
Hectorite X X X X X X X
Kaolin X X X X X X X X
Lithium Magnesium Silicate X
Lithium Magnesium Sodium
X
Silicate
Montmorillonite X X X X X
Pyrophyllite
Zeolite X X X X X X X X X X X
Potassium Silicate X X X X X
Sodium Metasilicate X X X X X X X X X
Sodium Silicate X X X X X X X X X X X X
Silica X X X X X X X X X X X X X X
Hydrated Silica X X X X X X X X X X X X X
Aluminum Calcium Sodium
X X X
Silicate
Aluminum Iron Silicates
Magnesium
X
Aluminometasilicate
Sodium Potassium
X X X
Aluminum Silicate
Silica and Silicates Data Profile –December 2018 – Writer, Christina Burnett
Clinical Studies/Case
Reproductive and
Physical/Chemical
Toxicity Studies
Developmental
Other Relevant
Ocular/Mucosal
Repeated Dose
Carcinogenicity
Toxicokinetics
Acute Toxicity
Manufacturing
Genotoxicity
Phototoxicity
- Nonhuman
Properties
Method of
- Human
Toxicity
Toxicity
Reports
In-Use
Activated Clay
Aluminum Iron Calcium
Magnesium Germanium
Silicates
Aluminum Iron Calcium
Magnesium Zirconium
Silicates
Ammonium Silver Zeolite
Ammonium Silver Zinc
X
Aluminum Silicate
Calcium Magnesium Silicate
Gold Zeolite
Silver Copper Zeolite
Sodium Magnesium
X X
Aluminum Silicate
Sodium Silver Aluminum
Silicate
Titanium Zeolite
Tromethamine Magnesium
Aluminum Silicate
Zinc Silicate X X X X
Zinc Zeolite X
“X” indicates that data were available in the category for that ingredient.
Silicates
Ingredient CAS # InfoB SciFin PubMed TOXNET FDA EU ECHA IUCLID SIDS ECETOC HPVIS NICNAS NTIS NTP WHO FAO NIOSH FEMA Web
Re-Review Ingredients
Aluminum 1327-36-2 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Silicate
Aluminum 1344-01-1 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Calcium Sodium
Silicate
Aluminum Iron √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Silicates
Attapulgite 12174-11-7; √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
1337-76-4
Bentonite 1302-78-9 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Calcium Silicate 1344-95-2 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Fuller’s Earth 8031-18-3 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Hectorite 12173-47-6; √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
68084-71-9
Hydrated Silica 10279-57-9; √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
112926-00-8;
1343-98-2;
63231-67-4;
7631-86-9
Kaolin 1332-58-7 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Lithium 37220-90-9 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Magnesium
Silicate
Lithium 53320-86-8 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Magnesium
Sodium Silicate
Magnesium 12408-47-8 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Aluminometasili
cate
Magnesium 12199-37-0; √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Aluminum 12511-31-8
Silicate
Magnesium 1343-88-0 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Silicate
Magnesium 14987-04-3 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Trisilicate
Montmorillonite 1318-93-0 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Pyrophyllite 11349-10-3; √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
113349-11-4;
113349-12-5;
12269-78-2;
141040-73-5;
141040-74-6
Silica 112945-52-5; √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
60676-86-0;
7631-86-9
Sodium √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Magnesium
Silicate
Sodium 12736-96-8; √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Potassium 66402-68-4
Aluminum
Silicate
Zeolite 1318-02-1 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Zirconium 10101-52-7; √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Silicate 1344-21-4
Sodium Silicate 1344-09-8 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Sodium 6834-92-0 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Metasilicate
Potassium 1312-76-1 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Silicate
Sodium Silver √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Aluminum
Silicate
Tromethamine √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Magnesium
Aluminum
Silicate
Activated Clay √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Ammonium √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Silver Zinc
Aluminum
Silicate
Ammonium √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Silver Zeolite
Aluminum Iron √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Calcium
Magnesium
Germanium
Silicates
Aluminum Iron √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Calcium
Magnesium
Zirconium
Silicates
Calcium 12765-06-9 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Magnesium
Silicate
Silver Copper 130328-19-7; √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Zeolite 168042-42-0
Sodium 12040-43-6 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Magnesium
Aluminum
Silicate
Zinc Silicate 13597-65-4 √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Gold Zeolite √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Zinc Zeolite √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Titanium Zeolite √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
Typical Search Terms

 INCI names
 CAS numbers
 chemical/technical names
 additional terms will be used as appropriate
Total references ordered/downloaded from initial searches = 45 (some relevant hits were duplicates)
Search updated October 2018, no new relevant studies.
Search Strategy: Re-review ingredients limited time frame from 2000-2018, except where noted
PubMed
Re-review ingredients
Aluminum Silicate – 11825 hits, limited with toxicity = 770 hits, limited with irritation = 14 hits (4 relevant), limited with sensitization = 9 (0 relevant), limited with dermal = 20
hits (5 relevant)
Aluminum Calcium Sodium Silicate – 6 hits (0 relevant)
Aluminum Iron Silicates - 281 hits, limited with toxicity = 27 hits, limited with irritation = 0 hits, limited with sensitization = 0 hits, limited with dermal = 0 hits
Attapulgite – 231 hits, limited with toxicity = 13 hits (3 relevant), limited with irritation = 0 hits, limited with sensitization = 0 hits, limited with dermal = 0 hits
Bentonite – 2155 hits, limited with toxicity = 161 hits, limited with irritation = 3 hits (1 revelant), limited with sensitization = 0 hits, limited with dermal = 7 hits (1 relevant)
Calcium Silicate – 1181 hits, limited with toxicity = 79 hits, limited with irritation = 0 hits, limited with sensitization = 0 hits, limited with dermal = 1 hit (0 relevant)
Fuller’s Earth – 50 hits (12 relevant)
Hectorite – 89 hits (0 relevant)
Hydrated Silica (limited to 2009-2018) – 12440 hits, limited with toxicity = 1764 hits, limited with irritation = 14 hits (4 relevant), limited with sensitization = 9 hits (0 relevant),
limited with dermal = 28 hits (6 relevant)
Kaolin – 1964 hits, limited with toxicity = 160 hits (4 relevant), limited with irritation = 2 hits (0 relevant), limited with sensitization = 17 hits (0 relevant), limited with dermal = 1
hit (0 relevant)
Lithium Magnesium Silicate – 3 hits (0 relevant)
Lithium Magnesium Sodium Silicate – 2 hits (1 relevant)
Magnesium Aluminometasilicate – 24 hits (0 relevant)
Magnesium Aluminum Silicate – 80 hits (1 relevant)
Magnesium Silicate – 776 hits, limited with toxicity = 31 hits (3 relevant), limited with irritation (0 relevant), limited with sensitization = 1 hit (0 relevant), limited with dermal =1
hit (0 relevant)
Magnesium Trisilicate – 198 hits (2 relevant)
Montmorillonite – 3385 hits, limited with toxicity = 214 hits (8 relevant), limited with irritation = 6 hits (1 relevant), limited with sensitization = 0 hits, limited with dermal = 8
hits (1 relevant)
Pyrophyllite – 946 hits, limited with toxicity = 60 hits (0 relevant), limited with irritation = 3 hits (0 relevant), limited with senstitzation = 0 hits, limited with dermal = 0 hits
Silica (limited to 2009-2018) – 47,440 hits, limited with toxicity = 3342 hits, limited with irritation = 30 hits (2 relevant), limited with sensitization = 41 hits (0 relevant), limited
with dermal = 84 hits (3 relevant)
Sodium Magnesium Silicate – 66 hits (1 relevant)
Sodium Potassium Aluminum Silicate – 8 hits (0 relevant)
Zeolite – 6699 hits, limited with toxicity = 193 hits (1 relevant), limited with irritation = 4 hits (1 relevant), limited with sensitization = 6 hits (0 relevant), limited with dermal = 5
hits (1 relevant)
Zirconium Silicate – 350 hits (0 relevant)
Sodium Silicate – 338 hits (3 relevant)
Sodium Metasilicate – 84 hits (5 relevant)
Potassium Silicate – 912 hits, limited with toxicity = 25 hits (1 relevant), limited with irritation = 4 hits (0 relevant), limited with sensitization = 0 hits, limited with dermal = 0 hits
Add-on ingredients
Sodium Silver Aluminum Silicate - 18 hits (0 relevant)
Tromethamine Magnesium Aluminum Silicate – 0 hits
Activated Clay – 383 hits (0 relevant)
Ammonium Silver Zinc Aluminum Silicate – 1 hit (0 relevant)
Aluminum Calcium Magnesium Potassium Sodium Zinc Silicates - 2 hits (0 relevant)
Aluminum Iron Calcium Magnesium Germanium Silicates – 0 hits
Aluminum Iron Calcium Magnesium Zirconium Silicates – 0 hits
Sodium Magnesium Aluminum Silicate – 19 hits (0 relevant)
Zinc Silicate - 70 hits (0 relevant)
Ammonium Silver Silcate – 4 hits (0 relevant)
Gold Zeolite - 62 hits (0 relevant)
Zinc Zeolite – 222 hits (0 relevant)
SciFinder: Re-review ingredients limited time from from 2000-2018, except where noted, and to Adverse Effects and English
Re-review ingredients
Aluminum Silicate – 10 hits, 0 relevant (CAS#1335-30-4), 25 hits, 0 relevant (CAS#1327-36-2)
Aluminum Calcium Sodium Silicate (from 2005-2018) – 15 hits, 2 relevant
Aluminum Iron Silicates (from 2005-2018)
Attapulgite – 11 hits, 5 relevant
Bentonite – 119 hits, 7 relevant
Calcium Silicate - 5 hits, 1 relevant (CAS# 10034-77-2), 60 hits, 4 relevant (CAS#1344-95-2)
Fuller’s Earth – 13 hits, 0 relevant
Hectorite – 4 hits (CAS# 12173-47-6)
Hydrated Silica (from 2005-2018) - 0 hits (CAS#870616-37-8), 0 hits (CAS#68918-35-4), 1 hit, 1 relevant (CAS#112926-00-8), 18 hits, 0 relevant (CAS#63231-67-4), 2 hits, 0
relevant (CAS#10279-57-9), 54 hits, 1 relevant (CAS#1343-98-2)
Kaolin – 132 hits, 1 relevant
Lithium Magnesium Silicate – 0 hits
Lithium Magnesium Sodium Silicate – 1 hit, 1 relevant
Magnesium Aluminometasilicate – 0 hits
Magnesium Aluminum Silicate – 4 hits, 1 relevant (CAS#1327-43-1), 0 hits (CAS#12511-31-8), 20 hits, 0 relevant (CAS#12199-37-0)
Magnesium Silicate – 11 hits, 1 relevant
Magnesium Trisilicate – 7 hits, 1 relevant
Montmorillonite – 47 hits, 7 relevant
Pyrophyllite – 0 hits (CAS#141040-74-6), 0 hits (CAS#141040-73-5), 0 hits (CAS#13349-12-5), 0 hits (CAS#113349-11-4), 0 hits (CAS#113349-10-3), 0 hits (CAS #12269-78-
2)
Silica (from 2005-2018) – 3606 hits, further limited by dermal OR irritation OR sensitization OR cosmetic = 6 hits, 0 relevant;
Sodium Magnesium Silicate – 0 hits
Sodium Potassium Aluminum Silicate (from 2005-2018) – 0 hits
Zeolite – 140 hits, 1 relevant
Zirconium Silicate – 5 hits, 0 relevant (CAS#10101-52-7), 5 hits, 0 relevant (CAS#1344-21-4)
Sodium Silicate – 16 hits, 1 relevant
Sodium Metasilicate – 13hits, 5 relevant
Potassium Silicate – 0 hits (CAS#10006-28-7), 5 hits, 0 relevant (CAS#1312-76-1)
Add-on ingredients
Sodium Silver Aluminum Silicate – 0 hits
Tromethamine Magnesium Aluminum Silicate – 0 hits
Activated Clay- 0 hits
Ammonium Silver Zinc Aluminum Silicate – 0 hits
Aluminum Iron Calcium Magnesium Germanium Silicates – 0 hits
Aluminum Iron Calcium Magnesium Zirconium Silicates - 0 hits
Ammonium Silver Zeolite – 0 hits
Sodium Magnesium Aluminum Silicate – 0 hits
Zinc Silicate – 0 hits (CAS #127734-84-3), 0 hits (CAS#126755-25-7), 0 hits (CAS#13814-85-2), 1 hit, 0 relevant (CAS#13597-65-4) 0 hits (CAS#11126-29-7)
Ammonium Silver Silcate – 0 hits
Gold Zeolite – 0 hits
Calcium Magnesium Silicate – 1 hit, 0 relevant
Silver Copper Zeolite – 0 hits
Zinc Zeolite – 0 hits
Titanium Zeolite – 0 hits
LINKS
Search Engines
 Pubmed (- http://www.ncbi.nlm.nih.gov/pubmed)
 Toxnet (https://toxnet.nlm.nih.gov/); (includes Toxline; HSDB; ChemIDPlus; DART; IRIS; CCRIS; CPDB; GENE-TOX)
 Scifinder (https://scifinder.cas.org/scifinder)
appropriate qualifiers are used as necessary

search results are reviewed to identify relevant documents
Pertinent Websites
 wINCI - http://webdictionary.personalcarecouncil.org
 FDA databases http://www.ecfr.gov/cgi-bin/ECFR?page=browse
 FDA search databases: http://www.fda.gov/ForIndustry/FDABasicsforIndustry/ucm234631.htm;,
 EAFUS: http://www.accessdata.fda.gov/scripts/fcn/fcnnavigation.cfm?rpt=eafuslisting&displayall=true
 GRAS listing: http://www.fda.gov/food/ingredientspackaginglabeling/gras/default.htm
 SCOGS database: http://www.fda.gov/food/ingredientspackaginglabeling/gras/scogs/ucm2006852.htm
 Indirect Food Additives: http://www.accessdata.fda.gov/scripts/fdcc/?set=IndirectAdditives
 Drug Approvals and Database: http://www.fda.gov/Drugs/InformationOnDrugs/default.htm
 http://www.fda.gov/downloads/AboutFDA/CentersOffices/CDER/UCM135688.pdf
 FDA Orange Book: https://www.fda.gov/Drugs/InformationOnDrugs/ucm129662.htm
 OTC ingredient list: https://www.fda.gov/downloads/aboutfda/centersoffices/officeofmedicalproductsandtobacco/cder/ucm135688.pdf
 (inactive ingredients approved for drugs: http://www.accessdata.fda.gov/scripts/cder/iig/
 HPVIS (EPA High-Production Volume Info Systems) - https://ofmext.epa.gov/hpvis/HPVISlogon
 NIOSH (National Institute for Occupational Safety and Health) - http://www.cdc.gov/niosh/
 NTIS (National Technical Information Service) - http://www.ntis.gov/
 NTP (National Toxicology Program ) - http://ntp.niehs.nih.gov/
 Office of Dietary Supplements https://ods.od.nih.gov/
 FEMA (Flavor & Extract Manufacturers Association) - http://www.femaflavor.org/search/apachesolr_search/
 EU CosIng database: http://ec.europa.eu/growth/tools-databases/cosing/
 ECHA (European Chemicals Agency – REACH dossiers) – http://echa.europa.eu/information-on-chemicals;jsessionid=A978100B4E4CC39C78C93A851EB3E3C7.live1
 ECETOC (European Centre for Ecotoxicology and Toxicology of Chemicals) - http://www.ecetoc.org
 European Medicines Agency (EMA) - http://www.ema.europa.eu/ema/
 IUCLID (International Uniform Chemical Information Database) - https://iuclid6.echa.europa.eu/search
 OECD SIDS (Organisation for Economic Co-operation and Development Screening Info Data Sets)- http://webnet.oecd.org/hpv/ui/Search.aspx
 SCCS (Scientific Committee for Consumer Safety) opinions: http://ec.europa.eu/health/scientific_committees/consumer_safety/opinions/index_en.htm
 NICNAS (Australian National Industrial Chemical Notification and Assessment Scheme)- https://www.nicnas.gov.au/
 International Programme on Chemical Safety http://www.inchem.org/
 FAO (Food and Agriculture Organization of the United Nations) - http://www.fao.org/food/food-safety-quality/scientific-advice/jecfa/jecfa-additives/en/
 WHO (World Health Organization) technical reports - http://www.who.int/biologicals/technical_report_series/en/
 www.google.com - a general Google search should be performed for additional background information, to identify references that are available, and for other general
information
Aluminum Silicate, Calcium Silicate, Magnesium Aluminum Silicate, Magnesium Silicate, Magnesium
Trisilicate, Potassium Silicate, Sodium Magnesium Silicate, Sodium Metasilicate, Sodium Silicate, Zirconium
Silicate, Attapulgite, Bentonite, Fuller’s Earth, Hectorite, Kaolin, Lithium Magnesium Silicate, Lithium
Magnesium Sodium Silicate, Montmorillonite, Pyrophyllite, and Zeolite
September 9-10, 1999

Dr. Belsito noted that this group of ingredients consists mostly of clay-like materials, but that salts (i.e., Potassium
Silicate, Sodium Metasilicate, Sodium Silicate, and, possibly, Zirconium Silicate) are also included. He also
recalled studies indicating that the salts, but not the clays, were irritants, and that his Team recommended that these
four salts should be included in a separate report. The Belsito Team also concluded that the remaining ingredients
are safe as used in cosmetic products. Dr. Belsito said that his Team will make a decision on specific data requests
after the current report has been divided into two separate reports.
Dr. Schroeter said that his Team agreed that the ingredients in this review could be separated into two groups,
soluble salts, which may be active (Sodium Metasilicate, Potassium Silicate, and Sodium Silicate) and minerals of
solids (or clays) within the same report. He noted that the clays have no absorption and are basically safe, except for
the possibility of irritation. Dr. Schroeter also noted that cosmetic use includes sprays and that the issue of
inhalation exposure could be addressed in the report discussion as a cautionary item. Furthermore, he said that the
irritation potential of clays could be addressed in the report discussion by stating that concentrations in formulation
that induce irritation should be avoided.
Dr. Andersen said that according to yesterday’s Team discussions, the principal issue concerning the soluble salts
relates to irritation. Therefore, he said that if the conclusion on this group of ingredients could reflect the need to
formulate so that products are not irritating, then that concern could be eliminated.
Dr. Andersen also said that it may be possible for the Panel to issue a tentative conclusion on this group of
ingredients. He recalled that, except for the issue of inhalation exposure to clays, there are no other safety issues
and, thus, the clays could be considered safe as used.
Dr. Belsito agreed that a safe as used conclusion could be issued on the clays. He also said that it could be stated in
the report discussion that data on the use of clays in aerosolized products are insufficient.
Dr. Shank expressed concern over the possibility of silicosis following inhalation exposure to dust particles.
Dr. McEwen said that silicosis is not a concern because these ingredients are not composed of crystalline silicone.
However, he noted that pneumoconiosis may be a concern.
Dr. Andersen noted that crystalline forms do exist.
Dr. Belsito proposed dividing the current document into two reports. One of the reports will contain a safe as used
conclusion on the clays and the other report on the salts will be re-reviewed as a separate document. Dr. Belsito
speculated that the issue of irritation will be the only safety issue relating to the salts.
The Panel agreed with Dr. Belsito’s proposal.
Dr. Schroeter confirmed that the issue of inhalation relating to the clays will be addressed in the report discussion.
The Panel voted unanimously in favor of issuing a Tentative Report with a safe as used conclusion (and appropriate
report discussion) on the clays.
The Panel also voted unanimously in favor of incorporating the data on the soluble salts from the current report into
a separate document that will be reviewed by the Panel.
Dr. Bergfeld stated that the report on the soluble salts will be reviewed at the next Team meeting.
February 14-15, 2000

Dr. Schroeter stated that a Tentative Report with a safe as used conclusion was issued at the September 9-10, 1999
Panel meeting. He then noted that one of the ingredients included in this review, Magnesium Silicate, had been
considered talc, and that FDA informed the Panel that there is a considerable amount of data indicating that talc may
have carcinogenic potential and that this issue is being addressed. Dr. Schroeter pointed out that the structure and
CAS number of Magnesium Silicate are different from those associated with talc, and that this should be clarified in
the CIR report.
Dr. Belsito said that the fact that talc is not one of the ingredients in this review should be stated in the report
introduction and discussion, and also noted that talc will be the subject of another review by the CIR Expert Panel.
The Panel voted unanimously in favor of issuing a Final Report with a safe as used conclusion on the Aluminum
Silicate ingredient family.
Because of the number of ingredients to date for which the issue of particle size (relating to inhalation or aerosol
exposure) has been raised, Dr. Bergfeld asked Dr. Belsito to review the caveat relating to particle size that has been
included in CIR reports. Dr. Bergfeld informed the Panel that this caveat will be discussed at the upcoming Panel
meeting.
Dr. Bergfeld also noted that because it is likely that the Panel will review talc at some point, the Panel’s
prioritization of this ingredient for review should be considered.
Dr. Belsito added that it is his understanding that FDA has reviewed talc and has not found that the data warrant any
immediate action. He said that talc should be added to the CIR Priority List, but should not necessarily be added at
the top of the list.
Dr. Bailey said that there are some aspects of talc that would be of interest, more so from the perspective of setting
standards or specifications for talc in terms of particle size. He noted that the results of an NTP inhalation study
(animals) on talc indicated exposure-related carcinogenic effects that were attributed to particle size. In this study,
the particle size of the talc was smaller than that used in cosmetics. Dr. Bailey added that he has not reviewed any
comprehensive data that address the particle size of talc that is used in cosmetics (i.e., the particle size distribution).
In light of the NTP finding, he also said that in order for one to have a higher level of confidence relative to
inhalation exposure, data on particle size distribution (in cosmetics) would be very useful.
Dr. McEwen said that the NTP study results were not linked directly to the talc, but to the overload and a secondary
mechanism. He also said that the effects of talc in miners and millers of this chemical have been studied over a
period of 50 to 60 years. The magnitude of the lung effects seen in a specific talcosis is basically pneumoconiosis,
which can be identified by the crystalline structure in X-rays. Dr. McEwen added that lung cancer has never
resulted from exposure to talc itself. However, talc that is mined from asbestiform-containing mineral deposits has
been implicated in cancer, specifically, the asbestiform particulate. According to Dr. McEwen, the specification for
cosmetic grade talc indicates that it contains no asbestiform particulate.
Dr. Bailey wanted to know the extent of industry compliance with the CTFA specification for cosmetic grade talc.
He said that it would be nice to have some assurance that the standard is being implemented.
Dr. McEwen said that relevant sampling would have to be done in order to insure this.
Dr. Bailey said that the Expert Panel could request these data, and that the Panel’s efforts may be more successful
than those of FDA.
Dr. Bailey also said that another issue relates to perineal use of talc and ovarian cancer, and that, based on the
available data, FDA has not arrived at any conclusion relative to this issue.
Dr. Bergfeld said that information relating to particle size will be retrieved from CIR reports for review. She noted
that the Panel has been faced with issues relating to aerosol exposure to cosmetic ingredients, and that previous
statements regarding particle size need to be captured for future use in safety assessments.
Potassium Silicate, Sodium Metasilicate, and Sodium Silicate
December 20-21, 1999

Dr. Schroeter recalled that at the September 9-10, 1999 Panel meeting, these three silicate salts were removed from
the CIR report on these ingredients and Silicate Minerals and Clays.
The Panel issued the following informal data request:

(1) Physical and chemical properties, including octanol/water partition coefficient and impurities data
(2) UV absorption (while these ingredients are not expected to have significant UV absorption, the Panel
believes the report would be improved if these data were available rather than assumed)
(3) Gross pathology and histopathology in skin and other major organ systems associated with repeated
dermal exposures; and, if these data are suggestive, reproductive and developmental toxicity data may be
needed
(4) Dermal irritation and sensitization (what is the highest non-irritating dose?)
(5) Mammalian genotoxicity data
(6) Ocular irritation, if available; with the view of establishing the highest nonirritating dose
May 18-19, 2000

Dr. Schroeter noted that no response to the following informal data request issued at the December 20-21, 1999
Panel meeting was received:
(1) Physical and chemical properties, including octanol/water partition coefficient and impurities data
(2) UV absorption (while these ingredients are not expected to have significant UV absorption, the Panel
believes the report would be improved if these data were available rather than assumed)
dermal exposures; and, if these data are suggestive, reproductive and developmental toxicity data may be
needed
(4) Dermal irritation and sensitization (what is the highest non-irritating dose?)
(5) Mammalian genotoxicity data
(6) Ocular irritation, if available; with the view of establishing the highest non-irritating dose
He also stated that his Team determined that item 6 above is unnecessary and should be deleted from the list of data
requests.
Dr. Schroeter also noted that the hypersensitivity test on Sodium Metasilicate that is being conducted by the
National Toxicology Program study is nearing completion and that the preliminary data appear to be negative.
Concerning item 5 above, Dr. Belsito noted that the Panel has negative Ames test data on the silicate, but no test
data on the metasilicate. Thus, the Belsito Team determined that Ames test data on the metasilicate and mammalian
genotoxicity data on the silicate and metasilicate are needed.
Dr. Slaga recalled that Ames mutagenicity test data on Sodium Silicate are included in the CIR report.
Dr. McEwen did not see the need for another non-mammalian mutagenicity assay, considering that assays of this
type are included in the report.
Dr. Klaassen noted that bacterial mutagenicity data on Sodium Metasilicate are not included in the CIR report and
need to be requested.
Dr. McEwen said that based on the negative Ames test data on Sodium Silicate, it is expected that the other two
ingredients also are not mutagenic. He did not see the need for additional mutagenicity tests on either of the three
ingredients.
Dr. Belsito noted that his Team did not mention specific ingredients in any of the other data requests and asked
whether this should be done because of differences in chemical structure.
Dr. Slaga noted that the three chemicals in this review are very similar and it is possible that data on one chemical
may be used to evaluate the safety of another.
The Panel voted unanimously in favor of issuing an insufficient data announcement with the following data
requests:
(1) Physical and chemical properties, including the octanol/water partition coefficient and impurities data
dermal exposures; and if these data are suggestive, reproductive and developmental toxicity data may be
needed
(3) Human dermal irritation and sensitization (specifically, the Panel wants to know the highest non-
irritating dose)
(4) Two genotoxicity studies for Sodium Metasilicate, one of which should be in a mammalian system; and
one mammalian genotoxicity study for either Potassium or Sodium Silicate
(5) Ocular irritation data, if available (again with the view of establishing a non-irritating dose)
December 4-5, 2000

At the May 18-19, 2000 Panel meeting, the Panel voted unanimously in favor of issuing an insufficient data
announcement with the following data requests:
(1) Physical and chemical properties, including the octanol/water partition coefficient and impurities data
dermal exposures; and if these data are suggestive, reproductive and developmental toxicity data may be
needed
(3) Human dermal irritation and sensitization (specifically, the Panel wants to know the highest non-
irritating dose)
(4) Two genotoxicity studies for Sodium Metasilicate, one of which should be in a mammalian system, and
one mammalian genotoxicity study for either Potassium or Sodium Silicate
(5) Ocular irritation data, if available (again, with the view of establishing a non-irritating dose)
Dr. Schroeter stated that unpublished data from industry were received in response to the preceding announcement
and that the Panel also received additional published studies. He then noted that his Team concluded that the
available data on Potassium Silicate, Sodium Metasilicate, and Sodium Silicate are no longer insufficient for the
following reasons, addressing each item on the list of data requests:
(1) Data on chemical and physical properties (Item 1) are available and further information is not needed.
The octanol/water partition coefficient (Item 1) is not needed because these ingredients are probably poorly
absorbed through the skin.
(2) Item 2 above is not needed because there was no evidence of developmental toxicity and these
ingredients are probably poorly absorbed through the skin.
(3) Item 3 is not needed. Irritancy may be a problem, but appropriate formulations should decrease the
likelihood of skin irritation.
(4) Item 4 is not needed. On the basis of limited skin absorption, mutagenicity and genotoxicity data are
not necessary.
(5) Item 5 is not needed. Ocular irritation may be avoided by formulation in rinse-off products to create a
non-irritating product. Leave-on product cautionary statements may also be developed.
Dr. Schroeter said that, based on the preceding comments, the reasons why the data originally requested are no
longer needed should be stated in the report discussion.
Dr. Belsito noted that Sodium Silicate is used in skin cleansing products, which include cleansing lotions, liquids,
and pads (which may be considered rinse-off products) and cold creams (which may be considered leave-on
products). He also noted that Sodium Silicate is used in skin cleansing products at concentrations up to 10.0%, and
that any leave-on product containing 10.0% Sodium Silicate may be irritating to the skin. Dr. Belsito added that a
safe as used conclusion for ingredient use at this concentration in a cold cream would probably be inappropriate,
given the uncertainty as to whether or not the skin cleansing cold creams are classified as leave-on products.
The possibility of concentration limits for Sodium Silicate (up to 4.0%, based on available data) as well as Sodium
Metasilicate in leave-on products was also mentioned, taking into consideration that Sodium Metasilicate has a
different type of irritation potential when compared to Sodium Silicate. Dr. Belsito said that a concentration limit
for Sodium Metasilicate needs to be determined.
Dr. Shank noted that Sodium Metasilicate is used only in rinse-off products.
Dr. Schroeter said that the irritation potential of Sodium Silicate should be addressed by indicating in the report
discussion that products containing this ingredient should be formulated to avoid skin irritation. He did not feel that
a concentration limit should be established for this ingredient.
Dr. Belsito agreed that Potassium Silicate, Sodium Metasilicate, and Sodium Silicate are safe as used in cosmetic
products when formulated to avoid skin irritation, and proposed this statement for the report conclusion.
The Panel voted unanimously in favor of issuing a Tentative Report with the following conclusion: Based on the
animal and clinical data included in this report, the CIR Expert Panel concludes that Potassium Silicate, Sodium
Metasilicate, and Sodium Silicate are safe as used in cosmetic products when formulated to avoid skin irritation.
June 4-5, 2001

Dr. Schroeter recalled that a Tentative Report with the following conclusion was issued at the December 4-5, 2000
Panel meeting: The CIR Expert Panel concludes that Potassium Silicate, Sodium Metasilicate, and Sodium Silicate
are safe as used in cosmetic products when formulated to avoid skin irritation.
Dr. Schroeter also noted that unpublished data (clinical skin irritation studies on Sodium Silicate and Sodium
Metasilicate) considered by the Panel at its December 2000 meeting have been incorporated into the report text, and
that these data do not warrant any change in the Panel’s tentative conclusion.
The Panel voted unanimously in favor of issuing a Final Report with the following conclusion: Based on the
available data contained within this report, the CIR Expert Panel concluded that Potassium Silicate, Sodium
Metasilicate, and Sodium Silicate are safe when formulated to avoid irritation in cosmetic formulations.
Silica and Silicates
June 29-30, 2009

Presentation:
DR. ANDERSEN: The next item on the agenda is to hear from the folks from SASSI which is the Synthetic
Amorphous Silica and Silicate Industry Association. Dave Pavlich is the association manager and has a PowerPoint
presentation for us. There are limited numbers of copies, but certainly enough for the panel to look at. The rest of
you can take notes on what Dave is saying. We're going to try and get this up onto the screen. Dave, take a deep
breath and let's see what we can do.
MR. PAVLICH: As for the acronym, when I reserved the domain name I thought for sure I'd get some interesting
calls from people to buy it, but that didn't happen. I'm also sure that there are people who go to that website and
they're disappointed by what they found, and amorphous silica is probably not what they had intended to see.
The Synthetic Amorphous Silica and Silicate Industry Association is an association that has been around for a
number of years but was actually incorporated and formed in July 2007. The eight founding companies that are
listed here, J.M. Huber, Evonik, Wacker Chemical, Cabot Corporation, Rhodia, PPG Industries, PQ Corp. and W.R.
Grace, you may or may not recognize them as being the major global producers of synthetic amorphous silica, but
they are. We are also associated with a group that's a subgroup called the Amorphous Silica and Silicate Producers,
so we've done some work with them in doing research, that's a group that we're associated with and we meet with
them every year. I'm also here with two other representatives from SASSI companies, Dr. Jim Hathaway from
Rhodia, and Dr. Gregg Daum from W.R. Grace. Dr. Hathaway is going to come up here in a little bit and go
through some of the details of our comments, but at this point I'll give an introduction of why we're here.
The basic reason is that the circumstance of CIR's review of silica fits our mission particularly well, and our
association's mission is to further the understanding of synthetic amorphous silica and silicate health and safety
within the industry, to monitor the regulation of synthetic amorphous silica and silicates by government, to educate
the public and government on the views of the industry, and to consult and cooperate with state officials and state
agencies on matters having industry-wide significance, and I would add other groups like CIR. That's our purpose
here.
We'd like to thank Dr. Andersen for working with us. He did attend our spring meeting in March and gave us an
overview of the CIR process for reviewing silica, and then gave us the opportunity to review the March 25 scientific
literature review. We did send comments in on May 12 on that review and a number of those were incorporated into
the latest version of the scientific literature review, but there were a number of things that we felt were not
addressed, and those are the comments that we're going to make today. I'll highlight here seven issues that we'd like
to address, and then I'll introduce Dr. Hathaway to go through those in detail.
First of all, obviously a reason for our existence is to differentiate synthetic amorphous silica from other forms of
silica. In the SLR we definitely feel that there is a need to have fair and accurate differentiation of SAS from other
forms of silica. Also the SLR we feel needed to focus more on just synthetic amorphous silica since that's the form
used in cosmetics and limit the discussion in reference to other forms of silica. This is a document that's published
and is going to be available, and obviously SASSI members are concerned about misinterpretation of information.
Similarly, there are a number of manufacturing processes that are mentioned in the summary that are not
contemporary and do not reflect the processes that are used for commercial manufacturing of synthetic amorphous
silica, and we feel that there is too much emphasis on those noncommercial processes and the composition of the
materials from those processes. Along the same lines, those references also give some information about the
impurity levels which we feel incorrectly represent synthetic amorphous silica. In the toxicological studies that are
referenced, there are a number of factors that Dr. Hathaway will emphasize that are important in interpreting the
judging the applicability of the studies on synthetic amorphous silica. The bibliography of the SLR is very lengthy.
We feel that it's relatively comprehensive but that because of the number of studies that are referenced that there is
little effort to identify the more current information that's available and to emphasize the importance of that data.
Finally, we were relatively surprised that in the summary, the information quoted was there were 3,276 products that
contain synthetic amorphous silica and the only specific reference was to hair spray with little identification of other
cosmetic products of routes of exposure that are suspected for those products. I'll now introduce Dr. Hathaway to go
through those comments in detail. Thank you.
DR. HATHAWAY: I appreciate the opportunity to provide additional comments to the CIR expert panel. I think
the thing that we're most concerned about is having a very clear and accurate differentiation from synthetic
amorphous silica and other forms of silica particularly crystalline silica or products that contain crystalline silica.
Unfortunately, there's a tremendous amount of confusion between these that is occurring all the time. Just a couple
of years ago the insurance carriers for all of the member companies wanted to have an exclusion against any product
liability for silica. Part of the problem is there's one cast number for all forms of silica and a lot of people don't
understand the difference. Companies had to have extensive discussions with their insurance carriers. Once they
understood the difference they limited it to crystalline silica, but to the extent that the document which will be
available publicly has some confusion in it, we'd very much appreciate it if those things could be corrected so that
we don't get something else out there that misinforms or confuses the public.
Instead of using the term silica, we would prefer that every time that you're referring to synthetic amorphous silica,
that either that full term be used or that it be abbreviated SAS and be very clear that the abbreviation stands for
synthetic amorphous silica.
Also the document contains a lot of references to the other forms of silica which I don't think adds anything of
benefit to the review, and we would prefer that you have something that I'll show you in a couple more slides, a very
limited discussion of the other forms of silica, and then following that strictly limiting the rest of it to synthetic
amorphous silica.
Hopefully you can read it a little bit better in the document that you have. There are some things here that are not
quite as clear as I had hoped they would be. If you look right here, that's the form of amorphous silica, it's called
fused silica. It's essentially made by melting crystalline silica to a molten form. You form a kind of glass. In the
document this was listed as if it were the major form of production of synthetic amorphous silica. I guess it's a
synthetic amorphous silica, but it's not what goes into cosmetics. It would be a hunk of glass and it's not ground up
and put into synthetic amorphous silica at all.
Over here in this group here, that's natural diatomaceous earth from diatoms. In nature it contains about 2 to 3
percent crystalline silica and the rest is amorphous silica. The ones that are further down that list are calcined, and
when you calcine diatomaceous earth, a lot of this is used as a filter aid for filtering various products in their
manufacturing processes, you form up to 70 percent crystalline silica. There are a lot of problems with the
epidemiology studies that are talking about amorphous silica because in some cases they found cases of silicosis, but
these are ones where there was exposure to the calcine diatomaceous earth which is up to 70 crystalline silica, and so
it's very important to make a very clear distinction between what we're calling synthetic amorphous silica and these
other forms that can actually contain crystalline silica themselves.
Right here, this particular area is what we think should be the focus of the document. These are the synthetic
amorphous silicas that would be used in cosmetics. There are two essential processes here. One is the way process
that produces precipitated silica and also silica gel, and the other one is a thermal process that produces pyrogenic
silica. Unfortunately, the historic name for pyrogenic silica was fumed silica and this has the potential for
tremendous confusion. Let me just show you. Over there there's a thing called silica fume. It sounds a lot like
fumed silica. Unfortunately, silica fume contains crystalline silica. I think the person who drafted the document had
some confusion between these two and we would of course like that cleared up as well and we would strongly prefer
that the thermal process, synthetic amorphous silica, always be called pyrogenic to help avoid this confusion in
terms of terminology.
As I mentioned before on that fused silica where they essentially melt crystalline silica, this is really not a
commercial process that's used in anything that goes into there. It would probably be best that it be taken out of the
document. You can show the kind of table that we presented in the previous slide and then after that limit the
discussion to the true synthetic amorphous silicas that are used in cosmetics.
I think I've pretty much discussed both of these things already, the confusion with heating the crystalline silica to
form a type of glass, and the confusion between silica fume and pyrogenic silica.
In some of the discussion of pyrogenic silica which in the document is referred to as fumed silica, they have a
reference saying that it may contain up to 6 to 8 percent crystalline silica. We're pretty sure that was confusion with
silica fume. Then it follows immediately after that reference with a reference from Cabot saying that their stuff is
99.8 percent pure as if there's maybe some discrepancy in which one do you want to believe. The pyrogenic silica
from Cabot Corporation is indeed 99.8 percent, and any of the producers of the pyrogenic form have a very high
level of purity. The precipitated silica is less pure mostly because it contains a certain amount of water and the
pyrogenic is very dry. It appears to call into question the claims about Cabot Corporation about the purity and we
think the way these things are juxtaposed they are potentially very misleading to reader.
In terms of the toxicology studies, I think the ones that discuss oral toxicity and dermal toxicity are pretty much fine.
This is a compound that is considered safe to use in food products. In terms of skin exposure there is very little in
the way of issues. Synthetic amorphous silica can absorb water, so if you put the powder directly on your skin it
may cause some drying of the skin and some irritation. I don't imagine that this would be an issue the way it's used
as ingredients within cosmetics, however. It could be an issue in the workplace. But there is a very key thing when
we're considering inhalation or intratracheal injection studies. One of the things that creates an anomaly here is that
these products as they're produced are about 100 microns in diameter and for some applications they are milled
down into the maybe the 10 or 20 micron range, and that's actually a relatively smaller percentage of the total. Most
of the material is actually in 100 micron range or at least about 30 or 40 microns in diameter as it would be used in
most cosmetic ingredients. But if you're going to do an inhalation study and you have material that's big, anything
above 10 microns is not going to get down into the lungs. So the various groups like OECD that do the toxicology
protocols require that these things be broken up into something that averages 4 microns in diameter, and indeed all
of the toxicology studies have had to do this in order to comply with these protocols. So you get an artificial
situation where this material can now be inhaled or it can be injected down into the trachea. What happens when
this is done is you have the smaller particles that have a higher surface area and although synthetic amorphous silica
if you look up some of the references on solubility, they will say it's insoluble; everything is relative. Crystalline
silica for example is pretty much insoluble. Synthetic amorphous silica is relatively insoluble. As you get to a
larger surface area for the mass of material, you do get some of this material dissolved and it dissolves to form
silicic acid. If you do break up these particles either by dispersion or by milling or by whatever means and you have
an inhalation toxicology study, you're going to get some silicic formed on the alveoli of the experimental animals
and you're going to get some corrosive effects from the acidic silicic acid. This is not something that you would see
from even inhalation of cosmetic products or from the manufacture of these things in the protocols that workers
might be exposed to during the manufacturing process because they're just not respirable in the form that they're
being used. In a sense it's almost an artificial situation, and they do cause inhalation toxicity if they are broken up to
those smaller sizes. One of the interesting things is though that because they are somewhat soluble under these
circumstances, there are a number of clearance studies that show that this material is completely cleared from the
lungs and that the reason that the studies don't find fibrosis that you would find with crystalline silica. It's something
that we would recommend that before they go into the animal inhalation studies that they talk about this particle size
and the fact that it's an artificial situation with all of the inhalation and intratracheal toxicology studies that were
done and that you would not see this with the larger particles that are used commercially.
As Dave mentioned, the review covers an enormous number of studies. Unfortunately, there's not a lot of I guess
what you'd call interpretation of weighing of which of the studies are most significant. We would like to see a little
bit more of this done and perhaps more emphasis be given to some of the newer or more credible studies rather than
just simply listing them all and leaving it up to the reader to try to judge which ones are most important. Most of the
older inhalation toxicity studies did not discuss this particle size difference in terms of the materials being dispersed
or milled down to a small particle size, that's unfortunate, and so the abstracts don't discuss that at all, but the reader
is going to wonder which ones of these are really the correct situation. If you want, we would be willing to go and
try to give some assistance here in terms of pointing out what we think are the more reliable and credible studies.
As Dave mentioned, we were surprised that there wasn't more discussion of the actual applications in cosmetics.
That really is not a big issue with us, but it's something that you might want to consider in terms of improving the
document. Here we have the spelling of our names and our website and so forth.
I'd be happy to address any questions that any of the panel members have.
DR. SLAGA: Just to have it straight, the 100 percent that is supplied to the cosmetic industry is between 10 and 100
microns?
DR. HATHAWAY: Correct.
DR. SLAGA: And only in some of the studies did an inhalation was it at 4 micron?
DR. HATHAWAY: Correct. They either break it up and disperse it some form or mill it down to that smaller
diameter so it can get in there. In fact, in order to comply with the testing protocols they have to do this even though
it's not representative of the material that would be involved in worker exposure or consumer exposure.
DR. LIEBLER: I appreciate the silica family tree that you provided us. I think it's helpful in organizing our
thinking about this. I have two questions that relate to this. One is are there any sort of milestone dates in terms of
synthetic amorphous silica manufacturing processes that would be useful in helping us interpret some of the older
literature? In other words, in the 1970s or 1980s or sometime were there any changes in manufacturing processes
that yielded the materials that are used in cosmetics now?
DR. HATHAWAY: I'm going to go out on a limb and make some guesses. I'm thinking that these processes
probably were introduced in the 1950s or earlier. There is certainly much more production now than there was in
that timeframe. But many of these articles that are from the 1950s to the 1970s still are talking about older
processes and maybe there was some use of this glass that was formed from melting crystalline silica and I'm not
sure what it would be today. I think a relatively small amount of these materials go into the cosmetic field. I know
of the stuff that our company produces probably 80 percent goes into tires to reduce rolling friction and most of the
other 20 percent goes into toothpaste, so relatively small amounts go into the cosmetic industry, but it's probably
widely used in a lot of products.
DR. LIEBLER: It doesn't sound like there's a clear dividing line of any sort in the manufacturing process that would
be helpful to us.
DR. HATHAWAY: Unfortunately not, but I would say the studies that would have dates after 1990 certainly would
be probably more credible than ones that had dates before that.
DR. LIEBLER: I have one other question. What is the analytical method that's used to determine the content of
crystalline silica in a background of synthetic amorphous silica?
DR. HATHAWAY: Usually this would be a microscopic thing. I was recently at our plant that manufactures this
and even though we expected to find no crystalline silica, we went ahead and had some industrial hygiene sampling
done at the site to reassure our own employees, and they do a microscopic analysis for the three forms of crystalline
silica and they found nondetectable levels at extremely low levels, whereas when they measured total particulates
which would include the larger particles, indeed there was a certain amount of dust exposure during the
manufacturing process.
DR. LIEBLER: So the analytical methodology then probably would have been the same for a long time if you say
it's microscopic evaluation?
DR. HATHAWAY: I believe so, yes.
DR. LIEBLER: So you're counting particles in microscopic fields. Right?
DR. HATHAWAY: I believe so, yes.
DR. BELSITO: As you may or may not be aware, and I guess that's my question, we're already issued two prior
reports on silicates and this is the third to capture all of the ingredients that we failed to capture before. Did you
have the opportunity to review those two prior published reports?
DR. HATHAWAY: This would have been before the one that came out in March?
DR. BELSITO: Yes. This is before this SLR.
DR. HATHAWAY: I don't think we were aware of that. Dave, were you aware of anything?
MR. PAVLICH: No, we haven't seen that.
DR. MARKS: In the manufacturing of the cosmetics, are there any physical changes that would occur as with a
natural amorphous silica where there would be more crystalline silica produced in the end product or the use?
DR. HATHAWAY: I'm not familiar with how they're done in cosmetics. I would assume these are simply
blendings, and unless you have a process that introduces very high heat, I don't believe you'd form any crystalline
silica.
DR. HILL: I want to get clarification in that regard. So if they were truly amorphous rather than crystalline and
they were inhaled because it was in some powdered product or some spray, what we would expect is dissolution to
silicic acid and the lung is able to clear that and you'd probably talking about small amounts where there wouldn't be
a toxicity issue. Is that what I heard you to say?
DR. HATHAWAY: I have a hard time imagining very much is going to be inhaled from any cosmetic use.
DR. HILL: Clearly not toothpaste.
DR. HATHAWAY: But even hair spray I have a hard time imagining.
DR. HILL: Because of the particles produced by the spray.
DR. HATHAWAY: There was one reference in the review that talked about hair spray and I believe that they said
that the particles were in the 30 to 50 micron range for that particular product which is way above the respirable size
and I would imagine that the proportion that might be below 10 would be very, very small. Most of the things that
we've looked at have been at least 99 percent above 10 in terms of total mass of the dust. So these the amount of
fines that might be below 10 is going to be below 1 percent and I would suspect considerably below 1 percent.
DR. HILL: And what is produced under those circumstances you're telling us that the lungs should be able to clear?
DR. HATHAWAY: Even when they used very large amounts of the dispersed material, this clears in the lungs. I
think the half-life is less than 30 days even with a significant amount. Between SASSI and ASAP, the European
equivalent of ours, we've done these dissolution studies to demonstrate this. There is also a study of three German
manufacturing for synthetic amorphous silica in terms of epidemiology studies where they're looking both at
pulmonary function and chest X-rays and I believe this is in the process of being written up for publication and
they've found no evidence of any fibrosis.
DR. MARKS: There was one reference in which Epstein in the early 1960s injected colloidal silica subcutaneously
and developed granuloma formation. Is this an example where we don't really know what was in that colloidal silica
that was not synthetic amorphous silica?
DR. HATHAWAY: I'm really not sure. Colloidal sounds like it would probably be amorphous, but I have a hard
time knowing. I'm not familiar with that particular article.
DR. MARKS: Can you comment about granuloma formation?
DR. HATHAWAY: There are an awful lot of things that can cause granulomas. If you implant a diamond in a rat
you're going to get granulomas forming. I'm not sure it's directly related to any kind of an inhalation type of toxicity
or exposure to the exterior of the skin. There are lots of things just because of their geometric shape and so forth
will cause granulomas in experimental animals especially rats. When I was in the Army and we were looking at
issues with the safety of Kevlar for bulletproof vests, they implanted some Kevlar in the rats and you form
granulomas around them.
DR. MARKS: I was thinking more in terms of application to damaged skin.
DR. SNYDER: Related to slide 7, the reliability of the studies, do you have additional data that you could provide
us that are not in the reports?
DR. HATHAWAY: We provided two documents that are relatively recent and I think pretty thorough reviews of
the issue. One of these is called the Jack Report that was produced in Europe. It's a very, very large document.
Then we recently produced another document that I think is around 50 pages long that's maybe a condensed
summary of a lot of that information and we did this as a voluntary effort with the Environmental Protection Agency
because they're concerned about nanoparticle issues. In the manufacturing process, you start off with nanosized
amorphous silica and it forms aggregates and then agglomerates to get up to the 100 micron size so the primary
particles are nanosized and this was the reason that we provided that summary. It's a shorter summary but I think it
covers the manufacturing processes very well. There are pretty good summaries on the epidemiology and the
toxicology studies. It also talks about the bonding of the agglomerates. These things do not break up under normal
circumstances. You have to go to pretty significant mechanical forces to get these things to break up into smaller
particles. Thank you very much.
Belsito’s Team Meeting:

DR. BELSITO: Okay, Silica and Silicates. Now, folks, we've really got to concentrate on this because the Marks
Group report's in public session, and we got to get ready to attack them.
Okay, so this is -- we got some pages here, information that was not in the book, unpublished data, and basically it
was two human studies, 27 individuals each, exposed to 17 percent concentration of hydrated silica with negative
sensitization.
And then we got a guinea pig sensitization study on hydrated silica -- the shortest study I've ever seen, or at least the
shortest summary -- and this was 10 percent in distilled water with a challenge that induction from 1 to 20 percent,
and that was on 10 animals, and that was negative.
And then we got a summary from the FDA on line just lots of data that I didn't think had added anything to the
report.
And then we had a rather SASSI talk this morning, so hopefully you've heard more than you need to hear already
today on silicates.
And so the question here is, what are we -- where are we going with this? And I thought probably, you know, safe
as used, I sort of did agree with the comments this morning that we need to be very careful about the amorphous
silica because I got like really confused reading the document as to where we're going.
And I guess the other questions I have are, how do we handle these prior reports from 2003 and 2005? Do we want
to lump them now? Do we want to wait till 2018 when the first 2003 report comes up for re-review, and then lump
them all together? Or where do we go with those? And table 10 was missing from my document.
SPEAKER: (off mike)
DR. BELSITO: Table 12 was where -- table 12 continued was where Table 10 was supposed to be, so --
MS. BECKER: Right. So table 12 continues -- started a page early.
B - SPEAKER: Microphone.
DR. BELSITO: Oh, so table 12 on page 78 is really table 10.
MS. BECKER: Correct.
DR. BELSITO: And table 12 continued belongs after belongs after table 12? Okay. Or is table 12
continued -- really Table 10? Which one is table --
SPEAKER: The first table 12 continued on page 78, the table --(off mike).
DR. BELSITO: Oh. So it's really not table 12 continued. Oh, okay, good. Well, that helped me out there.
(Inaudible chatter) I thought I was Hebrew reading from right to left.
Okay, those are my comments. Curt and Paul?
DR. SNYDER: So all of that data, that other data has been added in?
MS. BECKER: Everything's in.
DR. SNYDER: That's everything?
MS. BECKER: That I have except for what just this little bit you got handed.
DR. LIEBLER: I would quite agree with the revision suggested in the staff, the presentation this morning, on
clarifying the definition of the form to use and minimizing the emphasis on crystalline silica.
DR. BERGFELD: Minimizing or deleting?
DR. LIEBLER: Excuse me?
DR. BERGFELD: Minimizing or deleting.
DR. LIEBLER: Minimizing.
DR. BERGFELD: Do you think leaving it in leads to confusion?
DR. LIEBLER: No, I -- well, I got the impression that it's good to know that what is being discussed is not
crystalline silica.
DR. BERGFELD: That will be really a very great delete.
DR. LIEBLER: Very brief, right, minimizing.
DR. BELSITO: And probably just summarizing that a) we're not talking about crystalline silica, and so that means
things in the nature of silicosis, pneumoconiosis, those types of issues that people associate with silica are going
away.
DR. LIEBLER: Exactly. But if you don't mention that, if you don't mention it's not crystalline silica, then people
are going to get confused and asked why you're ignoring all that stuff.
DR. BERGFELD: But there are a lot of citations here that --(off mike).
DR. LIEBLER: Yeah. And I guess I had a question, in the older literature where it may not have been clear what
form of silica was actually used in some of these older studies, and what effects are valuated? Should those studies
be included?
That's why I asked the question this morning, was there any milestone or change in manufacturing process that
would have sort of invalidated earlier studies, because the material that was tested was no longer applicable to
current cosmetic use. And it sounds like it's not that straightforward.
But where it's not clear that the material study was the material that is used in current cosmetic use, I think that stuff
should be deleted.
MS. BECKER: Whenever I was unclear on whether it's crystalline or amorphous, I left it out. I only did thinks I
could definitely say were amorphous from the test to this paper.
DR. BERGFELD: You have the fume silica. Fume silica, that would be one of --
MS. BECKER: If they called it fumed silica. If it says silica fume, I never saw that.
DR. BERGFELD: Okay, but --
MS. BECKER: But I saw fumed silica.
DR. SNYDER: That's all the tox data, is fumed siliar.
DR. BERGFELD: But that's different from the crystalline form, then.
MS. BECKER: I guess.

DR. BAILEY: I would recommend taking from the presentation this morning that in some detail the
characterization and definition and so forth, and put that into the appropriate part of this report, because there is a
huge amount of confusion. And your assessment will be for the synthetic amorphous silica. And I think you need
to, in the discussion, strongly make that distinction and separate from the crystalline silica, because this is an area
where there's so much confusion, and the terms used and, you know, questions about silicosis and, you know, being
related to silicos used in cosmetics. That really needs to be clarified.
And your expectations need to be clarified that we're talking about, you know, that we're talking about the, you
know, synthetic amorphous silica in the process.
DR. BELSITO: Right. But as Paul pointed out, you know, a lot of the studies, and I guess what really threw, you
know, a monkey wrench into -- and again I think it's safe as used -- but I mean I think you want to present the
correct data and not incorrect data that you have to argue against: Was the fumed silica versus silica fumed, and one
is actually crystalline and not amorphous, and the other is amorphous.
DR. BAILEY: Right. Right, exactly.
DR. BELSITO: And so when we're referring a lot of the studies in here is a fumed silica which -- is that silica
fumed or fumed silica? Is it amorphous, or is it crystalline?
And, you know, I don't -- you know, based upon that, I don't know how to proceed with this. Should we --
DR. HATHAWAY: Can I make a --
DR. BELSITO: Yeah. (Chatter -- inaudible)
DR. HATHAWAY: Unfortunately, there's different categories of amorphous silica. What's used in the cosmetics
are synthetic amorphous silica, and there is the two processes, you know, the wet and the thermal that was described.
There is also a whole bunch of other things that are called amorphous silica that typically contain a certain amount
of crystalline silica. And so that adds to additional confusion. You have the diatomaceousers which contain a little
bit to start with.
When they're calcine they contain a lot. And then you have on the other side of the other amorphous ones is silica
fume, which is usually called an amorphous silica, but it contains a certain amount of crystalline silica.
So it presents a potential point of confusion, and we offered to work with -- I forget your name --
MS. BECKER: Lillian.
DR. HATHAWAY: Lillian -- you know, to try to come up with some, you know, perhaps a better way of presenting
the characterization of the material, you know, early on in the report.
DR. SNYDER: I think that's a good idea.
DR. BELSITO: So should we table this --
DR. BERGFELD: Yeah.
DR. BELSITO: -- and ask Lillian to work with the SASSI -- but we don't want to get too sassy in the process,
Lillian -- and go through and look at each of the references that are here and make sure that a) that when they're
talking about fume silica, it's the amorphous and not the crystalline.
And then spoof up the document and have it come back to us with the notion that at least I'm comfortable, Paul and
Curt, with the idea that this is going to be safe as used, but we want the information in the document to be what is
actually used in cosmetics and not what is not used in cosmetics or --
Lillian, do you feel that you've already done that --
MS. BECKER: I --
DR. BELSITO: -- or were you confused by their presentation?
MS. BECKER: I was. That's one of the things that took me so long in getting started on this particular -- was going
through and combing through all of that and figuring out what was amorphous and what was not.
DR. BELSITO: Okay.
MS. BECKER: And all I have to go on is what, you know, the writers wrote. And what the writers wrote I did
quote in there. If they say colloidal, I put it in there; if they say silica so I'll put it in there so that I did not
interpretation other than its amorphous or not.
So unless they know something I don't know about the papers, I don't think I can -- you know.
DR. BELSITO: Okay.
DR. BAILEY: (off mike) -- these are really editorial changes. I mean they may be more editorial than we're maybe
used to, but I think if you feel comfortable with the, you know, conclusion, and working with SASSI folks to make
these corrections and editorial changes, that, you know, we would -- I would recommend going ahead and giving
your conclusion and moving the documents forward.
DR. BELSITO: Okay.
DR. BAILEY: With the idea that you'll have a chance to look at it, you know, with those editorials when corrected.
MS. BECKER: And then when we get through, it might be more clear –
DR. BELSITO: Okay.
MS. BECKER: -- without the --
DR. BELSITO: So, then, why don't -- well, then, the suggestion is we move forward, tentative final, safe as used.
Lillian will get together with the SASSI people for editorial corrections, and I guess I would like to see done what
was done for the cyclomethicone report where there are comments that we should delete something that is currently
in here. If they could keep it, then just underline that whole paragraph with a comment that, yeah, in review we're
recommending this be deleted because in reality it was not amorphous silica, and then we can say, oh, okay. You
know, rather than just having a whole bunch of material disappear from this document and us now knowing why it
disappeared.
DR. BERGFELD: Well, can I offer another suggestion that maybe, when they're working on their draft, that they do
that? But then they give us the second draft of deleting all of that, because I think it's going to be confusing with all
that fume stuff in there. It's everywhere.
DR. SNYDER: But isn't the fume silica the pyrogenic silica which is one of the forms of a --
DR. BERGFELD: Well, maybe. You did say, Dr. Hathaway, that some of that had a high crystalline level.
DR. SNYDER: That's silica fume.
DR. BERGFELD: I know. I know. I know, but --

DR. HATHAWAY: Unfortunately, the two terms are very similar. That's why, you know, and the editorial changes
we would strongly recommend that you use the term "pyrogenic" instead of fume silica. We're trying to do that in
the industry to, you know, avoid that confusion.
DR. ANDERSEN: Don, I think with due respect to the industry input that we've received today, I'm not prepared to
turn this report over to industry for writing it.
DR. BELSITO: Well, I don't think for writing, but for comment that we can review.
DR. ANDERSEN: Comment can be made by any interested party when the tentative document is issued for public
review. If we get some further input, I'd love to receive that.
DR. BELSITO: Okay.
DR. ANDERSEN: But there is nothing that I’ve heard in terms of fundamental flaws that says this should stop.
Should we include up front maybe a further glossary that explains to the reader that some of the terminology you're
going to be seeing may look strange, and, in fact, the current preferred term for fume silica is pyrogenic silica. We
can put that up front so that the explanation is provided.
But if the author of the published study called it fume silica, we can't recreate what was said in that published study.
The fact that we think that's pyrogenic silica, you can in fact state positively that we think it is.
DR. BELSITO: Okay.
DR. ANDERSEN: That's a fine way to deal with it. But I don't -- I'm not hearing anything that says that there is a
fundamental flaw in this document. The data that are there don't raise particularly any safety issues. It is axiomatic
that we must be clear that this is not a safety assessment of crystalline silica.
DR. BELSITO: Mm-hmm.
DR. ANDERSEN: So however we do that, you know, it's going to be like teaching high school history: Tell 'em
what you're going to tell 'em; tell 'em and tell 'em what you told 'em. If we don't say it that many times, we will not
have done our job. So we can look at it from that point of emphasis, but unless there is a study that's included in
here that is known to be crystalline silica and shouldn't be in there, there's nothing to deal with here.
DR. BELSITO: Okay. So then we're not going to make any changes, except to perhaps a little stronger emphasis in
the --
DR. SNYDER: Prologue.
DR. ANDERSEN: Except to be responsive to Dan Liebler's --
DR. BELSITO: Right.
DR. ANDERSEN: -- point about minimizing the crystalline silica part, that I don't have a problem with that.
DR. BELSITO: Mm-hmm.
DR. ANDERSEN: But that is indeed, as John pointed out, it's editorial. And that's just a level of finessing this that
is important. I mean I think we heard clearly this morning that to any reader they better see clearly the focus of this
is away from crystalline silica.
DR. BELSITO: Okay.
DR. ANDERSEN: I think we're very close to that anyway, but a little more emphasis can't hurt.
DR. BAILEY: I mean I -- from the industry's perspective, I would like to see this document, you know, set sort of a
framework for future use of terms, and understanding of what is what. A glossary would certainly do that.
DR. BELSITO: Okay, sure.
DR. ANDERSEN: It could help.
DR. LIEBLER: You had a figure 1 that's sort of like what I called the silica family tree –
DR. ANDERSEN: Right.
DR. LIEBLER: -- earlier in this morning's presentation. And I think, you know, maybe sitting here with a couple
cups of coffee and listening to it here to get off to the second time made it more clear to me that there were some
nice distinctions that emerged from this morning's presentation that I just didn't get first time reading it. And that
might have been me, not you, but I think it's worth making the point about pyrogenic silica being -- also being called
in the literature "fumed silica," and how that can lead to confusion of that material with "silica fume."
And if that can be briefly explained in the introductory material so that it allows, then, the reader to go to the
original language in the literature report and not be baffled.
DR. BELSITO: Right. Okay.
DR. ANDERSEN: That works.
SPEAKER: That we know how to do.
DR. BELSITO: Okay. And then just to get back to my prior point about we have two prior reports out, the 2003,
2005, do we want to collapse all of those ingredients into this report? And then a final point is in one of those two
our conclusion was when formulated not to be irritating. In this series of reports we really don't have any data to
suggest that these materials are in fact irritating when used.
But now this will be the third silica document. One I think was safe as used, and one had a conclusion that -- that
potassium, sodium, and silicate is the one that says "when formulated to avoid irritation." And then the other one
was just "are safe as used in cosmetic products."
DR. BERGFELD: You could -- you could handle that with "should not be irritating in the product." I mean like we
did before.
DR. BELSITO: I understand that, but my point, Wilma, is that in this current document --
DR. BERGFELD: Yeah.
DR. BELSITO: -- with these current ingredients, we have no data to suggest that irritation is, in fact, the problem.
And, in fact, the irritation that we had --
MS. BECKER: Was only with the potassium study only.
DR. SNYDER: Sodium potassium.
DR. BELSITO: -- was only with potassium, sodium --
DR. BERGFELD: Silica.
DR. BELSITO: -- metasilicate and sodium silicate.
DR. BERGFELD: Which was the --

DR. BELSITO: And that was, you know, I think because we had data as in all cases where, you know, 100 percent
there was some irritation or something, and this was back when we -- I don't know what we were doing -- but so if
we don't combine these documents, then we're going to have two reports on silicates that say safe as used, and one
that says safe as used when formulated not to be irritating.
And it's just, to me, if I were not on this panel, and I'm looking, okay, so what's the difference between calcium and
sodium silicate, and why can one be safe as used and one only be safe as used when it's formulated not to be
irritating?
DR. ANDERSEN: Well, I think that the answer is not in this report, but the answer is in fixing the other report. The
only data that suggested a concern was actually sodium metasilicate.
DR. BELSITO: Right.
DR. ANDERSEN: And the conclusion could have focused on that ingredient in the earlier report; we just didn't do
that. But all of the other simple salts were not irritating, continuing the pattern. So I don't think that you lose
anything by not perpetuating the problem here but rather when we come back to the previous report fixing it. Or if
industry is particularly concerned, they can suggest an amendment as needed to the earlier safety assessment.
DR. BELSITO: Okay.
DR. HATHAWAY: I might be able to add a little bit of clarification. The sodium metasilicate is a very alkaline
material, and that may be the reason why in some formulations, if it's not very careful to adjust the overall pH of the
product, you could end up with an irritating situation. We really didn't comment on that; we focused really only on
the synthetic amorphous silica things, but that's probably why it was there in the older ones.
DR. BERGFELD: And our summary from the older document mentions that.
DR. BELSITO: Okay, so we're going ahead with the safe as used. We're going to do -- clean just as little bit,
strengthen the introduction to clarify exactly what we're looking at, the fume versus fumed silicate -- silicate fumes,
and, I gather from what Alan said, we're not going to add in the ingredients from the reports we previously did, we're
worry for the 2018 people.
So you'll remember this discussion, Wilma, in 2018.
DR. BERGFELD: Me, too.

Marks’ Team Meeting:

DR. MARKS: Okay. Let's move on. We've got another non-contentious ingredient named silica.
SPEAKER: Lillian will come up.
DR. SLAGA: I recommend we table this.
DR. MARKS: Okay.
DR. HILL: And I second that.
DR. MARKS: Let me see -- and I'm the one that --
DR. SLAGA: It's too complicated. Unless all these things are changed and number two, I would like to see us
relook at -- even if informal -- the other two that we -- has been approved in the past.
DR. MARKS: Well, one of --
MS. BECKER: (off mike)
DR. MARKS: Go ahead, Lillian.
DR. SLAGA: Why?
MS. BECKER: I'm just trying to catch up, so I think I'm just going to sit in while I listen here.
DR. SLAGA: Because I think somewhere (off mike).
DR. SHANK: But they're already finished.
DR. MARKS: No. Not -- actually nothing was said. Basically the suggestion was made that this be tabled so we
can go ahead and integrate the presentation we heard this morning. Thank you. And then also look at the two
previous safety assessments that were done and, in fact, one of the -- the potential suggestion --
DR. SLAGA: Well, even Belsito wanted them to look at those two. I mean --
DR. MARKS: Yeah.
DR. SLAGA: -- because that'll be brought out tomorrow, I'm sure.
DR. MARKS: Well, one of the potential tacts I thought was we just reopen the old safety assessments and group all
of this together.
DR. SLAGA: That could be wise.
DR. MARKS: And that could be -- so it could be tabled with that idea also as to consider do we group all -- all of
the safety assessments.
DR. SLAGA: Who's presenting this one?
DR. MARKS: I'm tomorrow. So it will be easy if it's tabled. But I should think we need to know what we want
other than obviously integrating the data we've heard today.
MS. BECKER: Well, of the data you heard today, the papers that they talked about are already integrated into the
report. I got the information in time to integrate it for you guys. So you've already read everything they've given us.
DR. SLAGA: Oh, okay. It's been changed over what they were --
MS. BECKER: Right, right.
DR. SLAGA: Oh, okay.
MS. BECKER: Yes. They gave me the stuff -- I already -- I stayed up late at night putting all this stuff in so you
guys could have it. You have it.
DR. SHANK: You made it clear about the crystalline versus amorphous. Is that what you're talking about?
MS. BECKER: Um.
DR. SLAGA: I didn't think that was --
DR. MARKS: Yeah, it's in the introduction -- the second paragraph. It's very clear. There are two
categories -- crystalline and amorphous -- and only the amorphous ones are used in cosmetics. That's page one.
DR. HATHAWAY: Part of the problem is that a lot of amorphous forms are not used. It's really only the synthetic
amorphous forms. And -- you know -- we would appreciate it if even though the data is in there, particularly the
section on the silicas -- you know -- I think it could be clarified so that it would be a lot less confusing to other
people. It may not affect your safety assessment, but since it would be a public document -- you know -- we would
like it to be -- you know -- as straight forward and easy for -- you know -- someone else to read and understand it.
MS. BECKER: When I was going through all the papers in many papers it is very difficult to figure out which type
of silica it was and I gave their -- the author's description of the silica as given and that is clear as I can make it. If
you know something I don't as in -- you know -- we know this guy only worked on this type of silica, which is never
used, we could -- you know --
DR. SLAGA: We probably don't know that.
MS. BECKER: We don't as far as I know.
DR. SLAGA: I would based on the (off mike).
DR. MARKS: (off mike)
MS. BECKER: But, I used the description of the authors provided.
DR. HATHAWAY: No, I understand that. The confusion comes as I mentioned this morning. This one amorphous
silica that's formed by melting crystalline silica -- you know -- ends up forming a solid object, you know. Maybe it
doesn't become a glass like this, but it's a type of glass. So it's not really relevant to this and then the confusion
between silica fume, which is considered another amorphous form but has a certain amount of crystalline silica in it
and the pyrogenic silica -- that a synonym is fumed silica -- you know there's a problem there. You know we would
just like -- we would very much appreciate it if -- you know -- all of these terminologies were clarified so there
would be not confusion on the part of an outsider reader and -- you know -- we're willing to work with you to try to
get that squared away.
SPEAKER: We can do that. We can help.
MS. BECKER: Yeah, because as far as -- my information -- with the information I have, it's as clear as I can make
it. So if you've got better information --
DR. SLAGA: Some of the publications won't be clear. That's -- I think that's the point you make.
MS. BECKER: Yes.

DR. ANSELL: Well, a lot of them do have scriptors -- precipitated study, aerosols, silica, undescribed, (off mike)
silica. Perhaps we could clarify --
DR. HATHAWAY: No. There's no question the revision is a lot better than the -- than the initial draft, but there's
still, we feel, could be improved to avoid -- you know -- confusion by people reading it.
SPEAKER: Well, I --
DR. ANSELL: Could you identify which of these are the cosmetic silicas as opposed to the (off mike) silicas?
DR. HATHAWAY: Correct. Yeah.
DR. SHANK: Inclusion of that flow sheet that you gave us this morning would be helpful.
DR. MARKS: It is actually in there.
MS. BECKER: It is in there.
DR. MARKS: Page 62. Yeah. It's page 62.
DR. SHANK: I forgot that.
DR. MARKS: Yeah. It's in there which -- so I think we're -- if we decide to issue a tentative report, that gives the
opportunity for you to comment and do some of this suggestions you have.
DR. HATHAWAY: I mean -- yeah. I mean if you'd be willing to -- you know -- have us work with you --
MS. BECKER: Um-hmm. Sure.
DR. HATHAWAY: I think the section on describing the forms of silica is an area that we would like to see
changed.
DR. MARKS: Sure.
DR. HATHAWAY: And maybe some introduction on the inhalation intratracheal thing on particle size -- you
know -- just to clarify. I mean you have it in there, but it was right at the very beginning -- you know -- that kind of
prefacing all of these studies, even though many of the studies may not have specifically referenced particle
size -- particularly some of the older ones.
DR. MARKS: And sometimes that appears in the discussion and the discussion at this point hasn't actually been
written, so these nuances are often included in the discussion to put it in perspective. So that can -- all that can be
done.
MS. BECKER: Yeah. The inhalation boilerplate is in there.
DR. MARKS: Yeah.
DR. HATHAWAY: On the form (off mike) size?
DR. MARKS: Yes.
DR. HATHAWAY: Okay.
SPEAKER: Let's help through the discussion focus on the most relevant studies versus (off mike).
SPEAKER: Dr. Marks?

DR. MARKS: Yes.
SPEAKER: May I make an administrative request here --
DR. MARKS: Sure.
SPEAKER: -- which is that we do have an administrative process which includes a time period during which
comments are solicited and welcome and we really would like people to submit valuable comments -- to submit
them during that time frame, not afterwards. Because that really messes up our process and it doesn't allow us to
incorporate the changes in a timely way so that you can see them before the panel meeting and the panel can see
them.
DR. MARKS: Right. And that's a 60 day time period, so we'll have plenty of --
SPEAKER: Well, okay -- wait -- yeah -- we --
DR. MARKS: -- plenty of time to add these wording. We haven't even seen the discussion on this. We are
basically today to decide --
SPEAKER: Okay.
DR. MARKS: -- one, do we want to issue a tentative safety assessment.
DR. PAVLICH: As we understood the process when Dr. Andersen visited, we were given the opportunity to look
at the first draft of the scientific review and we sent in our comments and then he told me that we probably wouldn't
have a chance to get those comments incorporated into the review before this meeting and therefore just to come and
give our presentation. So that was our -- that's how we understood the process. So -- I mean -- we had these
prepared last week, but we -- our understanding was that it wouldn't make it any difference if we sent them in early
or not.
SPEAKER: Not the case (off mike).
DR. PAVLICH: Not the case.
DR. MARKS: Okay.
DR. PAVLICH: We stand corrected.
DR. MARKS: So, Ron, Ron and Tom -- Ron, Tom and Ron -- whichever way I want to go is -- do you want to
move this forward to make a conclusion on these ingredients as a cosmetic ingredient and keep it as such? Do you
want to group this with the other reviews (off mike)?
DR. SLAGA: Well, based on a lot of changes have already made, there's -- we can do it with the others later. We
don't have to deal with them (off mike).
SPEAKER: She can't hear you.
DR. SLAGA: I think we have to deal with this --
DR. MARKS: Okay.
DR. SLAGA: -- and right now, I don't think we have to based on what we have already heard that we have to deal
with the other two that have been already out in literature.
DR. MARKS: Is there -- so can the conclusion be safe?

DR. SHANK: Yes.
DR. MARKS: Okay.
DR. SHANK: With one question. The iron -- the which is it called -- aluminum iron silicate. We have almost no
data on any of the metal silicates. But calcium silicate, sodium silicate -- that doesn't bother me. But the adding
aluminum iron -- especially if it's inhaled with a high oxygen content of the lung -- the iron atom could produce
oxidative damage which would not be expected by any of the other silicates. So I would not include aluminum iron
silicate without data. The others I can add. That's the only change.
DR. MARKS: So that would be insufficient?
DR. SHANK: Insufficient for -- well, these are add- ons, aren't they or whatever?
DR. MARKS: No.
SPEAKER: No. It's the original assessment.
DR. SHANK: So it would be insufficient for the aluminum iron silicate and you'd need inhalation data unless -- you
could say since it's not respirable.
DR. HATHAWAY: Well, I don't think any of our member companies produce that compound, so I don't have any
information.
DR. SHANK: Okay. We had no data on it. But if it's -- if it's not respirable, then it's not a problem.
SPEAKER: I have no idea what the (off mike) for that is.
DR. SHANK: But, since we have no data on it, we would need some data.
SPEAKER: That's a good compromise.
DR. MARKS: So we'll move that this be a tentative safety assessment and it's these ingredients are safe with the
exception of aluminum iron silicates, which would be insufficient data --
DR. SHANK: Inhalation needed.
DR. MARKS: Yeah. We need the inhalation.
DR. SLAGA: Unless that can be shown --
DR. SHANK: Well --
DR. MARKS: Yeah.
DR. SHANK: -- if it can show it's not inhaled then --
SPEAKER: Unless someone shows (off mike).
DR. MARKS: So we'll issue a tentative safety --
DR. HILL: And I'm answering a question while you're writing sort of from this morning is -- and I'm thinking in
particular of hairspray formulations where there -- the amounts are small anyway. I understood you to say that as
manufactured -- according to your knowledge -- there are large enough aggregates that even assuming that whatever
liquid accompanied the droplets evaporated before somebody inhales this, that the particle sizes are still too large to
go any farther than the trachea. So I --
DR. HATHAWAY: Correct. When they're -- when they're in a solution -- whether it's aqueous or a combination of
other solvents or whatever -- it's not going to disaggregate.
DR. HILL: So then my question became at least based on your knowledge of the companies that are manufacturing
this stuff, that are in products available to Americans at least, that there are no nanosize particles -- anything smaller
than four microns that are fines -- what we always called fines working with silica in the lab -- in products as they
are manufactured, but the finished products -- the hairsprays and such.
DR. HATHAWAY: We ran it by -- you know -- the companies on both sides of the Atlantic. Initially we had down
there 16 to 100 microns because that's pretty much what all the people on this side had and they recommended we
drop it to 10, because I guess they must have some products that are down closer to 10.
DR. HILL: Okay. Okay.
DR. HATHAWAY: But -- you know -- we checked with -- you know -- the eight companies are the same
companies on both sides of the Atlantic. They may have different plants and have -- you know -- slightly different
product mix, so we certainly checked with all of the European and the North American manufacturers.
MS. BECKER: Could we get a letter or memo saying that so I can put it in the document?
DR. PAVLICH: It's in the -- it's in our summary. Ten to 100 was quoted in that summary.
MS. BECKER: Okay. Thank you.
DR. MARKS: Okay. Any other comments? We'll issue -- we will move -- I will move since I'm the one that will
be presenting this -- issue a tentative safety assessment with a finding that aluminum magnesium (off mike)
aluminum calcium, sodium silicate, hydrated silica and a sodium potassium aluminum silicate are safe for use in
cosmetic ingredients. And that the aluminum iron silicates -- there's insufficient data and we need the inhalation
data to decide whether that's safe. And, Ron, if there's any discussion --
DR. SHANK: Unless it's in the 10 to the 100 --
DR. MARKS: Well, that would be essentially the --
DR. ANSELL: Yeah, that would be formulated to be nonrespirable.
SPEAKER: Do we have anything you want in the discussion other than inhalation?
DR. SHANK: Did Lillian catch what we just said?
DR. ANSELL: And formulated to be nonrespirable.
MS. BECKER: Yes. Writing it down.
DR. MARKS: And we can use the same words as they used in the 2004 report.
SPEAKER: Just finishing silica.
MS. BECKER: For which?
DR. SHANK: In the discussion for this document, you can just use the discussion on inhalation with cosmetic
sprays --
MS. BECKER: Okay.

DR. SHANK: -- that we used in 2004 --
MS. BECKER: Okay.
DR. SHANK: -- which was the potassium and (off mike).
MS. BECKER: Alright. That works for me.
DR. MARKS: Okay. Any other?
SPEAKER: Anything else?
DR. HATHAWAY: Just to say that although I mentioned hairspray, face powders is in here. So this is a totally
theoretical question.
SPEAKER: Alright.
DR. MARKS: Not really. Thank you very much for your patience and comments.
SPEAKER: Thank you.
SPEAKER: Thank you.
MS. BECKER: Thank you.
SPEAKER: Very helpful.
DR. MARKS: This morning and also right now. Thank you.
DR. PAVLICH: Good. Well thank you for having us.

Full Panel Meeting:

DR. BERGFELD: We're going to move forward then. This (off mike) this table to answer the questions that have
been so stated, and we'll be moving on to the next group, Dr. Marks presenting on silica and silicates.
DR. MARKS: In the March meeting of the CIR Panel, a scientific literature review was announced, and we're now
seeing the draft report on silica, alumina magnesium metasilicate, aluminum calcium sodium silicate, alumino-iron
silicates, hydrated silica, sodium potassium aluminosilicate. And we had the presentation yesterday by the SASSI
group clarifying the difference between synthetic amorphous silica, which is used in cosmetics and other forms of
silica, and based on the information that we reviewed, we move to issue a tentative safety assessment that has the
ingredients safe with the exception of aluminum iron silicates. We move that that be insufficient data, because of
concern about inhalation toxicity.
DR. SLAGA: Unless it's (off mike).
DR. MARKS: Ron can -- well, that would be the inhalation data. If it's not respirable, then it's not an issue.
DR. BERGFELD: Any other -- that's a motion?
DR. MARKS: Yes.
DR. BERGFELD: And there's no other comment on the motion? Second? Second, Ron? Discussion?
DR. BELSITO: Respirable? We have that boilerplate. How would it be respirable?
DR. MARKS: We don't know. We can consider that it's not.
DR. SHANK: I worry about the -- or I have concern about the iron atom going into the lung, high-oxygen
environment. There could be oxidative damage, which would not expect that the other silicates –
DR. BELSITO: But I –
DR. SHANK: If not, we can say this is formulated (off mike). That takes care of the issue. But we don't have that
information.
DR. BELSITO: I thought the information we have was that cosmetic formulations -- the particle size was such that
it's in a pump or a spray it's not respirable.
DR. SHANK: Okay, but this one doesn't have a stated use, does it?
DR. BELSITO: But how would it be used as an aerosol other than as a hairspray?
DR. SHANK: Don't know. Lack of information is not proof of safety.
DR. BELSITO: But -- then I just –
DR. BERGFELD: Alan?
DR. ANDERSEN: We did have the information yesterday from the synthetic amorphous silica group that said the
particle size of the amorphous silica material is between 10 and 100 microns in diameter, so independent of what
happens to it after that, the particle size as produced by the suppliers is already of a size to be not respirable.
DR. BELSITO: Correct.

DR. ANDERSEN: From that point, it doesn't matter what formulation it goes into. Not much can happen beyond
that, and in order to conduct the inhalation toxicity studies that were described, further unnatural reduction particle
size had to be done, but that doesn't represent what's actually on the market from the suppliers. So, we could rely on
that information that was presented to make the assertion that in fact the panel does not expect that these particles
are respirable and put that burden on the industry for all of the amorphous silica, including the iron one. So, it
would be a way to assert the panel's expectation of non-respirable.
DR. BERGFELD: So, you're going to amend?
DR. MARKS: I'll retract the previous motion with that clarification, and that being captured in the discussion so
that all these silica cosmetic ingredients would be safe and that we issue a tentative safety assessment of that
conclusion.
DR. BELSITO: Second.
DR. BERGFELD: Second. And with the assumption that the discussion will take the place or support your worry.
DR. MARKS: Yeah.
DR. BERGFELD: Okay. Any other discussion? John?
DR. BAILEY: Yeah, at yesterday's team meeting I emphasized the importance of stating clearly in this document
the synthetic amorphous silica as the material that's used in cosmetics, because we have a lot of confusion inquiries
coming in that rather it's crystal and we're amorphous and we'd like to be able to use this document to clear that up
both for people who have concerns in the public but also for the users of the ingredients so that that's clearly
communicated to them what they're supposed to do.
DR. BERGFELD: I think that I sat on Don Belsito's team and he discussed that and which to do with that, did you
not?
DR. BELSITO: Yeah, a very strong statement up front in the introduction going over basically that slide of silica
production and where we are and that this is not crystal and then the amorphous, so I think Dan had -- Did you
actually beef up your introduction, or --
DR. LIEBLER: I provided comments.
DR. BELSITO: Right.
DR. LIEBLER: But I think it's most important to -- because some of the original literature refers to silica
forms -- for example, as fume silica -- and that there's a preferred term now, pyrogenic silica, for that, but there
needs to be a very clear sort of glossary in the introduction section to provide the reader with some guidance as they
go forward in the report, because we did have some discussion about whether to change in the body of the report
reference to fume silica -- change that to pyrogenic -- but that would be essentially, as Alan pointed out,
replacing -- revising the literature inappropriately, and I agree with that, so a glossary up front that clarifies the
terminology for names and points out where you're going to have confusion between silica fume and fume silica, for
example.
DR. BERGFELD: Paul, any comment? Greg? Coming over here. Don? Ron? Rob? Jim? Is there any other
comments? Okay. Motion has been placed that this ingredient is safe and discussant points have been added, so all
those in favor please raise your hand for a safe review. Thank you very much. It's a unanimous vote.
September 24-25, 2009

DR. BELSITO: So now we get into the silica and the silicates (off mike). Okay, so where are we here? Silicates.
Okay. So, we got -- is this a handout from today from Sassi?
MS. BECKER: You got that in the e-mail.
DR. BELSITO: In the e-mail. Oh, I printed out an e-mail. Okay.
MS. BECKER: Yes.
DR. BELSITO: I must have addressed it. Okay. I thought, Lillian, you did a great job and I really thought that
Figure 1 and 2 were really great in this report. And I think it really addressed concerns of our team, at least
particularly Dan's concern of getting everything up front and making it clear. I like the way you've boxed that out in
Figure 1.
DR. LIEBLER: Yeah.
DR. BELSITO: It was really a superb way of handling that to show exactly where we're focusing.
DR. LIEBLER: One little note on that on Figure 1 -- so I completely echo Don's praise for your work on this -- but
one little thing I would change is under the box where you've got – where it says the types of silica in this safety
assessment, and it's got a little box around that -- that that actually kind of hides that because everything else in the
figure has a box around it. And that's actually a message that you want to stand out and putting the box around it
makes it blend in. So what I would say is take the box out of it and then use a bigger font and italicize it just so it --
DR. BELSITO: And put it into the box maybe even.
DR. LIEBLER: Or right under the box or, yeah, lower the box a little bit and stick that in the box. Yeah, that's a
good idea.
MS. BECKER: Yeah. That's what I'm drawing right now actually.
DR. LIEBLER: Okay. But that's just a tweak. It's very nice. Huge improvement.
DR. BELSITO: On page 17, under parenteral silica one, two, three, four, five, six lines down, it says lymphocytes
were less numerous and new.
MS. BECKER: Okay, few. Probably -- yeah, few. Probably something (off mike) said.
DR. BELSITO: So if it's less numerous and few, then you don't even need few.
MS. BECKER: Yeah.
DR. BELSITO: Just less numerous.
MS. BECKER: So we will check that.
DR. KLAASSEN: Probably don't need numerous either. There were lots of lymphocytes.
MS. BECKER: There's some pretty weird wording on some of these.
DR. BELSITO: Page 29. Things were moved around so perhaps I missed it, but in the prior document there was an
ECETOC 2006 report of two subchronic oral and toxicity studies that I couldn't find again.
MS. BECKER: If I remember correctly, a couple of short-term -- I'm sorry, long-term and chronic got moved
around just because of dates, but I don't -- did you check to see if it's just in a different time section?
DR. BELSITO: I tried to do that and I couldn’t find it, but, I mean, it's entirely possible. The reference though is
gone, at least as an ECETOC 2006 reference, so I'm wondering if someone recommended it be deleted or was it, in
fact, maybe published under a different title?
DR. BRESLAWEC: Here's ECETOC 2006 on 31.
MS. BECKER: There was also a couple that were thought to be duplicates of the other large document I had and we
picked one or the other.
DR. BELSITO: Okay.
MS. BECKER: So that might be --
DR. BELSITO: So it may be --
MS. BECKER: It might be under UNEP instead.
DR. BELSITO: Okay. But then that ECETOC 2006 reference doesn't occur in your references.
MS. BECKER: I see what you're saying.
DR. BRESLAWEC: If you look at the reference there's nothing that says ECETOC.
DR. BELSITO: And there are some ECETOC on page 31 that refers to some 2006 unpublished studies, which are
different from the studies that I was talking about.
MS. BECKER: European Centre for Ecotoxicology and Toxicology of Chemicals.
DR. BELSITO: Okay.
MS. BECKER: On page 57. It's in the references.
DR. BELSITO: There it is. ECETOC 2006. Sorry, I stand corrected.
Okay. On page 35, the fifth line up the bottom, starting from the line above that it says although there was a trend of
more frequent incidence in those exposed to pyrogenic silica, it was obscured in some control animals. Interstitial
fibrosis was associated with yadda, yadda, yadda. And some of the rats of the control treatment groups, although
there was a trend to more frequent incidence in those exposed, but was obscured in some control animals. I'm
assuming it wasn't significant because it was seen in control animals or --
MS. BECKER: If I remember correctly, yes.
DR. BELSITO: I just think that needs to be stated a little bit more clearly.
MS. BECKER: You got it.
DR. BELSITO: Page 54, the third paragraph, silica subcutaneously instilled in humans. Next sentence, the cells --
MS. BECKER: I'm sorry?
DR. BELSITO: -- invested blood vessels. Invaded blood vessels?
MS. BECKER: Page 54?

DR. BELSITO: Page 54.
MS. BECKER: Third paragraph?
DR. BELSITO: From the bottom.
MS. BECKER: Oh, sorry.
DR. BELSITO: Silica subcutaneouslyinstilled in humans caused granulomatous inflammation with seven days and
persisted for months. The cells invested blood vessels?
MS. BECKER: That was --
DR. BELSITO: Invaded blood vessels?
MS. BECKER: Something like that would have been stolen wording. Yes, that was wording from Epstein 63. That's
47 and that would have been his wording. That's not something I would have picked up, but I try not to interpret too
much. Is that 47? Epstein 63.
DR. LIEBLER: Just strike the whole sentence. It doesn't add anything.
MS. BECKER: Okay.
DR. BELSITO: Okay. In our conclusion, do we really need to isolate aluminum iron silicates?
MS. BECKER: That was Dr. Shank and his concern about the iron.
DR. BELSITO: I understand and I remember the discussion, but we decided that it wasn't going to be (off mike)
even in the current form that it was used. So do we need to put that in the conclusion or just the discussion? I mean,
I think, you know, its ingredients and practice of use in concentration as described in the safety assessment is
sufficient. If there's any concern that could go in the discussion that the size of these particles, irrespective of how
they would be used that was captured in the minutes, would not be respirable.
Beyond that, we know that the way pumps and sprays are formulated it wouldn't be respirable either. But as Alan
pointed out at the last meeting, you literally would have to break down the silicates in order to make them of a size
where they would be respirable. So, taking that out and putting it into the conclusion I think is a bit much.
MS. BECKER: Okay.
DR. BELSITO: I would just move that to the discussion if there's any concern at all.
DR. LIEBLER: So simply in the conclusion --
MS. BECKER: Just the first sentence.
DR. LIEBLER: -- just use the first sentence and then add aluminum iron silicates to the first sentence.
DR. BELSITO: Exactly.
MS. BECKER: Got it.
DR. BELSITO: The last thing that I couldn't find and maybe you can tell me where it was is -- and maybe it was
decided to get rid of it -- but in the old document there was a statement about natural silica levels in rabbits. And I
couldn't find where that was moved to, but the reference was retained.
MS. BECKER: Do you have the reference offhand?

DR. BELSITO: Yes, Ammon and Moan, 1959.
MS. BECKER: Ammon with an A?
DR. BELSITO: A-M-M-O-N.
MS. BECKER: I think that was marked as not necessary.
DR. BELSITO: I would agree that it's not necessary. Then we just need to delete the reference if it's not in the
document. I mean, just check because -- I mean, you could just do a quick word search and see if it pops up
someplace in the document other than the references.
MS. BECKER: Okay. That's going to be my major task this weekend actually.
DR. BELSITO: I hope not this weekend.
MS. BECKER: Oh, yeah.
DR. BELSITO: I think that's all that I had. So before we address the Sassi comments, any other comments?
DR. LIEBLER: Page 2 and 3, I recommend a couple of additional tweaks. Just moving sections to make the
presentation more logical in terms of the flow.
So, on top of page 2, you have Chemistry, major heading, then subhead Definition and Structure, and then
Amorphous versus Crystalline Silica. You have two paragraphs. Then you've got Silica, which is really the very
most introductory information about silica. And I suggested moving that stuff there that's subtitled Silica, beginning
with the CAS Number 7631, all the way through the top of the next page where it says, "The current terminology for
silicon dioxide fumed is pyrogenic silica." That whole chunk, move it up between Definition and Structure and
Amorphous versus Crystalline Silica. And I pointed -- I drew it on my copy for you.
MS. BECKER: Okay. All right. We're changing a lot of things as CIR, but normally we keep all of the definitions
of all the ingredients together. Would that -- I'm just asking if that -- separating silica out separately from the
aluminum magnesium, metasilicate, et cetera, would that be confusing?
DR. LIEBLER: I don't think so because the way you have it now you begin by talking about amorphous versus
crystalline silica. And then at the bottom of page 2, you start out by explaining what silica is. It seems like you
should start out by explaining what silica is and then get into the distinction between amorphous versus crystalline.
It just seems more logical to me.
MS. BECKER: Okay.
DR. LIEBLER: And so you can move that section up to the top. And then you also have, at the bottom of page 3,
you have the section on hydrated silica. That can go right after amorphous versus crystalline silica. And then you
get into the aluminum magnesium salts and the silicates.
MS. BECKER: Okay.
DR. LIEBLER: And so that way you're doing pure silica first, then the salts, to just introduce the chemistry.
MS. BECKER: Okay.
DR. BELSITO: Except I guess the only issue that I'd have with that, Dan, is that we're doing -- you know, we're
looking only at the amorphous. So then you would have amorphous and then you'd mix in amorphous with
crystalline and then go back to the amorphous forms. That could be confusing. So that I guess if you wanted to
move things around would be to move the amorphous and crystalline to the end of the whole thing and list the things
that we're discussing first and then making the point of the difference between amorphous and crystalline at the end.
MS. BECKER: That would be more my inclination, but.
DR. LIEBLER: So, instead of moving the things I moved, just take amorphous versus crystalline and move it to the
end?
DR. BELSITO: Yes.
DR. LIEBLER: I'm fine with that. That accomplishes the same thing. I just thought that you have amorphous
versus crystalline at the top of the description of all the silica and silicates and it was premature to address that at
that point. So, Don's suggestion takes care of that as well and I agree with it.
MS. BECKER: Okay.
DR. SNYDER: I had some issues with the nomenclature again. It's just really confusing because on page 5 we
introduce silica gel and precipitated silica for the first time. And then on page 6 we introduce colloidal silica. And
on page 8 we bring in the sodium metasilicate, hydrated silica, and silica solution. So I was a little confused as to
where those all --
DR. LIEBLER: So under hydrated silica, Lillian has these bullets of synonyms, and silica gel and precipitated silica
are listed there. So the reader will have encountered those definitions before they got to where you're concerned
about.
MS. BECKER: Right.
DR. LIEBLER: And colloidal silica, is that one here?
DR. SNYDER: Yeah, page 6.
DR. LIEBLER: Page 6.
DR. SNYDER: On the third paragraph on down, silica sols, colloidal silica.
DR. LIEBLER: Does colloidal fall under one of these? Lillian, do you know?
MS. BECKER: I thought it was under hydrate.
DR. LIEBLER: I want to double-check that. If it can be defined there, that's a good place to put it if that's correct.
MS. BECKER: The issue was that through the literature the naming conventions are not consistent. And unless
they gave me something that said I can identify it as exactly what we have as our definition, I used the terminology
of the author.
DR. LIEBLER: So in Table 1 with the box around the forms that are defined in the safety assessment on page 61,
you have silica gel or colloidal silica.
MS. BECKER: Right.
DR. LIEBLER: So the reader will have seen this figure at that point. It's just that colloidal silica isn't listed under
the bullets that you have on pages 2 and 3.
MS. BECKER: Right. Yeah, and what I just explained is also in the introduction that I did not guess what the
authors were trying to say.
DR. LIEBLER: Okay.
MS. BECKER: Unless they gave me real evidence.

DR. LIEBLER: Right.
DR. BELSITO: So colloidal silica is silica gel?
MS. BECKER: Yes.
DR. BELSITO: And silica gel is hydrated silica?
MS. BECKER: Pretty much.
DR. LIEBLER: Right.
DR. BRESLAWEC: So on page 3, you said include that in the bullets there?
DR. BELSITO: Under hydrated silica.
DR. LIEBLER: And colloidal silica.
MS. BECKER: So that -- well, okay, but that's another reference, so that would be slightly different.
DR. BELSITO: But you could add it just so it's clear and just put that reference so we know where each of them
falls.
DR. LIEBLER: I mean, there must have been a basis for in Figure 1 including colloidal silica with silica gel.
MS. BECKER: Right. Right.
DR. LIEBLER: So that would presumably be the same reference.
MS. BECKER: Yes. That's what ARTS did. Yes.
DR. LIEBLER: Okay.
DR. SNYDER: And then there's in the nomenclature you get all the way to page 19 and we start talking about ultra
fine and then fine silica. And we haven't defined that (off mike).
MS. BECKER: And neither did the authors.
DR. LIEBLER: I'm sure it's just particle sizing.
DR. SNYDER: So then for this use, does this have an aerosol use?
DR. LIEBLER: You know what? I'm sorry, just to -- fine versus ultra fine, on page 5, under Particle Size and
Form, we've got amorphous silicas are composed of very fine particles, average 20 microns. Very fine, ultra fine,
fine.
SPEAKER: Super fine.
DR. LIEBLER: Super fine.
SPEAKER: The point comes into question that we do have data here that says that the sum of the particles are
respirable size, certainly the.01 to.1 micron diameter particles.
DR. LIEBLER: I don't know if there's a standard nomenclature of, you know, fine, ultra fine, very fine, that actually
corresponds to giant particle diameter ranges. It might be something to look for and see because you list very fine in
a way that just might mean it's sort of a kind of ordinary colloquia descriptor as opposed to whether or not very fine
means a particular size range. And if there is any definition in the literature that assigns the term "fine," "very fine,"
"ultra fine," the size range, this would be a good place to put it. This would be the ideal place to put it. So if there is
any additional information you could find that would put it there, that would be useful there.
MS. BECKER: Okay.
DR. LIEBLER: I mean, I realize this whole area is a mess, but, you know.
MS. BECKER: Right. And it's a 1961 reference, so.
DR. LIEBLER: Yeah. I'm not sure where you could ask, but someone might be able to point you in the right
direction. I forget who was here last time that made -- the Sassi people, I guess, you know, provided some input on
– some clarification on the nomenclature and forms. They may know something or be able to point you in the
direction on sizing nomenclature. If there is any and if it's referred to in the types of particle study, it probably
should be up front in this report.
MS. BECKER: Okay.
DR. KLAASSEN: On page 5, about the fifth or sixth line, it says there that very fine particles had an average of 20
micrometers.
DR. LIEBLER: Yeah, that's what I was pointing to. Yeah. Yeah. So I'm assuming fine is more than 20
micrometers and ultra fine is less.
MS. BECKER: Well, I think the phrase that might solve all of it, is right after the 20, is "which tends to aggregate
loosely in the air." So something that size doesn't exist very long. It adheres onto others and makes larger particles.
DR. BELSITO: And I think that's what we were told before.
MS. BECKER: Yes.
DR. BELSITO: And then going on it says aggregates assemble in chains, fumed or clusters precipitated in gel.
Agglomerates are assembled -- assemblies of aggregates held together by strong physical adhesion forces and not in
a dispersible nano-size less than 100 nanometers.
MS. BECKER: I think that kind of solves it.
DR. BELSITO: So the concept of very fine is a laboratory concept, not a real concept in nature?
MS. BECKER: At least not in the air.
DR. BELSITO: At least not as it would be formulated into a cosmetic product. I seem to remember them telling us
that, too. They rapidly sort of adhere together.
DR. LIEBLER: I was just looking for a way to address Paul's question about whether --
DR. SNYDER: I mean, it was deep in the document and all of a sudden this popped up. And I thought if we could
pop in appropriate information to define that, that would be useful. If any of the subsequent literature refers to
particle size and distinguishes effects on the basis of anything having to do with particle size, then I think we need to
deal with it.
DR. BELSITO: But then we could put -- we could move that issue of the aggregation of these very fine particles
into the discussion as well since there is a hairspray use. And I see that the panel noted data on the use of very fine,
fine molecular structures, average of 20 microns.
SPEAKER: (off mike) they are in respirable range of diameter.

DR. BELSITO: Right. But it is our understanding that these aggregate into chains, fumed or clusters, precipitated
in gel to particle sizes that would not be respirable in cosmetic formulations.
DR. KLAASSEN: In general, to get things down into the alveoli you want to have it between 1 and 10. Larger than
10 they don't get to the alveoli very well and if they're smaller than 1 they don't settle in the alveoli. They just blow
them back out again. So, even at this 20 microns here they're relatively safe as far as getting them into the alveoli.
You still have them in the bronchi, et cetera. So, what Don said I agree with. This just gives us even further
protection.
DR. SNYDER: We have a statement on page 53 in the fourth paragraph, the last sentence, related to -- in relation to
monkey status, it says the frequency and the size of the cell aggregates vary with the type of silica precipitated in
greater (off mike) and greater than gel. So that's what we should capture there.
DR. HOWARD: It is in the discussion -- I mean, the summary. So you want that clearly in the discussion?
DR. SNYDER: Well, I mean, I think that's just some more data --
DR. BELSITO: Well, I think we did, particularly now that we've moved the aluminum iron silicates out of the
conclusion. We're going to make mention about it in the discussion anyway. So then we could just expand upon it a
little bit if the panel noted data on use of very fine silicas, average molecular size 20 microns. However, we noted
that these tend to aggregate into -- help me.
DR. SNYDER: Tend to form aggregates.
DR. BELSITO: Tend to form aggregates of a size that would not be respirable.
DR. LIEBLER: But is the passage you're referring to, Paul, is that referring to the silica particles or cells
aggregating? Because it says the frequency and size of the cells aggregates.
DR. BELSITO: Oh, oh.
DR. LIEBLER: That's why I'm reading.
DR. SNYDER: Oh, I see. Yeah.
DR. LIEBLER: I'm trying to see if there's anything that's being said about clumps or aggregates of, like,
lymphocytes.
DR. SNYDER: No, I mean, to me (off mike) the other way. I read it that it was the aggregates as in aggregates of
silica. I mean, I guess there's nothing in that paragraph to suggest otherwise, is there?
DR. LIEBLER: So I'm just wondering what that actually refers to. Because the preceding paragraph refers to
considerable cellular infiltration of the alveoli and the alveolar septa.
DR. SNYDER: There's nothing about aggregation there.
DR. LIEBLER: And with the extension and accumulation of acetate and macrophages. See, that could easily be
referring to clumps of macrophages, perhaps. That's how I would read that. So maybe check that language there.
DR. KLAASSEN: And if true, then this sentence should go up in the other paragraph.
DR. LIEBLER: Yeah.
DR. BELSITO: So where are you moving this, Curt?

DR. KLAASSEN: Well, into the previous paragraph. It really has to do with macrophage. If it really has to do
with cells and the aggregation of cells, then it probably is more appropriate in the previous paragraph. But we, first
of all, need to make sure what's going on here.
MS. BECKER: It's the study on page -- it starts at the very bottom of 35.
DR. SNYDER: Yeah. It's macrophage and (off mike) aggregate. So just change that to "Frequency and size of the
inflammatory cell aggregates varied with the type of silica," and move it up to the previous paragraph, to the
paragraph that begins, "Rabbits and (off mike)."
DR. BELSITO: But these weren't rabbits; these were monkeys.
DR. SNYDER: Oh, so the monkeys then.
DR. BELSITO: So that's the paragraph above it?
DR. SNYDER: Yes.
MS. BECKER: These are two different experiments. I'm sorry. Say what you want to change again.
DR. BELSITO: The paragraph above is a different study.
MS. BECKER: Right.
DR. BELSITO: These are two different studies in monkeys. So that paragraph has to – I mean, you can't move it
anywhere.
DR. SNYDER: Okay. All right.
DR. BELSITO: The monkeys were exposed to different types of silica. The precipitated silica had lower lung
volumes. No change in parameters, ventillary performance, mechanical parameters, dynamic lung compliance and
FEP. When exposed to silica gel, the frequency and size of cellular aggregates varied with the type of silica.
DR. SNYDER: I would just change that sentence. So the frequency and size of inflammatory cell aggregates varied
with the type of silica.
DR. BELSITO: Okay.
MS. BECKER: Okay.
DR. BELSITO: So the frequency and size of inflammatory cell aggregates varied with the type of silica. Okay.
DR. SNYDER: That'll do it.
DR. BELSITO: Okay. Industry comments from Sassi, page 53. It says: In our opinion the following statement on
page 53 does not accurately describe the commercial pyrogenic process used to manufacture synthetic amorphous
silica. Amorphous silica is the product of a high heat process applied to crystalline silica. The contemporary
pyrogenic process is accurately described on page 6 of the report and should be substituted for the description on
page 53.
I'm just reading what was sent out to us.
DR. SNYDER: I can't make it out.
MS. BECKER: Maybe 6 and 3?

DR. SNYDER: It's on page 50, actually.
MS. BECKER: Page 50.
DR. BELSITO: They may be referring to the old report. I don't know.
DR. SNYDER: Here it is on page 50, the second paragraph. (off mike) pyrogenic silica is a product of high heat
process applied to crystalline and silica.
MS. BECKER: You're on 50?
DR. SNYDER: Page 50.
DR. BELSITO: Fifty, the first and second paragraph.
DR. SNYDER: Second paragraph, first line.
DR. BELSITO: So --
MS. BECKER: You want to get rid of that sentence?
DR. BELSITO: Well, no. They're saying that it's not the way it's produced. The way it's produced is --
DR. SNYDER: On page 6.
DR. BELSITO: What we said on page 6: Precipitated silica and silica gels are produced from an alkaline metal
silicate dissolved in water and then acid, usually sulfuric.
DR. LIEBLER: No, they are actually probably referring to the bottom of page 5 on the current report, amorphous
pyrogenic silica.
DR. BELSITO: Yes. Okay.
DR. LIEBLER: So here it says, on page 5, the bottom of our current report, it says, "Amorphous pyrogenic silica is
manufactured by the hydrolysis of volatile silanes, usually silica and tetrachloride, in the flame of an oxygen
hydrogen burner."
And then page 50, second paragraph of our second report, it says, "Amorphous pyrogenic silica is the product of a
high heat process applied to crystalline silica."
MS. BECKER: Right. Which is of that.
DR. BELSITO: Right. So what they're saying is that's not -- the contemporary pyrogenic process is the process
currently described on page 5.
MS. BECKER: Right. The rest of the paragraph, I think --
DR. LIEBLER: We agreed.
MS. BECKER: So we just want to get rid of the --
DR. BELSITO: You want the amorphous pyrogenic silica, you just want to --
DR. SNYDER: Capture from page 6.
DR. BELSITO: -- capture from page -- no, 5.

DR. LIEBLER: Yeah, right. So the sentence on page 50, the first sentence of the second paragraph, amorphous
pyrogenic silica through -- applied to crystalline silica, delete that sentence and in its place copy the sentence from
the bottom of page 5, "Amorphous pyrogenic silica through oxygen hydrogen burner." It's the same definition word
for word from the bottom of page 5 instead.
MS. BECKER: Thank you.
DR. BELSITO: Okay. The next comment from Sassi is we noted in our earlier comments the lack of differentiation
between silica fumes and the commercial product called fumed silica, i.e., pyrogenic silica, leads to a clear
misunderstanding of the significance of the statement on page 8 -- may be different -- regarding the high level of
crystalline silica impurity 6 to 8 percent noted in the Swensson 1971 study.
DR. SNYDER: On page 7, first sentence.
DR. BELSITO: Since silica fume is a commercial product not classified as synthetic amorphous silica, we
recommend deleting this reference on the basis of irrelevance. So, that's now on page 7.
DR. SNYDER: First sentence, (off mike) composition of the fumes.
DR. KLAASSEN: So you want to eliminate the first paragraph? Is that what we're talking about?
DR. LIEBLER: Maybe the first sentence.
DR. BELSITO: The first sentence.
DR. LIEBLER: Swensson, et al., through courts.
DR. BELSITO: You have the Cabot Corporation. They're not saying anything about --
DR. LIEBLER: So that's two (off mike).
DR. BELSITO: So it would just be, "Cabot Corporation 2004 states that its silicate products are greater than 99.8
percent pure." The moisture content, yeah, treated silicas are susceptible to.
Okay. Next comment from Sassi. On page 3, two references to Spiron as a technical name for silica are noted. Our
members are not aware of this technical name and suspect it is a trade name.
MS. BECKER: For silica?
DR. BELSITO: That may have already been removed because I'm not seeing Spiron here anywhere.
SPEAKER: I don't see it.
MS. BECKER: You have that little table somewhere (off mike)?
DR. BELSITO: No, it would have just -- it would have been on the page. I mean, maybe it was in the old report
and it's already been deleted. Again, this letter seems to be addressing the old report and not --
MS. BECKER: Yeah, because they would have got the version that I produced right after the last panel meeting.
DR. BELSITO: Okay.
MS. BECKER: It's been edited since then one more time before you got it.
DR. BELSITO: Okay. What you may want to do, Lillian, again, just do a word search for "Spiron." Make sure that
it's been deleted.
Okay. Page 24, a reference to a UNEP 2004 study mentioned the LC50 of.69 1 milligrams per liter. We believe the
greater than symbol was omitted in error on the LC50, so.
SPEAKER: On page 21? Under inhalation, third paragraph?
DR. BELSITO: Okay. So you need to check and be certain that they're correct, that the LC50 was greater than.691.
MS. BECKER: Sure.
DR. BELSITO: Okay. In the discussion we noted that the last sentence to the paragraph was incomplete. It appears
a word may have been omitted. I didn't notice a word omitted, so this may again --
DR. LIEBLER: Last sentence of which paragraph?
DR. BELSITO: It just says, "in the discussion session section on page 50A." Well, it's not relevant anymore. We
noted that the last sentence of the paragraph was incomplete.
MS. BECKER: Okay. Okay, it wasn't quite the last sentence. My guess is that the whole section was completely
removed.
DR. BELSITO: Right. Okay. That was it from the silica council.
DR. SNYDER: They changed that sentence anyway. So instead of saying no pursuant silica is used -- to the panel
determined that silicosis is not an issue since crystalline silica is not an ingredient used in cosmetics.
MS. BECKER: Okay.
DR. BELSITO: Okay.
DR. LIEBLER: I had a -- again, in the front on pages 4 and 5 of our current document, the use of subheads under,
for example, Physical and Chemical Properties and then Properties.
MS. BECKER: I'm sorry. Where?
DR. LIEBLER: On page 4, Physical and Chemical Properties. And then you hove Properties and then you have the
subhead Silica. And then there's no other compound like silicates referred to.
I think when you don't have any other compound referred to, you can just delete the Silica subheading. I made a few
notes like that, but then I stopped. I think it's a question if there's going to be silica and then you're going to do
aluminum magnesium silicate, then you have the subheads for each. Otherwise, you just delete silica subheads.
MS. BECKER: Okay.
DR. BELSITO: Except that I find it helpful because then you know exactly what information you have under that
particular heading. You can quickly, very visually see it rather than -- I know what you're saying.
DR. LIEBLER: Yeah.
DR. BELSITO: It's like you look at properties and the only properties we're going to get are on silica. It's not going
to be on something else.
DR. LIEBLER: Okay. I'm an editorial slasher by nature, so.
DR. KLAASSEN: You can have silica property.

DR. BRESLAWEC: May I suggest that we do whatever the JAMA format requires us to do in terms of the IJT
publication on that?
DR. BELSITO: Okay.
DR. BRESLAWEC: We'll follow the guidance there.
DR. BELSITO: Sure. Okay, good. That sounds reasonable. Anything else on this silica?
DR. LIEBLER: When judgment fails, fall back on policy.
SPEAKER: What?
DR. LIEBLER: When judgment fails, fall back on policy.
DR. BELSITO: Okay. So no other comments. We'll move to sodium and potassium bromate.
MS. BECKER: So we're going final?
DR. BELSITO: We're going final. And I think the change moving the aluminum iron out of the conclusion is really
editorial. I mean, it's not substantive so I don't think we need to send it out again.

DR. MARKS: You're welcome. Next is silica and silicates. We have in front of us a "Tentative Report of Silica
and Related Ingredients." There were comments from industry. There's a September 3 letter from SASSI, the
Synthetic Amorphous Silica and Silicate Industry Association, who characterized their comments as being relatively
minor. The conclusion is that these ingredients are safe as cosmetic ingredients, that aluminum iron silicate is safe
as a cosmetic ingredient in the practices and uses described in the safety assessment when formulated to be
nonrespirable, and I think there are some potential comments about that. Ron Shank?
DR. SHANK: I think the conclusion is okay. The SASSI suggestions I agree with to put in as they have requested.
There is a UNEP report of 2004. On page 21 SASSI refers to the LC50, we say 0.691 and SASSI says it should be
less than 0.691. That can be checked by going to the UNEP report. On page 45 under "Clinical Assessment of
Safety," it says that the oral lethal dose is 15 grams per kilogram. That would be over 1 kilo per person, so that there
is something wrong there, and it really doesn't add anything. I would just throw it out. It's an FDA comment or
something. With due respect to FDA, I don't think that could possibly be correct that the oral lethal dose is 15 grams
per kilo. It would be pretty hard to take a kilogram for an adult. Those are my only comments.
DR. MARKS: Lillian will capture those then. I'm not sure we need to mention that tomorrow unless you feel we
need to.
DR. SLAGA: Right.
DR. MARKS: Are there any other comments? Ron Hill?
DR. BERGFELD: I'd like to make a comment that I thought it was nicely reorganized and redefined so that we
were not as confused in reading it. Thank you.
DR. MARKS: I suspect tomorrow that our team will be seconding a motion that a final report be issued with the
conclusions as stated on page 55, that these are safe and with the proviso that aluminum iron silicates are not
respirable. Let's take a break for 5 minutes. You have more comments? After your comments, Jay.
DR. ANSELL: Just on the wording, this is the first report we hit where we put in this "were ingredients in this
group not currently to be used in the future. The expectation is that they be used in product categories and
concentrations comparable to others in the group," is a little tortured.
DR. MARKS: We've discussed that at some time in the past, Jay. Do you have a proposal to make it clear and less
tortured?
DR. ANSELL: No, not right now.
DR. MARKS: When you come up with the proposed change, let us look at it. I know we all worked on it, and Alan
particularly.
Full Panel Meeting:

DR. BERGFELD: We're moving on to "Silica," Dr. Belsito.
DR. BELSITO: Yes, at the last meeting we issued a tentative safety assessment that these ingredients -- silica,
aluminum magnesium metasilicate, aluminum calcium sodium silicate, hydrated silica, sodium potassium aluminum
silicate -- are safe as cosmetic ingredients in the practice of use in concentrations as described in the safety
assessment, and put a caveat in that conclusion that aluminum ion silicate is safe as a cosmetic ingredient, the
practice of use in concentration as described in the safety assessment when formulated to be non-respirable.
We thought that we would like to make a minor editorial change in that conclusion and just put aluminum ion
silicate into the list of other silica products that are safe as used and move the discussion of the ability of these
particles to be inhaled, which essentially they cannot be because of their size -- they tend to aggregate into large
molecular sizes -- into the discussion rather than putting it into the conclusion.
DR. BERGFELD: And that's a motion.
DR. BELSITO: That's a motion.
DR. BERGFELD: Is there a second? Second, Paul? Discussion? Ron?
DR. SHANK: That's okay.
DR. BERGFELD: It's okay? Any other discussion?
DR. BELSITO: Yeah, in the discussion itself just putting -- stressing that these do tend to aggregate into larger
molecular weight particles in formulation, stressing that a little bit more.
DR. BERGFELD: Any other discussion? Seeing none, I call the question. All those in favor of this conclusion
please indicate by raising your hands. Unanimous. No abstainers. Okay.
Silica and Silicates

June 4-5, 2018
DR. BELSITO: Silicates. This was also part of Wave 2. And this is a re-review with a question of add-ons,
correct?
MS. BURNETT: Correct. And I handed out at the table this morning to help clarify what add-ons are where,
hopefully to help your discussion.
DR. BELSITO: Yes, I didn’t see that. I said combined them all, add in the new ones. We need to take a look
regardless. Usage has increased astronomically for many, and we need a sense of concentration of use, regardless of
what we decide to do. That was my analysis.
DR. LIEBLER: Yeah, I said reopen to add all the new ingredients. This is a chemically heterogeneous group, so
the new ingredients easily belong. That’s the benefit of the dog’s breakfast, by the way.
However, their properties aren’t significantly different, and existing data covers the entire group. No need for new
data, we can affirm the previous conclusion.
DR. BELSITO: I don’t know that we can confirm it until we get a sense of concentration of use.
DR. LIEBLER: Fine.
DR. EISENMANN: And the report is not correct. The concentration of use survey has not been started on silica
and hydrated silica. Those weren’t included in the list they gave me. And I don’t expect that to be -- if I get it
started -- those are high use ingredients, so it’s going to take at least --
DR. BELSITO: That’s fine.
DR. EISENMANN: So, don’t expect to see this until December.
DR. BELSITO: Oh, I wanted to see it in September.
DR. EISENMANN: Well --
DR. BELSITO: I’m teasing you Carol.
DR. EISENMANN: -- I doubt we’ll get to those that quick.
DR. BELSITO: No, I mean, that’s fine. I just thought that we could open, merge them all, add in the new ones.
But the use has increased astronomically, which is part of the reason to look at it again anyway.
DR. EISENMANN: I was a little concerned about -- see I think this isn’t chemistry that drives the toxicity of these
ingredients, it’s more structure. And it wasn’t really addressed at all in this report. There is a discussion that’s in
the silica report about amorphous versus crystalline. I don’t know, that’s part of my concern about combining this,
that that might get lost.
DR. BELSITO: Okay, so, run that by me again. Your concern here is not the chemistry it’s the structure.
DR. EISENMANN: It’s the physical structure of these compounds.
DR. BELSITO: Dan, you need to address that because that’s above my head.
DR. EISENMANN: Right, and I’m not an expert in it either. I just know that was a big issue in the report, and the
report hasn’t been published, so I’m a little concerned about --
MS. BURNETT: Because that report hasn’t been published, pretty much the entirety -- it will be reorganized into
current format. But the bulk of the data will still be there. It’s not going to be like the published paper re-review,
where we italicize it, and then it doesn’t get published. This will go directly into this paper; and so, it will be like a,
you know, silica 2.0 version for the panel to review.
DR. BELSITO: Right. How come that report wasn’t published?
MS. FIUME: I don’t know. It may have been internal. It may have been journal, I’m not sure. But it did need
some reorganization. So, it’ll be incorporated in here and all of the information will get published.
DR. BERGFELD: With the mention of the structural differences, is it possible to reorganize according to the
structure?
DR. BELSITO: Anything is possible.
DR. LIEBLER: To the extent that they’re all structurally characterized. I suppose. The structure issue, as opposed
to the chemical substance issue, Don, is like these crystalline silica versus amorphous silica. Chemically, in a
chemical composition sense, they’re about the same. In the way that the structure is, they’re very different. And
because the structure is different, they interact with biological components differently.
MS. BURNETT: I’m still reading and trying to understand the original report. But as I have read the physical
properties and method of manufacture section, we have clearly stated that the cosmetic silica is amorphous not
crystalline.
So as far as I understand, the data that is in this report is only on the amorphous silica. And there are like different
names within the amorphous silica, but we go by the INCI names. So, if the amorphous silica is the silica, that’s
what the report is on.
DR. LIEBLER: I use that as an example of a structure difference for Don to explain, I think, what Carol was
pointing out. I don’t know how these partition into crystalline or amorphous. If the data you have so far says these
are all amorphous silicates, then that’s what they are. And I guess we’re going to need more data to make decisions
about grouping them.
MS. BURNETT: Okay.
DR. LIEBLER: Are you going to think about subgrouping them? I don’t know if we are. I don’t know if we need
to.
DR. KLAASSEN: Here we do have, in contrast to one of the chemicals we were talking about this morning, you
know, It is well known -- and as you know -- that some silica compounds can cause silicosis, which is a real lung
disease. And so, we need to make sure that we know which ones might cause silicosis and which ones don’t cause
silicosis.
DR. BELSITO: But isn’t that the point Christina was making with the amorphous versus crystalline? Because it’s
the crystalline ones that cause silicosis.
DR. KLAASSEN: But that’s what I’m saying; we need to make sure that all of these that we have here -- or what is
known about it to make -- we need to make sure that these are all the amorphous. And how strong is the data, first
of all, that it has to be an amorphous compared to a crystalline, et cetera; which I don’t know offhand.
MS. FIUME: I do know, looking at the minutes, PDF Page 54, maybe that’s the 2009 review; where the Panel
determined that silicosis is not an issue since crystalline silica is not an ingredient used in cosmetics. So, that’s what
was discussed at that time, that it’s not crystalline.
DR. BELSITO: So, as you go through the add-ons, et cetera, just make sure that what we’re talking about is
amorphous. Anything else?

DR. MARKS: I know. Silicates. Let’s see, I have silicates are the next.
DR. SHANK: That’s what I have.
DR. MARKS: And this is silicate related ingredients re-review.
MS. BURNETT: This morning, to help in the discussion -- I apologize, when I wrote this report, I didn’t put in a
table summarizing which ingredients were the existing ingredients, which were the previously reviewed ingredients,
and which were the brand new potential add-ons.
It was clear to me because I had my table, but I didn’t include it in the report. I handed that out this morning to help
you see which was which; so that when you’re talking you know which ingredients --
DR. SHANK: Thank you. Thank you.
DR. ANSELL: Do you have an extra copy of that by any chance?
MS. BURNETT: I don’t have any extra copies.
DR. SHANK: Here, I’ll give you mine.
DR. ANSELL: Can you part with it?
DR. SHANK: Sure. Who needs it?
MS. BURNETT: Oh, she has electronic.
DR. SHANK: You want it?
MS. BURNETT: No. I’m good, I have mine. I have it on my computer, so I can view it.
DR. SHANK: Okay.
DR. MARKS: Thank you, Christina. I know when I went through this I was going back to the original reports,
which the last one I have is on page 226 of the PDF, which was the conclusion on the silicate aluminum magnesium,
et cetera. Okay.
As Christina documents in her memo on May 23rd, this is a re-review. And basically, we have a conglomeration of
stuff. There are ingredients -- there is the suggestion to consolidate ingredients from three reports previously. And
they are on page 89, 155 and 226, for those who want to refer to that. And then 16 add-ons.
And then, in terms of the reports themselves, in 2003, there are 17 silicates that were safe. Then in the next
paragraph, Christina talks about the 16 possible add-ons. And then, let me see, in the 2005 and 2009 reports with --
I have to look at the conclusions. Did I put -- are they all safe? Or one them was irritation, wasn’t there?
MS. BURNETT: 2005 the potassium sodium, metasilicate and sodium silicate have a formulated to be
nonirritating.
DR. MARKS: Nonirritating, yes.
MS. BURNETT: They were part of the original group, that were reviewed, and the panel decided to split them off.
Then during the discussion in 2009, for the silica report, it was mentioned that when these were re-reviewed, that
they would all be grouped together. I don’t know if you saw that; but I had a good laugh when I read that. Saying,
we will let the folks in 2018 deal with it. Well, guess what? You guys are all still here.
DR. HILL: Here we are. I saw that. I chuckled.
MS. BURNETT: And you have to deal with it.
DR. HILL: It’s 2018 already.
MS. BURNETT: And just to remind the panel, the final report of the 2009 silica report was never published.
DR. MARKS: Yes. Thank you.
MS. BURNETT: It’s kind of hanging in limbo right now.
DR. MARKS: Yeah. Okay. Yeah, the irritation and sensitization were okay, except the silicates were irritating.
That’s page 83.
I think the first question, is do we want to open this? Obviously this 2003 report. And that can either be for
changing the conclusion, or it can be for add-ons and consolidation. Do we want to reopen or not?
DR. SHANK: I don’t think it’s useful to reopen.
DR. SLAGA: I’ve been with reopening this; I like combining all of these together.
DR. MARKS: Hmm, interesting.
DR. SLAGA: I don’t remember who pushed to have it separated a long time ago. I know the panel did, but I --
MS. BURNETT: I don’t remember.
DR. SLAGA: The other group, way over there?
MS. BURNETT: The team minutes were not really published back then, so I can’t really tell.
DR. MARKS: Oh, is that right?
MS. BURNETT: It’s summarized.
DR. HILL: They’re summary versions.
MS. BURNETT: Yeah. They’re summary versions.
DR. SHANK: I don’t see how it’s useful, what that accomplishes. And I think you may have trouble publishing
that if most of the report is already -- if you put it all together, you’re going to have to justify it, to some journal, that
it’s already been published, now we’re putting it together. I don’t see -- it’s not worth the effort.
DR. SLAGA: Well, what about the 16 though? The 16 possible.
DR. MARKS: Yeah. That’s the question I would add, is the new 16 add-on ingredients that have never been
reviewed before.
DR. SHANK: Okay. There’s very little data on those 16, and only two of them are used. So that could be handled
in the re-review summary without reopening. I certainly would not combine --
DR. SLAGA: Published data.
DR. SHANK: -- all of these into one report.

DR. ANSELL: That’s really our comment for recommending not reopening; is that we would like to hear a much
more substantive discussion as to why these three reports form a relevant family.
DR. HILL: Here’s what I wrote. I think in general, maybe we should bring everything together and get a global
view of properties; and then respectively separate into either different reports, or at least different subsections very
carefully constructed so any read across that is or isn’t used is very clear.
Sodium metasilicate is very different from synthetic amorphous silica or zeolite. And I’m also not prepared to read
across from sodium silicate to something like sodium aluminum silver silicate, or silver copper zeolite, where there
are different metals with different redox properties, blah, blah, blah, blah, blah. Anyway, so I guess I’m at a level
agreeing with Dr. Shank.
DR. SLAGA: But how do we deal -- there’s two of them that are being used.
DR. HILL: Which two are they?
DR. SLANK: Zinc zeolite and --
DR. SLAGA: Would that be worthwhile to add those two? I mean, being consistent with earlier, where we didn’t
want to add them because they were not in use. But two of them are in use out the 16.
MS. BURNETT: Ammonium silver and zinc.
DR. HILL: Ammonium silver --
DR. SLAGA: I know doesn’t seem much to add but --
MS. BURNETT: Ammonium silver zinc.
DR. SLAGA: -- some consistency here.
DR. ANSELL: Well, then we would just open up that report. We don’t have to open all three of them to merge
them. If we feel that --
DR. SLAGA: No, no. Eliminate the others that have been published already. I’m talking 2 out of 16.
DR. HILL: Well then actually, the six that haven’t been published from 2009.
MS. FIUME: Right. So, it would be 22 that have not been published yet.
DR. SLAGA: Oh, okay.
DR. HILL: And are they across all three families?
MS. FIUME: The 2009 ingredients, that report has not been published. So, it wouldn’t be republishing existing
information.
DR. SLAGA: Which one?
MS. FIUME: The 2009 report. The silica and silicate ingredients. I mean, if there’s commonality to create a
family out of all of these -- or any of these; because we do need to consider, number one, the re-review. But once
you reopen the re-review, you don’t have to read across. You can make a split conclusion if the family fits together,
but you don’t have enough information to decide on all of them.
You can do a split conclusion. It doesn’t have to be read across. Once you decide to reopen, you know, if you’re
combining -- because there are different conclusions among the ingredients you would be combining. Then you can
start a whole new review.
DR. ANSELL: I think we would have an issue with reopening to add an ingredient, and then determine that the
existing data is insufficient to support that new ingredient.
DR. SHANK: That’s not a no-brainer then.
DR. ANSELL: Yeah. It would need its own report, which you guys could always do.
DR. SHANK: Why were the six ingredients in 2009 never published?
MS. FIUME: I believe the journal may have liked to see some additional information, or it may have needed a little
bit of --
MS. BURNETT: Reorganization.
MS. FIUME: -- reorganization for publication.
DR. SHANK: So, it was sent to a journal and the peer review said change it?
MS. FIUME: I’m not sure if it’s an internal decision or if it was a journal decision. I’m not sure, at that point, if it
was done or not.
DR. SHANK: Okay.
MS. BURNETT: It’s been almost ten years, so.
MS. FIUME: Yeah.
DR. ANSELL: Yeah. And I think that’s our core point. I mean, safety is one thing. We just don’t understand why
we would reopen for purposes of merging these without --
MS. FIUME: Well, we have done it in the past, where we’ve reopened and based on the ingredients themselves,
the conclusion it may not have been worthwhile to go forward. But we have created bigger families and looked at it
as a full report, not simply -- once the decision was made to reopen because some of them were no brainers, those
were brought in, because we were initiating a full report.
So, we’ve done it both ways in the past. But again, it’s the panel’s purview as to how they’d like to go forward,
with this group, based on the similarity -- the information that’s already included.
DR. HILL: For me, the 2003 grouping is a strange looking family. I mean, I would have put the clays together and
that’s it. You know, and then some of these other silicates together and that’s it.
And then some of the new ones and some of these ones in the other report fit with that, but not that. You know, so
that’s when I say -- I mean, you published in 2003, you reached conclusions, but it’s a strange grouping.
DR. MARKS: We’re still at the point -- initially, we said we did not want to reopen. We don’t want to consolidate
the ingredients from the previous reports -- the previous three reports. Two out of the three reports were published.
And then we didn’t like all the add-ons, but two of them are being used. Do we reopen to address the two add-ons
that are being used?
And then obviously, the comments you made, Ron Hill, about the lack of consistency of the grouping of the
ingredients raises some issue. Although that 2003, all them were safe. Even though maybe the grouping isn’t to
your liking.
So, where should we go team? Do you want to not reopen, or do you want to -- and which of the two of the new
add-ons are being used?
DR. ANSELL: Ammonium silver zinc --
DR. HILL: Aluminum silicate. It’s the fifth one down in her table. And zinc zeolites, all the way at the --
DR. MARKS: Zinc zeolite. That’s one use. And then what was the other? The ammonium silver zinc aluminum
silicate, is that the one?
DR. HILL: Yes.
DR. MARKS: And how many ingredients is that? Or how many products?
DR. ANSELL: Seventeen.
MS. BURNETT: It’s in 17 and has a use concentration.
DR. MARKS: Yeah, 17 is a lot.
DR. HILL: So, one way to fly on this, or at least for discussion to think about, is pull ingredients out of that 2009
group that never got published, that go with this one or that one. I don’t see any zeolites, but there are silicates that
would fit.
So, you pull the silicates that go with the ammonium silver zinc aluminum silicate and see what data you got. And
then we had that sassy publication in the interim. I think that was actually my second meeting here in 2009, if I’m
not mistaken.
And we have the whole transcript covered, which I captured, which I read. And I thought that was -- it reminded me
of things I heard -- it’s hard to say, nine years ago, but nine years ago.
DR. MARKS: So, what you’re suggesting is -- and that would be reopening, but not reopening the ’03 report,
reopening the ’09 report. Because it is a report even though it wasn’t published.
DR. HILL: Well, it never was published.
DR. MARKS: Well, that doesn’t matter. From a CIR point of view, it’s a report.
DR. SHANK: Right.
DR. MARKS: Am I not correct?
DR. SHANK: Yes.
DR. HILL: I got you. Okay, well -- okay then maybe --
DR. SLAGA: But that could be decided some other time.
DR. MARKS: We could talk about that today and perhaps -- so we don’t want to reopen the 2003 report? We’re
pretty solid about that.
And then should we mention, tomorrow, to consider -- because it’ll be very interesting to see, obviously, what the
Belsito team, their approach. Our approach would be to reopen the 2009 report and add, where appropriate, the new
add-ons which is --
DR. HILL: It’s really the one that has 17 uses, I think, I heard.
DR. MARKS: Seventeen uses. The zeolite is chemically significant, different from the silicate ingredients in the
2009; you would include that, since that has one use?
DR. HILL: Yeah. I mean, if you’re going -- a re-review summary is going to be written for the 2003; so, if you
don’t want to reopen, I guess then that zinc zeolite stays in orphan. Is there any downsize to having it stay in orphan
other than just one we have in the dictionary that’s not been reviewed?
DR. MARKS: Right. And the other is if we suggest the 2009 report, 15 years, that’s 2000 -- let me see, 2024
right? We put it off for another eight years or so.
DR. SHANK: Beyond my time.
DR. MARKS: So, second, not reopen the 2003 report. We’re solid on that one, team? And then we could consider
reopening the -- our suggestion would be if there is -- it doesn’t sound like there’s any urgency to these new add-
ons. I mean, is the aluminum silver -- there are no alerts or concerns about these two that are in use.
MS. FIUME: Not that I’m aware of. But I can I just -- for a procedural question. I know there’s been a lot of
discussion this morning about whether they’re in use or not in use. As part of the reopen decision, which is a new
turn as I’m sure Dr. Bergfeld will point out tomorrow. But a lot of these silicates that are just a combination of
aluminum, or calcium, or magnesium, which were in the 2003 report, you don’t feel they can be no-brainers; and
added to that report and be reopened for add-ons as no-brainers?
DR. SLAGA: I mean, that’s what I originally thought.
MS. FIUME: That would be our typical --
DR. ANSELL: Ammonium, silver, zinc and zinc zeolite add to the ‘03.
MS. FIUME: But there is aluminum calcium magnesium potassium sodium zinc silicate. And you know, we’ve
done aluminum silicate. And, you know, we’ve done aluminum silicate, we’ve done calcium silicate, we’ve done
magnesium silicate. So, there is a calcium magnesium silicate as a proposed add-on.
If you don’t want the entire list of 16 -- regardless of in use or not in use -- are there some that can be brought in as
no-brainers, and brought into the 2003 report? And would you consider, at least, taking that step?
DR. HILL: For me, as soon as you have silver in there then that’s not necessarily, chemically a no-brainer without
some additional information. Because there’s nothing with silver in it, on it, or around it, in the original 2003.
DR. MARKS: Okay.
DR. HILL: And that has redox properties that aren’t present in these other metals from the 2003 one.
MS. FIUME: But there is a calcium magnesium silicate.
DR. SLAGA: Right.
DR. HILL: Silver is nothing --
MS. FIUME: There’s a sodium magnesium aluminum silicate, as ingredients that have not yet been reviewed.
MS. BURNETT: So, possibly eliminate the silver ones.
MS. FIUME: So, could they be brought in reopened to add these no-brainers?
DR. MARKS: And then we can list the specific ones. But I see what you’re saying, that of the potential add-ons,
limit that 16 to ones which are chemically very similar to the 2003 report no-brainers, and reopen and add those.
Don’t consolidate.
Tom, you seem to be indicating that sounds okay. Ron Shank, do you have a problem with that? And we can list
which ones. We mentioned the calcium magnesium silicate, and there are several others -- or a couple others. What
is your sense, Ron Shank?
DR. SHANK: You’re taking the no-brainers from the new add-ons?
DR. MARKS: Yes.
DR. SHANK: And adding them to the 2003?
DR. MARKS: So, like calcium magnesium silicate would be one of the no-brainers. Not silver, based on Ron
Hill’s concern.
DR. SHANK: Okay. So, out of those 16, the only --
DR. MARKS: Yes. So, let’s go there.
DR. SHANK: -- one that is used is zinc zeolite.
DR. HILL: And ammonium silver --
DR. SHANK: Or the silver. And Dr. Hill says count in -- that’s not a no-brainer. So, you’re reopening to add zinc
zeolite, which has one use.
DR. SLAGA: No, no. Add even the ones that are not being used --
DR. MARKS: Calcium magnesium silicate.
DR. SLAGA: -- to this because they’ve never been reviewed.
MS. FIUME: I mean, they’re in the dictionary.
DR. SLAGA: We eliminated -- re-reviewed based on it wasn’t a no-brainer. That was the final earlier today.
These are --
DR. ANSELL: So, you dropped silver. You’d keep germanium?
DR. HILL: There’s still quite a few that you could keep though.
DR. SHANK: What about iron?
DR. HILL: Yeah. I think so.
DR. MARKS: So, let’s go from the top. Obviously not activated clay. How about the second one, the aluminum
calcium magnesium potassium sodium zinc silicate?
DR. HILL: So why not activated clay, because you’ve already got -- in the 2003 -- you’ve got attapulgite,
bentonite, Fullers Earth, hectorite and kaolin.
DR. MARKS: So, you would add that?
DR. HILL: I think activated clay would be fine.

DR. MARKS: Okay.
DR. HILL: The next one would be fine. The next one would be fine. The next one would be fine. The next one
would be fine. Then we’ve got two silvers, but I think the calcium magnesium silicate would be fine.
DR. ANSELL: Calcium magnesium germanium would be okay?
DR. HILL: Where’s that?
DR. MARKS: Well, no.
DR. ANSELL: That’s number three.
MS. BURNETT: The third one down.
DR. HILL: I don’t know about germanium. That’s iffy. I’d have to think about that. I’m sorry I didn’t yet.
Remember, my take was put them all together and then split them back out. But, I’m in a different mode now. I
think germanium would be okay.
DR. MARKS: Okay. So, you don’t like the silvers. Now we’re down to the gold zeolite. Zeolite was safe in the
’03 report. Adding gold to it, does that change it? And then we’re into silver copper zeolite.
DR. HILL: So, I’d have to see what the definition of the gold one -- it really isn’t very clear if I remember right.
MS. BURNETT: Yeah.
DR. HILL: What form the gold is in.
MS. BURNETT: Gold zeolite is a product obtained by the reaction of gold chloride with zeolite.
DR. MARKS: Yeah. So, it’s gold plus zeolite.
DR. HILL: I have to think about that one and the germanium. But anyway, skipping that for the moment and the
two silvers, then you still -- you have sodium magnesium, aluminum, here’s another silver. I think titanium’s okay.
Tromethamine is new. So I flagged that at least.
But then the last of them is probably fine, based on what’s in that grouping in 2003. I know it seems like I’m cherry
picking, but I’m just looking at chemistry that I know.
DR. MARKS: So, you would have two, four, six, eight, nine ingredients if I count --
DR. HILL: Six, seven, eight, nine, maybe ten if we do zinc silicate. Did you catch that one?
DR. MARKS: Yup.
DR. HILL: Let’s see, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10 I count.
MS. BURNETT: I have nine.
DR. MARKS: Oh, I didn’t include the gold since you were hesitating.
DR. HILL: No, I didn’t. but I did include the last four -- all of the last four.
DR. MARKS: Okay. The last four.
DR. HILL: But that’s just --

MS. BURNETT: Eliminating all the ones with silver.
DR. HILL: And I’m not sure about gold; I have to think about that.
DR. MARKS: And you’ve eliminated the zinc, the one that has 17 uses, the ammonium silver zinc aluminum
silicate. So, we’re adding on virtually everything with no use; although that hasn’t been a -- these are no-brainers.
DR. HILL: And now the interesting question is, would you group all the ones that had silver and possibly with the
gold in there, and then make another group and another report. But the only ingredient that’s in use -- and I don’t
know about data --
MS. BURNETTE: None of those are in use.
DR. HILL: -- would be the ammonium silver zinc aluminum silicate. What do we have in the way of data?
DR. MARKS: So, now we’re at reopen the 2000 report and add approximately -- I’ll say approximately --
somewhere around ten ingredients, which are no-brainers from that new add-on list. What’s your sense, Ron Hill?
You don’t have a problem with that?
DR. HILL: I don’t have a problem with that; or I don’t have a problem with do not reopen, since most of those are
not in use.
DR. MARKS: Ron Shank, which way do you lean? Still not reopen.
DR. SHANK: Yes. Not reopen.
DR. SLAGA: Reopen.
DR. MARKS: So, we have a split here. I mean the question is, is it really worth it for a bunch of ingredients that
have no uses. But that shouldn’t be --
DR. SLAGA: Well, zinc zeolite a product, right?
DR. MARKS: Yeah. One use for that one.
MS. BURNETT: I have data on that one.
DR. MARKS: But again, that’s the criteria. Do we use that criteria for reopening? Some things I don’t think we
have. It’s just as a no brainer.
MS. FIUME: I would like to state CIR has been trying to create, through the past couple of years, complete
families, even if ingredients had been reviewed in the past.
DR. MARKS: Right.
MS. FIUME: Regardless of the number of uses. Because then I was going to channel Bart, a little bit, and say
thank you for potentially adding the add-ons to the report. But then can we look at the 2005 and 2009 reports,
because again, there are similar ingredients. So that our family is complete, in one place, could you consider
bringing those into the report as well.
And they do have conclusion, but again, there is sodium potassium aluminum silicate in the 2009 report. So, it’s
sort of out there.
I guess one of our goals has been recently, as we prepare these bigger families, is that it makes sense to have a
family of ingredients in one place. And that’s, you know, what we’ve been striving to do. So, is it possible to make,
even albeit large, a family of ingredients out of these combined four categories, if it was going to be redundant.
DR. ANSELL: Right.
DR. MARKS: And that’s -- Ron Shank, right from the beginning, you didn’t like the idea of combining all into one
report?
DR. SHANK: I didn’t see the need. Had that been done at the beginning, okay. But to go back and put them all
together, half of them have already been published. So, now what you’re saying is taking the 16 add-ons, and the
2009, and putting them all into a reopened 2003.
DR. MARKS: No. Actually --
DR. SHANK: And leaving the three irritating ones --
DR. MARKS: No. I wasn’t that far along, Ron Shank.
DR. SLAGA: Ten out of 16 for the --
DR. MARKS: I was leaving 2009 standalone. And what I thought we were at was just taking the no-brainers and
adding it to the 2003, which was proposed.
DR. SLAGA: That’s all we’re doing.
DR. SHANK: But there are no-brainers in 2009.
MS. FIUME: My request --
DR. MARKS: Well, that’s already been --
DR. SLAGA: And that’s what creating a family is.
MS. FIUME: Yes. If you were going to go ahead and reopen it, then could we look at the 2009, 2005, and say yes
there are actually a lot of ingredients that also belong in that family, so that they’re all in one place; if it were to be
reopened.
DR. SLAGA: No-brainers.
DR. ANSELL: Right. But I think you’re turning it kind of upside down. The reopening justification now is to
order the family. And I think that was our original question, is that worth the effort?
MS. FIUME: Well, I guess, step one would be, are there no brainers that are now listed that have not been
reviewed; and is that a reason to reopen to add. And if that is, we take that step. Then can we take the next step of
looking at ingredients that, yes, were reviewed, because we’ve done this many times, and bring them into the family
as well.
So, I’m looking at it as a step process; but if you go ahead and take the first step, is there any reason not to take the
second step and create a whole family.
DR. SLAGA: Maybe that’s a way to bring it up, the way it was stated. That the 2003 additions, no-brainers, and
then approve that, and then say there’s a possibility that the others could be brought in for a family relationship.
MS. BURNETT: I would like to point out that some of the potential add-ons that have the iron included, the iron
was reviewed in 2009. You wouldn’t have that data from the 2003 report, if that would aide anything.
DR. HILL: What you’re saying is we’re not sure if iron is a no-brainer read across. And I’m sort of asserting in
these kinds of materials, it pretty well should be.
MS. BURNETT: Okay.
DR. MARKS: Well, our team should at least -- there’s two different issues. We’re still at -- and we have a split
decision among the panel as to whether we not reopen versus open 2003 report and add the ten “no brainers”. I say
10, it might be 9 or 11.
DR. HILL: It’s around there, somewhere in there.
DR. MARKS: Versus the idea of reopening and consolidate. I hear you, Monice. Right from the get-go we said
we didn’t like to consolidate. But we also hear the idea, well this is in the same family, it’d be nice to have it all on
one report.
Consolidate? Because we’re back to that again. And we shouldn’t -- I don’t think we should go into tomorrow
wavering that way, if we all feel don’t consolidate. And we maybe have a split concern that way. It’ll be interesting
to see -- the good thing for me is I’m seconding the motion.
DR. SLAGA: That’s right. If they say consolidate all of them, we’d say we agree.
MS. FIUME: And as a reminder, we’ve done it in the past where we have reopened, and then the next time you can
come back and then look at it again as an entire family, with more information and change it.
But I just wanted to lay out all the steps. And I understand if it’s not reopened, you know, that’s the panel’s
prerogative. But I just wanted to lay out the steps of how to look at the thought process.
DR. HILL: And what you just said last was what I was proposing, even if it wasn’t obvious by how I said it; is put
the information together and then decide. But it’s staff effort and I really appreciate that.
MS. BURNETT: Already started, so it’s fine.
DR. HILL: Well, I mean, the problem is if they put you on something else --
DR. SLAGA: Alright Jim, you heard that. You could either punch them tomorrow or double punch them.
DR. MARKS: No. I think it would be since we’re split on it, as long as they’re not split, we’re going to probably
agree to whichever way they want to go.
DR. SLAGA: They’re probably playing in their sandbox, right?
DR. MARKS: I see the advantage -- and I have in here consider consolidating with the 2005/2009 report. But my
feeling is if their team -- from what you said Christina you’ve already started that, that consolidating them is not
going to be a huge issue from your point of view. Staffing point of view.
MS. BURNETT: No.
DR. SHANK: Am I the outlier? This is a housekeeping issue as far as I’m concerned.
DR. MARKS: Yeah, exactly.
DR. SHANK: Not a science issue.
DR. MARKS: Yeah.
DR. SHANK: So, if you want to put them together, the staff won’t throw rocks at us --
MS. BURNETT: I would have thrown those rocks a long time ago at somebody else, so it’s good.
MS. FIUME: She would have thrown the rocks at Bart and I.
DR. HILL: I think in putting them together and looking at subgroupings in terms of what can be read across as -- I
don’t know that there’s such as a thing as a real no brainer but anyway -- that fit that criteria to a reasonable degree.
And looking at sub -- I think some things will emerge that if we don’t put them together, okay the sleeping dog will
lie and there’s probably no disaster to that too.
DR. MARKS: I’m going to second what I think’s going to be the proposal to open the 2003 report. Put the add-
ons; ten of them are we think no brainers. I’ll ask you to talk about zinc tomorrow so just so, Ron Hill, you indicate
--
DR. HILL: The silver?
DR. MARKS: Oh, silver. I’m sorry. Sorry, got the wrong metal. Silver, Ron Hill.
DR. HILL: I didn’t bring my advance inorganic chemistry book with me to look at germanium and gold.
DR. MARKS: And then consolidate with the 2005 and 2009 reports and we’ll see where it goes. I want to get to
science now that we’re past the procedural issues. Irritation and sensitization should be fine. It formulates to be
nonirritating. That takes care of the silicates.
As I read it, there was some issues with respiratory in this. Is that true or not? And if it is, at least going forward, I
wanted to get a preview of the science of the respiratory issues and how that’s going to be address with these.
DR. SHANK: And where are you in all this 272 pages?
DR. MARKS: I put respiratory okay, use table 75. I guess there must have been a few things in here. I’m sorry,
Ron, I just highlighted respiratory and I didn’t put a page. I’m not sure where when I look through the report. Ron
Hill?
DR. SLAGA: I didn’t see anything.
DR. SHANK: We have four reports all in one.
DR. MARKS: Yeah, exactly. Let me see if I --
DR. HILL: I was looking at transcripts a lot and starting into this, since I wasn’t around at the beginning.
DR. MARKS: Sorry, Ron. Maybe just put as an alert and as we go -- when it gets all consolidated. It seems to me
it came out -- nothing stood out to you respiratory wise, Ron Hill?
DR. SHANK: Correct.
DR. MARKS: I mean, Ron Shank. Good.
MS. BURNETT: The summarized discussion from the original report mentioned --
DR. MARKS: Here it is. Page 89.
DR. SHANK: Page 89?
DR. MARKS: Page 89. This was the 2003 report. And if you look at the end of -- it says, “Panel considered that
any spray containing these solids should be formulated to minimize their inhalation. With this admonition to the
cosmetic industry, the CIR panel conclude that these ingredients are safe.” So that must have been -- not in a
conclusion, but in the discussion.
And then when you look at page 149, right above -- yeah. The conclusion doesn’t mention any admonition to the
cosmetic industry, which is kind of interesting. I thought that’s pretty strong wording to not have in the conclusion.
And then, if you look right above the conclusion on page 149, not the note, but right before the note. The
concentration of ingredients is very low. That’s the respirable concentration. Even so, the panel considered that any
spray containing these solids should be formulated to minimize their inhalation.
That could have been a conclusion. We do formulate to be nonirritating. Can you formulate to minimize
inhalation? Or is that the way it’s delivered?
DR. SLAGA: That might be coming up soon.
DR. MARKS: That’s where I’m sure I got the inhalation concern.
DR. HILL: Yeah. I was reading back in the transcripts, and the discussion of talc came up which continues to
remain an almost ridiculously contentious issue. But it’s out there, heavily, in the consumer world, in discussion.
Discussion, I use one word.
Because it mentions talc is a hydrated, magnesium silicate. And it gives the chemical composition. This is in the
149, right above the conclusion. Occurs in various forms and has unique crystalline structure. And talc is not
included in this report. The significance there goes to the no-brainer contention with these add-ons.
DR. MARKS: Okay. I just wanted to, Ron, bring that up, and Ron and Tom, about I suspect at some point we’re
going to -- I have to address that again with it being reopened.
DR. SHANK: The respiratory issue?
DR. MARKS: Yeah. Or whether the inhalation boilerplate addresses it.
DR. SHANK: I think it does.
DR. MARKS: Yeah, okay. I think that’s fine. Okay, well, we’ll see what happens tomorrow. I’m planning on
seconding it -- whether it’s the motion or not -- opening the 2003 report with ten no-brainer add-ons. Silver, Ron
Hill, has concerns. And depending on what, I’ll ask you, Ron Hill, to -- and then we’ll consolidate with the 2005
and 2009 reports. Does that sound okay now to everybody?
DR. SHANK: Yes.
DR. MARKS: Good. Okay. And we’ve taken care of the respiratory. Okay. Thank you.
Christina and Monice, that was a -- I don’t know, every ingredient we’ve had there has been some good discussion
so far. Are we going to have one where it’s, yes, that’s fine. Let’s move on to the next one.
Full Panel Meeting:

DR. BELSITO: This is a re-review coming up from 2003, and there are 16 possible add-ons that have not been
assessed by the panel. There were also silicates that have been reviewed and were published in 2005, mainly
potassium silicate, sodium metasilicate, and sodium silicate.
And these would be additional materials that could be incorporated, so bringing that total of 19 into this report. But
then there was also in 2009, assessment of silica and related cosmetics, and that safety assessment, it turns out, was
never published for some reason, and would be due in another six years.
We felt that we could reopen this report; and also in addition to what was reviewed in 2003, include the 16 possible
add-ons that haven’t been looked at. And include the ones from 2005, the three there, as well as the ones in 2009,
that were not published. So, essentially add all of the prior reports on the silicates together, add the new ones.
We need to take a look at this because usage has increased significantly for many of these. And we need a sense of
the concentration of use before we decided on the safety. So, we would like to reopen, combine all of them, and at
this point our real interest is what concentration they’re used at. We may not need additional data based on that.
DR. BERGFELD: So, you’re asking just to reopen and add?
DR. BELSITO: Reopen, add the 16, and combine the prior reports on silicates.
DR. BERGFELD: Okay. Dr. Marks?
DR. MARKS: We second that motion. I just want to clarify. So, you don’t want to move forward with either a
tentative report or an insufficient data announcement with the reopening.
DR. HELDRETH: Reopening would be a tentative report.
DR. MARKS: Okay then, if it’s a tentative report we have to have a conclusion, correct? And I haven’t heard a
conclusion.
DR. BELSITO: Well then, I would say that it’s insufficient for concentration of use of what we’re adding on.
DR. BERGFELD: Okay.
DR. EISENMANN: But we were never asked to do a concentration of use survey, yet, on some of the ingredients;
so, it’s hard to make it to be a tentative report.
DR. HELDRETH: Yeah, we can put up the insufficiency, and we could give industry time to respond with that
information.
DR. MARKS: So, then it would be an insufficient data announcement.
DR. BERGFELD: Is that okay? Agreeable?
DR. BELSITO: I’m fine with whatever the procedures are. I think this will clear pretty quickly once Carol gets us
the data on concentration of use. But it’s hard to say “safe as used,” when we don’t know how the new ones are
used yet.
DR. HELDRETH: Alternatively, we can concede that this can just be considered a report strategy, at this point.
And if you agree with the strategy, then we will create a new report that comes back to you.
DR. BELSITO: I’m fine with that.
DR. BERGFELD: So, it’s just a reopen.

DR. MARKS: And then you wanted to include, of the add-ons, Ron Hill had a question with the silver. You
weren’t happy with including that as a no-brainer on the add-ons?
DR. HILL: I didn’t do it as a no-brainer, but if we’re reopening, which we weren’t clear we were doing in our
session, fully reopening.
DR. MARKS: Oh yeah, we’re reopening.
DR. HILL: Okay. I didn’t know where we landed at the end. Okay, then I think we leave it in for now. But it’s
not necessarily a no-brainer, it’s not clear that we will, for sure, be able to read across, but leave it in for the
moment.
DR. BERGFELD: Any other comments? I’ll call to question then? All those in favor of reopening, please
indicate by raising your hand. Thank you. Unanimous.
Amended Safety Assessment of Silica and Silicates as Used in

Cosmetics
Status: Draft Amended Report for Panel Review

Release Date: November 9, 2018
Panel Meeting Date: December 3-4, 2018
The 2018 Cosmetic Ingredient Review Expert Panel members are: Chair, Wilma F. Bergfeld, M.D., F.A.C.P.;
Donald V. Belsito, M.D.; Ronald A. Hill, Ph.D.; Curtis D. Klaassen, Ph.D.; Daniel C. Liebler, Ph.D.; James G.
Marks, Jr., M.D.; Ronald C. Shank, Ph.D.; Thomas J. Slaga, Ph.D.; and Paul W. Snyder, D.V.M., Ph.D. The CIR
Executive Director is Bart Heldreth, Ph.D. This safety assessment was prepared by Christina L. Burnett, Senior
Scientific Analyst/Writer.
© Cosmetic Ingredient Review

1620 L St NW, Suite 1200◊ Washington, DC 20036-4702 ◊ ph 202.331.0651 ◊fax 202.331.0088
◊ cirinfo@cir-safety.org
INTRODUCTION
The Cosmetic Ingredient Review (CIR) Expert Panel (Panel) previously reviewed the safety of Aluminum Silicate,
Calcium Silicate, Magnesium Aluminum Silicate, Magnesium Silicate, Magnesium Trisilicate, Sodium Magnesium
Silicate, Zirconium Silicate, Attapulgite, Bentonite, Fuller’s Earth, Hectorite, Kaolin, Lithium Magnesium Silicate,
Lithium Magnesium Sodium Silicate, Montmorillonite, Pyrophyllite, and Zeolite in a report that was published in 2003.2
The Panel concluded that these ingredients are safe as used in cosmetic products. In accordance with its procedures, the
Panel evaluates the conclusions of previously-issued reports every 15 years, and it has been at least 15 years since this
assessment has been issued. This report has been reopened to add additional ingredients, including several that were also
previously reviewed: Potassium Silicate, Sodium Metasilicate, and Sodium Silicate (published in 2005 with the
conclusion that these ingredients were safe for use in cosmetic products in the practices of use and concentration
described in the safety assessment when formulated to avoid irritation)3 and Silica, Alumina Magnesium Metasilicate
(now called Magnesium Aluminometasilicate), Aluminum Calcium Sodium Silicate, Aluminum Iron Silicates, Hydrated
Silica, and Sodium Potassium Aluminum Silicate (finalized in 2009 with the conclusion that these ingredients are safe as
cosmetic ingredients in the practices of use and concentrations as described in the safety assessment).4
This report assesses the safety of 40 ingredients (listed below; previously reviewed ingredients are in red) as used in
cosmetics. According to the web-based International Cosmetic Ingredient Dictionary and Handbook (wINCI;
Dictionary; see Table 1), the majority of these ingredients function as abrasives, absorbents, bulking agents, and/or
deodorant agents in cosmetic products.5
Activated Clay Magnesium Aluminometasilicate

Aluminum Calcium Sodium Silicate Magnesium Aluminum Silicate
Aluminum Iron Calcium Magnesium Germanium Magnesium Silicate
Silicates Magnesium Trisilicate
Aluminum Iron Calcium Magnesium Zirconium Montmorillonite
Silicates Potassium Silicate
Aluminum Iron Silicates Pyrophyllite
Aluminum Silicate Silica
Ammonium Silver Zinc Aluminum Silicate Silver Copper Zeolite
Ammonium Silver Zeolite Sodium Magnesium Aluminum Silicate
Attapulgite Sodium Magnesium Silicate
Bentonite Sodium Metasilicate
Calcium Magnesium Silicate Sodium Potassium Aluminum Silicate
Calcium Silicate Sodium Silicate
Fuller's Earth Sodium Silver Aluminum Silicate
Gold Zeolite Titanium Zeolite
Hectorite Tromethamine Magnesium Aluminum Silicate
Hydrated Silica Zeolite
Kaolin Zinc Silicate
Lithium Magnesium Silicate Zinc Zeolite
Lithium Magnesium Sodium Silicate Zirconium Silicate
The Panel has also reviewed other related ingredients. The Panel determined that the ammonium hectorites (i.e.,
Disteardiomonium Hectorite, Dihydrogenated Tallow Benzylmonium Hectorite, Stearlkonium Hectorite, and Quaternium-18
Hectorite) are safe as used in cosmetic ingredients.6 Additionally, silylates and surface-modified siloxysilicates (i.e., Silica
Silylate, Silica Dimethyl Silylate, Trimethylsiloxysilicate, and Trifluoropropyldimethyl/Trimethylsiloxysilicate) are safe as
used in cosmetics when formulated and delivered in the final product not to be irritating or sensitizing to the respiratory
tract.7 The ingredients from these reports are not part of this amended safety assessment.
This safety assessment includes relevant published and unpublished data that are available for each endpoint that is
evaluated. Published data are identified by conducting an exhaustive search of the world’s literature. A listing of the search
engines and websites that are used and the sources that are typically explored, as well as the endpoints that CIR typically
evaluates, is provided on the CIR website (https://www.cir-safety.org/supplementaldoc/preliminary-search-engines-and-
websites; https://www.cir-safety.org/supplementaldoc/cir-report-format-outline). Unpublished data are provided by the
cosmetics industry, as well as by other interested parties.
Some chemical and toxicological data on the Silica and Silicate ingredients included in this safety assessment were
obtained from robust summaries of data submitted to the European Chemical Agency (ECHA) by companies as part of the
REACH chemical registration process.8-14 Additionally, some data were obtained from assessments by the Organisation for
Economic Co-Operation and Development Screening Information Data Sets (OECD SIDS)15-19 and the European Centre for
Ecotoxicology and Toxicology of Chemicals (ECETOC).20 These data summaries are available on the ECHA, OECD SIDS,
and ECETOC websites, respectively, and when deemed appropriate, information from the summaries has been included in
this report.
Excerpts from the summaries of the 2003 and 2005 reports are disseminated throughout the text of this re-review
document, as appropriate, and are identified by italicized text. (This information, except for chemical and physical
properties, is not included in the tables or the summary section.) The Silica report (2009) has been incorporated into this
safety assessment due to reorganization. The original reports that were published in 2003, 2005, and 2009, and reports on
related ingredients, are available on the CIR website (https://www.cir-safety.org/ingredients).
CHEMISTRY
Definition
These inorganic oxide ingredients, comprising in part, silicon dioxide, are solids derived from naturally occurring
minerals. Specifically, many of these ingredients are directly derived from various Silicate clay minerals. However, these
ingredients can be produced synthetically; and in the case of Silica and Hydrated Silica, these are more commonly prepared
as such for commercial purposes. The definitions and functions of the Silica and Silicate ingredients included in this safety
assessment are provided in Table 1.
Silica
Silica is a silicon-oxygen tetrahedral unit where a silicon atom is central within 4 oxygen atoms that are shared with
adjacent silicon atoms.21 Various physical forms of Silica are caused by differences in the spatial relationships of the
tetrahedral that determine physical characteristics. Amorphous Silica has an irregular tetrahedral pattern. Crystalline Silica is
polymorphic where each variety has a characteristic regular 3-dimensional arrangement of the tetrahedral. As would be
predicted from these descriptions, crystalline Silica has a well-defined x-ray diffraction pattern; whereas amorphous forms of
Silica do not.1 Only synthetic amorphous Silica forms are used in cosmetics and this safety assessment is limited to these
forms of Silica; crystalline Silica forms are not used in cosmetics.
The CAS No. 7631-86-9 is the general CAS No. which includes all forms of silicas including amorphous,
crystalline, synthetic, and natural forms.16 The amorphous forms of Silica may also be referred to as amorphous silicon oxide
hydrate, silicic anhydride, silicon dioxide, and silicon dioxide, fumed.5 Pyrogenic Silica is the current terminology for silicon
dioxide, fumed.4
Hydrated Silica
Hydrated Silica may also be referred to as hydrosilicic acid, precipitated Silica, Silica gel, Silica hydrate, silicic acid,
silicic acid hydrate, silicon dioxide hydrate, synthetic amorphous silicon dioxide, and colloidal Silica.5,22
Physical and Chemical Properties

All silicates have the great ability to adsorb, especially the clays.2 Reports describe drugs, bacteria, viruses, and
toxins adsorbed to clays due to the physical structure of clays and their cationic nature.
Physical and chemical properties of the Silica and Silicate ingredients are provided in Table 2. These ingredients
generally are not soluble in water.
Silica and Hydrated Silica

The Food Chemicals Codex states that Silica is a white, fluffy non-gritty powder of extremely fine particle size that
is hygroscopic. Silica absorbs moisture from the air in varying amounts.23 Amorphous silicas are composed of very fine
particles (average of 20 µm) which tend to aggregate loosely in the air.24 Primary particles, or single particles, exist only in
the colloidal form of Hydrated Silica.20,25 Aggregates assemble in chains (Silica; pyrogenic) or clusters (Hydrated Silica;
precipitated and gel). Agglomerates are assemblies of aggregates, held together by strong physical adhesion forces and not in
a dispersible nano size (< 100 nm).
The acidity of synthetic amorphous Silica is related to the number and reactivity of the silanol groups present on the
solid Silica surface.26 Surface silanols (pKa = 7.1) are more acidic than monosilicic acid (pKa = 9.8). The acidity increases
with the degree of polymerization. The surface of Silica may be made up of free silanol groups (isolated hydroxyls),
hydrogen-bonded silanol groups (hydroxyl groups on adjacent surface silicon atoms), and siloxane groups.1 Amorphous
Silica is capable of rehydroxylating in aqueous systems to form a high ratio of silanol to siloxane groups. Depending on the
hydrophobic properties of the solvent, it may form a network-like structure through hydrogen bonding. This gives
amorphous Silica gelling and thickening abilities in various solvent systems. Oxygen electron donors of compounds such as
ethers, alcohols, and ketones or the nitrogen of amides and amines may interact through hydrogen bonding due to the acid
dissociation constant of the silanol groups on the Silica surface. Esterification has been reported with a Si-O-C-R structure.
A totally dehydrated Silica or a fully hydrated Silica has little or no adsorption of hydrophobic organocompounds.
Method of Manufacturing
Silica and Hydrated Silica used in cosmetics are synthetically produced. A manufacturing process for Silica
(pyrogenic form) is shown in Figure 1.1 Mean particle size, particle size distribution, and degree of aggregation and/or
agglomeration can be determined by adjusting processing parameters.27
Silica may be produced by a vapor-phase process.28 The pyrogenic form of Silica is produced in a relatively
anhydrous state. Hydrated Silica is produced by a wet process and contains a large amount of bound water.
Silica
Silica is reported to be > 95% pure.16 Possible impurities include: Na 2 O (0.2% to 2.1% wt.), sulfates as SO 3 (0.2% to
3.0% wt.), Fe 2 O 3 (< 0.05% wt.), and trace oxides (<0.07% wt.). Heavy metal impurities include: antimony (< 5 ppm),
barium (< 50 ppm), chromium (< 10 ppm), arsenic (< 3 ppm), lead (< 10 ppm), mercury (< 1 ppm), cadmium (< 1ppm), and
selenium (< 1 ppm).
A manufacturer has stated that its Silica products are > 99.8% pure.29 The moisture content of untreated Silica is < 1
wt%. Treated Silica is susceptible to adsorbing chemical vapors.
USE
Cosmetic
The safety of the cosmetic ingredients included in this assessment is evaluated based on data received from the US
Food and Drug Administration (FDA) and the cosmetics industry on the expected use of these ingredients in cosmetics. Use
frequencies of individual ingredients in cosmetics are collected from manufacturers and reported by cosmetic product
category in the FDA Voluntary Cosmetic Registration Program (VCRP) database. Use concentration data are submitted by
the cosmetics industry in response to surveys, conducted by the Personal Care Products Council (Council), of maximum
reported use concentrations by product category.
According to 2018 VCRP data, Silica has the most reported uses in cosmetic products, with a total of 8024; the
majority of the uses are in leave-on eye makeup preparations and makeup preparations (Table 3 and Table 4).30 Kaolin has
the second most reported uses in cosmetic products, with a total of 1794; the majority of the uses are also in leave-on eye
makeup preparations and makeup preparations. The reported numbers of uses for the remaining ingredients in this report are
much lower. The frequencies of use for both of these ingredients have greatly increased since the original safety assessments
were finalized: in 2009, Silica was reported to have 3276 uses and in 1998, Kaolin was reported to have 509 uses.2-4 The
results of the concentration of use survey conducted in 2018 by the Council indicate Silica has the highest reported maximum
concentration of use; it is used at up to 82% in face and neck products and 50% in mascaras.31,32 Kaolin is used at up to 53%
in “other” manicuring products and up to 35% in rinse-off “other” skin care preparations.31 According to the original safety
assessment, the maximum use concentration in 1999 for Kaolin was 100% in leave-on “other” skin care preparations.
Additonally, the maximum use concentration for Hectorite was 100% in rinse-off skin cleansing preparations (the maximum
leave-on concentration was 15% in makeup foundations).2 Silica was reported to be used at up to 44% in eye shadows in
2008.4 Cosmetic ingredients with no reported uses in the VCRP database are listed in Table 5.
Many of the Silicate ingredients described in this safety assessment may be used in products that can be incidentally
ingested or come into contact with mucous membranes; for example, use is reported in lipsticks and oral hygiene products.30
Hydrated Silica was reported to be in dentifrices at up to 17.1%.32 Additionally, these ingredients have been reported to be
used in products that may come into contact with the eyes, such as eye shadows, eye liners, and mascaras. Silica was
reported to be used at up to 50% in mascaras.32 Moreover, these ingredients are reported to be used in spray products and
powders that could possibly be inhaled, like hair sprays and face powders. Hydrated Silica was reported to be used at up to
0.9% in a hair spray and Silica was reported to be used at up to 66% in face powders.32 For ingredients where there is a lack
of inhalation data, the Panel has noted that in practice, 95% to 99% of the droplets/particles released from cosmetic sprays
have aerodynamic equivalent diameters > 10 µm, with propellant sprays yielding a greater fraction of droplets/particles
below 10 µm compared with pump spray.33-36 Therefore, most droplets/particles incidentally inhaled from cosmetic sprays
would be deposited in the nasopharyngeal and bronchial regions and would not be respirable (i.e., they would not enter the
lungs) to any appreciable amount.33,35 Silicates are also used in powders, and these products could possibly be inhaled.
Conservative estimates of inhalation exposures to respirable particles during the use of loose powder cosmetic products are
400-fold to 1000-fold less than protective regulatory and guidance limits for inert airborne respirable particles in the
workplace.37-39
In regulations on cosmetic products in the European Union, zirconium and its compounds (including Zirconium
Silicate) are listed under Annex II-substances prohibited in cosmetic products. 40 Aluminum Silicate, Bentonite, and Kaolin
are listed under Annex IV – colorants allowed in cosmetic products. The remaining Silicate-related ingredients listed in this
report are not restricted from use in any way under the rules governing cosmetic products in the European Union.
According to Australia’s National Industrial Chemicals Notification and Assessment Scheme (NICNAS), the
following ingredients are Tier I chemicals (not considered to pose an unreasonable risk to the health of workers and public
health on the basis of the Tier I Inventory Multi-tiered Assessment and Prioritization (IMAP)): Aluminum Silicate, Bentonite,
Calcium Silicate, Fuller’s Earth, Kaolin, Magnesium Silicate, Magnesium Trisilicate, Montmorillonite, Sodium Potassium
Aluminum Silicate, Zeolite, and Silica (as amorphous, fumed, crystalline-free; gel; gel-precipated, crystalline-free; and
vitreous).41 Attapulgite, Potassium Silicate, Sodium Silicate, and Sodium Metasilicate are Tier II chemicals (require risk
management measures to be instituted for safe use for human health or the environment). The remaining silicates have no
NICNAS determination.
Non-Cosmetic
Aluminum Silicate is approved as an indirect food additive in the Code of Federal Regulations (CFR).2
Bentonite is considered generally recognized as safe (GRAS) as a direct food additive and Kaolin is considered GRAS
as an indirect food additive. Pyrophyllite is listed as a naturally occurring color additive in the CFR. Calcium Silicate,
Magnesium Aluminum Silicate, Magnesium Trisilicate, Attapulgite, Hectorite, and Kaolin are all used in over-the-
counter drug products.
Potassium Silicate and Sodium Silicate were reported as being used in industrial cleaners and detergents.3
Sodium Metasilicate is a GRAS food ingredient.
Aluminum Calcium Sodium Silicate

Aluminum Calcium Sodium Silicate (hydrated) is used for countering the effects of aflatoxin in animal feed.42-53
This ingredient is also GRAS in the US in food for use as an anticaking agent at a level not exceeding 2% in accordance with
good manufacturing practices (21 CFR §182.2729).
Calcium Silicate
Calcium Silicate is used in endodontics in root canal sealer preparations and dental cements.54-56
Fuller’s Earth
Fuller’s Earth is reported to be used as military decontaminant for removal of hazardous materials from the skin.57
Hydrated Silica
Hydrated Silica (colloidal) is used in fiber, sizing, diazo paper manufacture, cellophane film, ceramics, grass fiber,
paints, batteries, foods, and polishing.58
Silica
Silica is used in pharmaceuticals as a thickener in pastes and ointments to inhibit the separation of components and
maintain flow properties in powder products.16 It is also a general excipient for pharmaceuticals.1,59 Silica can function as a
carrier for fragrances.16 Silica is used in animal feed as carriers and anticaking agents in vitamins and mineral premixes.
Silica is also used in paints, lacquers, plastics, paper, and in the production of “green tires”. Silica is used as an insecticide by
cuticular lipid layer dehydration. Silica is used as reinforcing fillers for many non-staining and colored rubber and silicone
products.16,24
Silica has many uses in foods and food preparations.1,16,60 These include use as an anticaking agent in dry powders, a
dispersion agent for dry powders in liquids, an anti-settling or suspending agent, a stabilizer in oil/water emulsions, a
thickening or thixotropic agent, a gelling agent, a flavor carrier, an extrusion aid, a clarification and separation aid, and a
support matrix for immobilization of enzymes. It is also used as a defoaming agent, conditioning agent, a chill-proofing agent
in malt beverages, and a filter aid in foods.
Sodium Magnesium Aluminum Silicate

Sodium Magnesium Aluminum Silicate is reported to be used in print enhancement (imparting high brightness and
opacity), paper filer, and carbonless copy intensifier.61
Zeolite
The use of Zeolite has been investigated for use in oral drug delivery of acidic medications, such as aspirin.62
Zinc Silicate
Zinc Silicate is reported to be used as phosphors (in television screens), in spray ingredients, and to remove traces of
copper from gasoline.61,63
TOXICOKINETICS
Absorption, Distribution, Metabolism, Excretion (ADME)
No statistically significant absorption of aluminum and elevated levels of silicon were recorded in assayed plasma
samples of dogs given Magnesium Trisilicate and Zeolite orally.2 The urinary excretion of Silica was 5.2% in males
given 20 g of Magnesium Trisilicate. Ten percent Bentonite in the diets of rats overcame T-2 toxicosis completely.
Various Zeolites were added to the diets of pigs. No adverse effects were noted by the supplementation.
A sample of Aluminum Silicate was toxic to pulmonary alveolar macrophages and lactate dehydrogenase activity
(LDH) and β-galactosidase (β-GAL release were increased.2 Aluminum Silicate had relatively no effect on the
hemolysis of rat red blood cells (RBCs). Synthetic Calcium Silicate samples and higher concentrations of Calcium
Silicate caused increased hemolysis of human RBCs; a greater fibrous character of Calcium Silicate samples caused
increased LDH and β-GAL release.
Sodium Silicate administered orally acts as a mild alkali and was readily absorbed from the alimentary canal
and excreted in the urine.3 Urinary excretion of Sodium Silicate given orally to rats at 40 and 1000 mg/kg was 18.9%
and 2.8%, respectively.
Oral
Silica
In an oral study of Silica in an aqueous suspension, female rats (strain and number not specified) received 1500
mg/kg/d for 30 days via gavage.16 Controls were not described. The rats were then killed and necropsied. The Silica content
in the livers, kidneys, and spleen was 1.5 µg (control value = 1.8 µg), 6.4 µg (7.2 µg), and 5.3 µg (7.8 µg), respectively.
In a similar study, 20 female Sprague-Dawley rats received Silica via gavage in an aqueous suspension (100 mg/rat;
~500 mg/kg) 20 times over one month.16 Controls were not described. No clinical signs of toxicity were observed. The
Silica content in the liver, spleen, and kidneys was 4.2 µg (control value = 1.8 µg), 5.5 µg (7.2 µg), and 14.2 µg (7.8 µg),
respectively.
Silica, Hydrated Silica, and Sodium Metasilicate

In a dietary ADME study, 5 guinea pigs received Silica (0.8 mg/g feed) as three separate forms (Sodium
Metasilicate, Hydrated Silica, and Silica solution (30%)) in single doses or in four repeated doses every 48 h.64,65 Urine and
feces were collected in 48-h increments after each dose of each form and analyzed for Silica content. The urinary output of
Silica, in the form of Sodium Metasilicate, peaked within 48 h and gradually returned to normal after eight days. When
administered four times, 48 h apart, the peak was maintained, but did not increase. Within 48 h after the last dose, the
concentration of Silica in the urine began to return to normal. With the Silica solution and Hydrated Silica, the urinary output
of Silica also peaked within 48 h and gradually returned to normal after eight days, but the peaks were much lower than those
observed with Sodium Metasilicate. When administered four times, 48 h apart, the Silica concentrations behaved similarly to
the Sodium Metasilicate form, except with a lower peak. In this study, approximately 63% of the Silica was recovered. The
authors of the study suggested that the Silica in the urine was in the soluble or molybdate reactive form, and that the Silica
particles underwent depolymerization prior to excretion.
Inhalation
The retention and elimination of aerosolized Silica (initial dose and particle size not reported) was studies in female
inbred albino rats (strain and number not reported).16 The rats were exposed to the test material for 40 days. The amount was
then increased to 40 to 50 mg/m3 until day 120. Groups of rats were killed and necropsied periodically through the test
period.
The average 1-day retention value was 28 µg/lung at the lower unspecified concentration. During the first 10 days, a
steep linear increase was seen with ~28 µg/day as theoretically expected. Increments then became smaller. The author
suggested that elimination increased and that an equilibrium between retention and elimination was established. After 40
exposures, the average 1-day retention value was 59 µg/lung at the high concentration. After 120 exposures, the total deposit
(lung and mediastinal lymph nodes) was 435 µg/lung, equivalent to 7.4 % of the theoretically deposited material (5840
µg/lung, based on the measured 1-day retention); more than 92% of the deposited Silica in the alveoli was eliminated during
the exposure period. At that time, the mean retention of the lungs was 300 µg/lung (~ 69% of the total). The deposition rate
in the mediastinal lymph nodes was negligible during the first 40 days, but increased gradually. After 120 exposures, the
retention was substantial amounting to 135 µg (~ 31% of the total deposit). A test for the determination of free alveolar cells
showed a decrease immediately after a single exposure and 24 hours later an increase of 100% was observed.16
In another retention and elimination study, female Sprague-Dawley rats (number not reported) were exposed to
aerosolized Silica (0.050 to 0.055 mg/l; particle size not provided) for 5 h/d for 5 d/week for one year.16 Because the rats had
occurrences of bronchitis, putrid, lung inflammation, and pronounced cell reactions, the exposure incidences were reduced to
2 or 3 d/week. Rats in each group were killed and necropsied periodically during treatment and after treatment.
After 6 weeks of treatment, Silica was observed in the lungs (0.5 mg) and the mediastinal lymph node (0.02 mg); after
18 weeks these values were 1.2 mg and 0.11 mg; and after 12 months, the values were 1.37 mg and 0.13 mg, respectively.
Corresponding to the respiration volume, 1% of the inhaled Silica was retained in the lungs. After a recovery period of 5
months, there was 0.160 mg and 0.047 mg Silica observed in the lungs and mediastinal lymph node, respectively, with a
reduction of 88% in the lung and > 50% in the lymph nodes. The increase in lung deposition was rapid at the initial
exposure; levels of deposited Silica were low from 18 weeks to 12 months of exposure.16
In an elimination study, aerosolized Silica (0.05 mg/l; particle size not provided) was administered for 5 h per day for
3 days to female Sprague-Dawley rats (number not specified).16 The rats were observed for up to 3 months. Twenty h after
the last exposure, 0.25 mg Silica was found in the lungs. After 3 months, the Silica content was 0.018 mg. In the lymph
node, 0.018 mg Silica was found after 1 month and 0.008 mg Silica after 3 months.
Another elimination study of Hydrated Silica (55 mg/m3; particle size not provided), rats (details not provided) were
exposed to the test materials for 5 h.16 The mean retention value at 20 h was 0.138 mg/lung. The mean Silica-content of the
lungs for Hydrated Silica was 1.022 mg after 4 months recovery and 3.113 mg after 12 months recovery. The corresponding
values for the mediastinal lymphatic nodes were 0.033 mg and 0.069 mg, respectively. Five months after exposure, the
average value for the lungs was only 0.457 mg (87% elimination rate) and 0.052 mg for the mediastinal lymphatic nodes.
An elimination study was performed on rats (details not provided) exposed to aerosolized Silica (hydrophoblic; 50
mg/m3; particle size not provided) for 1or 3 days.20 The rats were killed and necropsied after 20 h, 1 month, or 3 months. At
1 month recovery, elimination of Silica was 78% (1 day exposure) and 75% (3 days exposure). After 3 months recovery,
elimination was 87% and 92%, respectively. There was little Silica in the mediastinal lymph nodes.
Rats (details not provided) were exposed to aerosolized Silica (hydrophobic; 200 mg/m3; particle size not provided) in
an elimination study for 5 h/d for 3 days.20 After a 3 month recovery period, 81% of the Silica was eliminated. Elimination
by the lymph nodes was marginal.
Subcutaneous
Silica
In a subcutaneous study in female Sprague-Dawley rats (number not provided), 6.89 mg Silica was measured in the
tissue 24 h after a single dose of 10 mg was injected.16 One month after injection, the amount of Silica had decreased to
0.646 mg, and after 2 months, the amount of Silica at the injection site was 0.298 mg.
In another study, Silica (10 mg in water) was subcutaneously injected in rats (no further details).20 The Silica was
quickly removed from the injection site with a mean recovery of 6.90 mg at 24 h, 0.65 mg after 1 month, and 0.30 mg after 2
months.
Approximately 95% to 97% of Silica (30, 40, or 50 mg in water) injected subcutaneously in rats was recovered 6
weeks after treatment (no further details).20
TOXICOLOGICAL STUDIES
Acute Toxicity Studies
The following are a list of acute oral LD 50 determinations: Calcium Silicate, 3400 mg/kg in rats; Magnesium
Aluminum Silicate, 50,000 mg/kg in mice; Zirconium Silicate, > 200 g/kg in mice; Hectorite, > 5 g/kg in rats; Kaolin,
149 g/kg in rats (death due to bowel obstruction); 15 natural Zeolites, 10 g/kg in rats.2 The acute dermal LD 50 was >
3.5 g/kg for rabbits exposed to Magnesium Aluminum Silicate.
The toxicity of Potassium Silicate, Sodium Metasilicate, and Sodium Silicate has been related to the molar
ratio of SiO 2 /Na 2 O and the concentration.3 The acute oral LD 50 of Sodium Metasilicate ranged from 847 mg/kg in
male rats to 1349.3 mg/kg in female rats, and from 770 mg/kg in female mice to 820 mg/kg in male mice. Gross lesions
of variable severity were found in the oral cavity, pharynx, esophagus, stomach, larynx, lungs, and kidneys of dogs
receiving 0.25 g/kg or more of a commercial detergent containing Sodium Metasilicate. Similar lesions were seen in
pigs given the same detergent and dose as in the previous study. Male Sprague-Dawley rats orally administered 464
mg/kg of a 20% solution containing either 2.0 or 2.4 ratio of Sodium Silicate to 1.0 ratio of sodium oxide showed no
signs of toxicity, whereas doses of 1000 and 2150 mg/kg produced gasping, dyspnea, and acute depression. Acute
intraperitoneal injections of a neutralized 2% solution of Sodium Metasilicate in white rats resulted in a decrease in
spleen weight and relative enlargement of the kidneys.
Acute dermal, oral, and inhalation data are summarized in Table 6. Hydrated Silica in water and Potassium Silicate
(30%) had dermal LD 50 s greater than 5 g/kg in rabbits and rats, respectively.10,16,20,68 In oral rat studies, the LD 50 s for
Aluminum Silicate (concentration not reported), Calcium Silicate (20%), Hydrated Silica (26% in water), Potassium Silicate
(concentration not reported), Silica (in stock diet 1:4 w/w), Sodium Magnesium Aluminum Silicate (concentration not
reported), and Sodium Silicate were > 2 g/kg, > 10g/kg, 40 g/kg, > 5 g/kg, > 10 g/kg, > 2 g/kg, and up to 8.65 g/kg,
respectively.9,10,12-16,20,28,69,70 An oral LD 50 for Sodium Silicate in mice was 6.60 g/kg.12 Orally administered Aluminum
Calcium Sodium Silicate had no adverse effects up to 800 mg/kg in mice.71,72 In inhalation studies, the LC 50 s for Hydrated
Silica (30% SiO 2 ), Potassium Silicate (30%), and Silica (concentration not reported) in rats were > 3300 mg/m3, > 2060
mg/m3, and > 191,300 mg/m3, respectively.10,16,20,28,73
Short-Term and Subchronic Toxicity Studies

In short-term oral toxicity studies, no adverse effects were seen in mice or rabbits dosed up to 5 g/kg
Magnesium Aluminum Silicate; beagle dogs and rats fed Aluminum Silicate had no renal lesions.2 Dogs and rats fed
Magnesium Trisilicate for 4 weeks had polydipsia and polyuria, and all dogs had renal cortical lesions. Guinea pigs
had renal lesions after 4 months of drinking Magnesium Trisilicate in their tap water. Rats fed 10% Magnesium
Aluminum Silicate had slightly elevated silicon levels of the spleen and dogs and rats fed 10% Magnesium Aluminum
Silicate had no negative responses in 90-day feeding studies.
Beagle dogs fed 2.4 g/kg/day of Sodium Silicate for 4 weeks had gross renal lesions but no impairment of renal
function. In an oral subchronic study (drinking water containing 600 and 1200 ppm of added Silica), there were body
weight gains in male rats, but decreases in female rats. No apparent effect of the treatment in the drinking water was
found on the longevity in rats having started treatment after weaning.
Dermal and Oral

Short-term and subchronic dermal and oral toxicity studies for Hydrated Silica, Montmorillonite, and Silica are
summarized in Table 7. No adverse effects were reported in a 3 week dermal study of Silica (up to 10 g/kg/d) in rabbits.16,20
In short-term oral studies, the no observed adverse effect level (NOAEL) for Hydrated Silica was > 24.2 g/kg/d in a 14 day
dietary study in rats. Mild gastrointestinal effects were the only adverse effects reported in a 2 week study of
Montmorillonite in human subjects that received up to 3.0 g/day of the test material.74 The no observed effect level (NOEL)
was 500 mg/kg/d in a 5 to 8 week dietary study in rats that were fed up to 16,000 mg/kg/d Silica.28,70,75 In subchronic oral
studies, the NOEL was 4000 mg/kg/d in a 13 week dietary study in rats fed Hydrated Silica at up to 4000 mg/kg/d.20 No
adverse effects were reported in rats that received 40 mg/kg/d Montmorillonite for 90 days (no further details provided).76
No clinical signs of toxicity or gross or microscopic changes were reported in a 13 week dietary study in rats that received up
to 3500 mg/kg/d Silica.16,20
Inhalation
Hydrated Silica
In an inhalation study, 45 male Fischer 344 rats were exposed to aerosolized Hydrated Silica (30 mg/m3; particle
size not provided) for 6 h/d for 8 days.77,78 The recovery period was up to 112 days. During exposure, there was an early and
transient influx of cells into the lung tissue which returned to normal by day 12. At 5 days post-exposure, the number and
differential counts of alveolar lavage-derived cells were similar to controls. The brochalveolar lavage (BAL) protein, lipid
phosphorus, and saturated dipalmitoyl phosphatidyl-choline levels increased immediately after exposure and were normal by
day 5 post exposure. There were no differences between controls and treated lungs as to weight, DNA-, protein-, or
hydroxyproline-content. The authors concluded that inhaled Silica caused an early, transient alveolar inflammatory response,
without producing fibrosis. There was only a mild inflammatory response with no evidence of connective tissue response.
Male CD BR rats (number not provided) were exposed to aerosolized Hydrated Silica (10.1, 50.5, and 154 mg/m3;
diluted 4:1 with deionized, distilled water; particle size not provided) for 6 h/d, 5 d/week, for 4 weeks followed by a 10 and
94 day recovery period.79,80 The controls were unexposed. Lesions were only observed in lungs and associated draining
lymph nodes. There was a dose-dependent increase in mean lung weight and lung to body weight ratio after 4 weeks of
exposure in the mid and high dose groups. The mean lung to body weight ratio continued to increase in the high dose group
10 days into recovery, but was similar to controls after 3 months. There were dust laden alveolar macrophages, neutrophilic
infiltration, and Type II pneumocyte hyperplasia observed in the alveolar duct region of the lungs. Pulmonary lesions
progressively decreased in rats examined after the 10 day and 3 month recovery period.
At 3 months post-exposure, most dust-laden alveolar macrophages were cleared from the lungs, but small numbers
of minute silicotic nodule-like lesions were present in the alveolar ducts and perivascular regions where dust laden alveolar
macrophages had aggregated. There was minimal collagen deposition observed in the silicotic nodule-like lesions; the
lesions did not increase in size or number over time. The lung clearance half-life was ~50 days for the mid and high dose
groups. In the high dose group, there was an increase in mean neutrophil count and globulin concentration and a decrease in
mean lymphocyte count at the end of the treatment. The increase in mean neutrophil count and decrease in mean lymphocyte
count were still present after 3 months of recovery. The tracheal and mediastinal lymph nodes were enlarged with nodular
aggregates of dust-laden alveolar macrophages and hyperplastic reticulo-epithelial (RE) cells. The NOAEL was 10.1
mg/m3.79,80
In another inhalation study, groups of 25 male Crl:CD(SD)BR rats were exposed to aerosolized Hydrated Silica (0,
10, 50, or 150 mg/m3; particle size not provided) for 6 h/day, 5 days/week for 4 weeks.81 Some of the rats were killed at the
end of the exposure period, at 10 days, or 3 months. There were dose-dependent lesions observed in the mid and high dose
groups but not in the low dose group. Particles were mostly phagocytized by alveolar macrophages in the alveolar duct
region and a few free particles were observed in Type I pneumonocytes in the alveoli. Particle-laden alveolar macrophages
directly penetrated into the brochiolar interstitium from alveoli and accumulated in bronchus-associate lymphoid tissue,
peribronchial, or perivascular interstitium and accumulated in the tracheo-bronchial lymph nodes. Some particle-laden
alveolar macrophages in the bronchus-associated lymphoid tissue transmigrated directly into bronchial lumen through the
epithelium. The transmigrated particle-laden alveolar macrophages in the tracheo-bronchial lymph nodes were similar to
those in the alveoli. They were characterized by slender cytoplasmic processes, phagosomes, myelin figures, cholesterol
clefts, and lipid droplets. Migrated particle-laden alveoli macrophages were observed to be necrotic and have released
particles in the tracheobronchial lymph nodes.
At 3 months, the lungs of the low dose group were normal. The lungs of the mid dose group were normal in
appearance, but a small number of tiny nodular aggregates of dust-laden alveoli macrophages and epithelioid cells were
observed. One rat had a few silicotic nodules in perivascular regions adjacent to the bronchioles. The high dose group had
decreased numbers of particle-laden alveoli macrophages that were sharply circumscribed in the alveoli. Some aggregates of
particle-laden alveoli macrophages and epitheliod cells were closely apposed with alveolar walls and transformed into
nodular aggregates without any collagen fiber deposition. Three of 10 rats had silicotic nodules in the perivascular region of
the bronchioles.81
In a 13 week study, male and female Wistar rats were placed in a whole body inhalation chamber 6 h/d, 5 d/week
and exposed to Hydrated Silica at 35 mg/m3 (particle and agglomerate/aggregate size 1 to ~120 µm).82 The rats were
periodically killed and necropsied over the 52-week recovery period.
Slightly decreased body weight and increased lung and thymus weights were observed. Necropsy revealed swollen
and spotted lungs and enlarged mediastinal lymph nodes. Microscopic examination of the lungs revealed accumulation of
alveolar macrophages, intra-alveolar leukocytes, and increased septal cellularity. There was also accumulation of
macrophages in the lymph nodes. The collagen content in the lungs was slightly increased. During the recovery period, the
effects of Silica exposure were mostly gone within 26 weeks. Accumulation of Silica and macrophages in the mediastinal
lymph nodes were still present at the end of the recovery period.82
Hydrated Silica and Silica

Young adult Wistar (Crl:WI)WU BR) rats (10 male and 10 female per dose group) were exposed nose-only to either
2 types of aerosolized Hydrated Silica (precipitated and gel forms) or Silica at 1, 5, or 25 mg/m3 (particle sizes not provided)
for 6 h/d for 5 consecutive days followed by a 3-month recovery period.22 The rats were killed and necropsied. There were
no clinical signs of toxicity during exposure. The effects were limited to 1 day post exposure. Silica levels in the
tracheobronchial lymph nodes were below detection limits in all 3 groups. Silica was found in the lungs at day 1 but had
cleared by 3 months. All 3 test materials induced biomarkers of cytotoxicity in BAL fluid, increases in lung and
tracheobronchial lymph node weights, and histopathological lung changes in the high dose groups at day 1 post exposure.
The mid dose only induced histopathological changes and changes in BAL fluid. The effects of all 3 test materials, with the
exception of slight histopathological lung changes at the higher exposure levels, were reversed during the recovery period.
The low dose caused no adverse effects.
Silica
In a short-term inhalation study, 15 Fischer 344 rats were exposed to aerosolized Silica for 8 days (no further
details).78 Three of the rats were killed and necropsied at days 0, 5, 12, 60, and 120 after exposure. There was initial
inflammation, predominantly alveolar, which subsided before day 12.
In another short-term inhalation study, groups of 40 male and 40 female Wistar rats were exposed to Silica (17, 44,
or 164 mg/m3; particle size not provided) in a whole body exposure chamber for 6 h/d, 5 d/week for a total of 14 days.82 The
control was 6 male and 6 female unexposed rats. Respiratory distress was observed in all groups. One female in the high
dose group died. Body weights and feed consumption were decreased in the males in the mid and high dose groups.
Hematological measurements were unremarkable. There were increased lung weights in both sexes (47%, 65%, and 86% for
the low, mid, and high dose groups) compared to controls. The absolute and relative liver weights were decreased in males,
but not females. Dose-dependent changes were observed in the lungs (i.e., pale, spotted and/or spongy, occasionally irregular
surface, alveolar interstitial pneumonia, early granulomata). The mediastinal lymph nodes were enlarged.
The above study was repeated with Silica (46, 180, or 668 mg/m3) on groups of 30 male and 30 female Wistar
82
rats. Respiratory distress was observed in all groups. One male died in the high dose group. Body weights were decreased
in the male mid and high dose groups and in the high dose females. Feed consumption was decreased in both sexes in the
mid and high dose groups. There were increased lung weights in both sexes compared to controls (males 25%, 39%, and
68%; females 34%, 50%, and 86% in the low, mid, and high dose groups, respectively). There were decreased liver weights
in males of all dose groups and the high dose group females. The lungs were spotted, swollen, and had irregular surfaces in
the high dose groups as well as interstitial pneumonia and early granulomata. Silica was observed in the mediastinal lymph
nodes in the mid and high dose groups and 1 rat in the low dose group. An accumulation of alveolar macrophages and
particulate material was observed in the lungs of males in the mid and high dose group.
In another inhalation toxicity study, female Wistar rats (number not reported) were exposed to aerosolized Silica (8
and 40 mg/m3; particle size not provided) for 1 h/d, 5 d/week for up to 3 months.16 The rats were killed and necropsied at 7 d
and 3 weeks after treatment. No macroscopic changes were noted. Histopathologically, there was an occurrence of dust cells
in the lungs which decreased post-exposure. There was no fibrosis of the reticulo-cellular type and normal parenchyma of
the lungs. A decrease of Silica content in the lungs was observed 7 and 48 days after treatment termination. After 3 months,
there was almost no Silica in the lungs.
Groups of 10 male and 10 female Wistar rats were exposed to Silica (0, 0.51, 2.05, or 10.01 mg/m3; particle size not
provided) for 6 h/d, 5 d/week for 13 weeks.20 A group of rats from each dose group was allowed to recover for 13 weeks
before being killed and necropsied. Silica was observed in the lungs in a concentration dependent manner at the end of
exposure. Silica was observed in the tracheobronchial lymph nodes in the high dose group. After recovery, the amount of
Silica in the lungs was below detection limits in the low dose group and only a small amount was detected in the high dose
group.
In a 13-week inhalation study of Silica (1.3, 5.9, or 31 mg/m3; particle size not provided) using groups of 50 male
and 50 female Wistar rats, the animals were subjected to full body exposure for 6 h/d, 5 d/week. Ten rats of each sex were
killed and necropsied at weeks 13, 26, 39, and 52.82 There were no mortalities during treatment or recovery. Clinical signs
were increased respiration rates in a dose dependent manner and body weight gains were depressed. RBC count was
increased in males in the high-dose group. In the mid- and high-dose groups, white blood cells (WBC) were elevated in both
males and females; the concentration-response relationship was poor. Blood cell counts returned to normal by week 39.
Necropsy at 13 weeks revealed swollen and spotted lungs and enlarged mediastinal lymph nodes; the severity was dose
dependent. All groups had increased lung weights and collagen content, less so in the low-dose group. All these effects
reduced to control levels by the end of the study except for collagen content in males in the mid- and high-dose groups.
After treatment, Silica could be detected in the lungs of all the rats in relatively small amounts. In the high-dose
group, the average Silica amount in the lungs was 0.2 mg. Silica was detected in 1 male in this group in the regional lymph
node. At the end of the study, no Silica above control levels could be detected in any rat. Microscopic evaluation after
treatment revealed accumulation of alveolar macrophages and granular material, cellular debris, polymorphonuclear
leukocytes, increased septal cellularity, alveolar bronchialization, focal interstitial fibrosis, cholesterol clefts, and granuloma-
like lesions in the lung. The lesions in the lung did not have fibroblastic activity or hyalinization and regressed during
recovery. All types of pulmonary lesions were more marked in males than in females. Accumulation of macrophages was
observed in the mediastinal lymph node at 13 and 26 weeks. Treatment-related, microscopic changes in the nasal region
were occasionally found at week 13 such as focal necrosis and slight atrophy of the olfactory epithelium. Interstitial fibrosis
was not noted directly after the exposure period, but was observed for the first time after 13 weeks post-exposure, with
increasing incidence especially in the high-dose group, and a few in the mid-dose group. There was decreased severity and
frequency of the effects until the end of the study. The authors concluded that the no observed effect level (NOEL) was 1.3
mg/m3.82
In another 13 week study, 4 male Fischer 344 rats were exposed to aerosolized Silica (50.4 ± 19 mg/m3; mean
diameter 0.81 µm) for 6 h/d, 5d/week.83 The control group was not treated. The Silica burden was determined after 6.5 and
13 weeks of exposure and after 3 and 8 months of recovery. The Silica load increased quickly during the first 6.5 weeks of
exposure (0.76 mg/lung) but less so after 13 weeks (0.88 mg/lung). During recovery, the Silica burden disappeared rapidly
from lung tissue (15% after 12 weeks; 6% after 32 weeks). BAL showed mean cell numbers in the lavage increased 5- to 15-
fold compared to control. The cells comprised > 50% polymorphonuclear leukocytes (PMN) and some 2% lymphocytes
whereas the control lavages only contained < 1% of either cell type. Protein content and enzyme activities (LDH and
glucuronidase) were markedly higher than under control conditions. All BAL markers approached normal levels after 13
weeks recovery in most rats, however, a few had minimal increases.
There was invasion of neutrophils and macrophages into the alveoli after 6.5 weeks but this effect tended to decrease
during recovery. Fibrosis was observed in alveolar septa which subsided during recovery. After 13 weeks of exposure,
intensely stained TUNEL-positive cells were detected throughout the terminal bronchiolar epithelium and through the
parenchyma of the lungs. The authors concluded that aerosolized Silica produced transient pulmonary inflammatory
response and most biochemical markers return to control levels post exposure.83
Chronic Toxicity Studies

No lesions were found in rats dosed up to 1000 mg/kg Zeolite for 104 weeks in a dietary study.2
Oral
Hydrated Silica
In a chronic study, groups of 40 male and 40 female Fischer 344 rats were fed Hydrated Silica (1.25, 2.5, or 5%
incorporated into feed) for 103 weeks.84 The mean cumulative intake of Silica was 143.46, 179.55, and 581.18 g/male rat
and 107.25, 205.02, and 435.33 g/female rat for the low, mid and high dose groups, respectively. Survival for all treatment
groups was similar to controls. There were no differences between treatment groups and controls with regards to body
weight, feed intake, behavior, or in hematological or chemistry parameters. Liver weights in the females in the mid and high
dose groups were lower at 12 to 24 months. There were no significant findings at the histopathological examinations.
The above experiment was repeated in groups of 40 male and 40 female B 6 C 3 F 1 mice for 93 weeks.84 The mean
cumulative intake of Silica was 38.45, 79.78, and 160 g/male mouse and 37.02, 72.46, and 157.59 g/female mouse for the
low, mid, and high dose groups, respectively. There were no differences in survival between treatment groups and controls.
Feed consumption was increased in the mid and high dose groups whereas there was reduced weight increase in the males
during weeks 15 through 50 (p < .01) and weeks 30 through 50 for the females (p < .05). There were no remarkable findings
with regards to hematology or organ weights.
In a 6 month dietary study, groups of 12 male and 12 female CD-1 rats received 0%, 3.2%, or 10% Hydrated Silica
(approximately 0, 2170 or 7950 mg/kg/d in males and 0, 2420 or 8980 mg/kg/d in females).16,20 No clinical signs of toxicity
or significant chnges to feed consumption, growth, hematology, clinical chemistry, or gross or microscopic pathology were
observed. The NOAEL was reported to be 8980 mg/kg/d Hydrated Silica.
Montmorillonite
No signs of systemic toxicity were observed in male and female Sprague-Dawley rats fed Montmorillonite clay
(calcium montmorillonite; 9.34% total AL) at up to 20,000 ppm for 28 weeks. No further details were provided.85
Silica
Silica (3.2% or 10%) was incorporated into the feed of rats (n = 24; 12 male, 12 female) for 6 months.70 There were
no mortalities. The only clinical sign was discolored stools. Growth and development was normal and feed consumption
similar to controls. Necropsy was unremarkable; organ weights, absolute and relative, were similar to controls. Histology
and hematology were unremarkable. There were no changes in clinical chemistry.
In another feeding study, rats (n = 24; 12 males, 12 females) were fed Silica for 6 months.70 The low dose males and
females consumed an average of 0.78 and 0.55 g Silica/week, respectively. The high dose males and females consumed and
average of 3.00 and 2.11 g Silica/week, respectively. There was no effect with regards to body weight gain, feed
consumption, blood chemistry, or urinalysis. There was an increase in the number of leukocytes in the female high dose
group and eosinophils in the male high dose group. There was a decrease in glucose concentration and AP activity in the
male rats in a dose dependent manner. There was decreased serum calcium concentration in the female rats in a dose
dependent manner. There were reduced absolute and reduced liver and prostate weights.
No clinical signs of toxicity and no macroscopic findings were reported in an oral gavage study where 20 male and 20
female Wistar rats received 500 mg/kg/d Silica 5 times/week for 6 months.28
Inhalation
Hydrated Silica
In a chronic inhalation study, groups of 35 Wistar rats were exposed to aerosolized Hydrated Silica (average 1.5 mg/ft3
[53 mg/m3]; most measurements ranged 0.7 to 2.4 mg/ft3 [25 to 85 mg/m3]; particle size not provided) for 8 h/d, 5 d/week for
12 months.86 Treatment related deaths were 26/35 (75%). After 6 months of exposure, aggregations of focal pigmentation
visible as reddish-tan foci of dust were observed. There was also moderate, well-established generalized emphysema and
lymph nodes that were greatly enlarged and firm. The majority of the rats died from pulmonary vascular obstruction and
emphysema from the 4th to the 9th month. The authors concluded that high exposure to amorphous Silica causes severe
progressive pulmonary inflammation associated with increased mortality of the animals, primarily through partial obstruction
of the pulmonary vasculature combined with pulmonary insufficiency due to emphysema.
New Zealand white rabbits (sex and number not reported) were exposed to aerosolized Hydrated Silica (0, 28, 134, or
360 mg/m3; particle size not provided) for 8 h/d, 5 d/week.87 The mid and high dose groups were exposed for 9 months, the
low dose and the control groups were exposed for 27 months. The rabbits in the mid and high dose became distressed during
exposure. Clinical signs were fewer, commenced later, and receded more quickly in the lower concentrations. There was
increased body weight gain which corrected when exposure was terminated. The author suggested that this was due to
edema. The body weights then decreased. The rabbits had dyspnea and shortness of breath accompanied by cyanosis.
Elevated right and left ventricular pressures were concentration and time related.
In the high dose group, emphysema was observed which decreased after termination of treatment. Pulmonary
emphysema, vascular stenosis, alveolar cell infiltration, sclerosis, and epithelization granulomatosis, macrophage catarrh
were observed. Lesions were observed in the liver, spleen and kidney. After 6 months of exposure, the cardiac pressure of
the low dose group increased steadily. At 24 months, the elevation was 64% over pre-exposure pressure. This effect was
partially reversed with termination of treatment (34% after 12 months). The author reported concomitant radiographic
changes, electrocardiographic deviations, modification of lung functions, hematolytic changes, anatomical cor pulmonale,
congestive cardiac failure, emphysema, and chemical pneumonitis. The LOAEL was 28 mg/m3.87
In a chronic study, rabbits (n = 50), rats (n = 84), and guinea pigs (n = 82) were exposed to aerosolized Hydrated
Silica (average of 126 mg/m3; particle size not provided) for 8 h/d, 5 d/week, for 12, 15, and 24 months, respectively,
followed by a recovery period of up to 12 months.88 Control groups were not treated. There were no treatment-related
differences in mortality between test and control groups. For the rats, most of the deaths were due to intercurrent infection.
Lung weights increased during exposure but returned to normal during recovery. Particle-phagocytosing macrophages
accumulated in alveoli, bronchioles, and lymphoid tissue in all species. Hilar lymph nodes were enlarged, mildly in rats and
more evidently in the guinea pigs and rabbits; this disappeared with the termination of treatment. Epithelial proliferation was
minimal. Mild deposition of reticulin fibers occurred in alveoli with no evidence of collagen formation. Bronchial and
tracheal epithelia remained intact. No epithelization or pleural changes were observed; no neoplasia occurred.
The emphysema was equally distributed between treated and control groups. It was dominated by the diffuse
hypertrophic vesicular distention but apparently did not result from destructive effects on the mucosa or terminal bronchioles
and disruption of the continuity of alveolar walls. The author stated that the emphysematous effect in the rats could possibly
be due to aging and recurrent epizootic pneumonitis. There was complete reversibility of Silica retention and inflammatory
responses in guinea pigs within 6 months of recovery. Silicotic processes were completely absent in all species.88

Male Sprague Dawley rats (n = 80) were exposed to aerosolized Silica or either two forms of Hydrated Silica
(precipitated and gel) at 15 mg/m3 (particle size ≤4.7 µm).89 Exposure was for 5.5 to 6 h/day, 5 d/week for up to 12 months.
At maximum exposure, a few macrophage aggregates were found in the lungs. Interstitial fibrosis associated with dense
collections of mast cells appeared in some of the rats of the control and treatment groups, although there was a trend of a
more frequent incidence in those exposed to Silica, but was a few were observed in some control animals. The authors
concluded that the LOAEL was 6 to 9 mg/m3. Macrophage aggregation was less pronounced in rats than in monkeys (see
below) under these test conditions.Fibrosis was of minor importance as test and control groups were similar.
The same researchers conducted a similar study using male monkeys (Macaca fascicularis; n = 10) with exposure to
the test materials described above for 6 h/d, 5 d/week, 13 or 18 months.89 The decrease in lung respiratory volume and
ventilatory mechanics in the monkeys was more marked in the group exposed to Silica. Dynamic pulmonary compliance,
forced vital capacity, inspiratory capacity, total lung capacity, and forced expiratory flow were decreased. Average flow
resistance and closing volume were increased. In the precipitated Silica group, lower lung volumes were observed. There
were no changes in lung volume parameters, but there were reductions in ventilatory performance and mechanical
parameters, dynamic lung compliance, and forced expiratory flow when exposed to Hydrated Silica (gel).
Cytoplasmic changes (increases in number of vacuoles) in macrophages in the lungs and tracheal lymph nodes were
observed. Large numbers of macrophages and mononuclear cell aggregates (bronchioles, alveolar spaces venules, arterioles)
were observed in the lungs. Reticulin fibers were present in the aggregates in all 3 groups. In 6/10 monkeys exposed to
Silica, collagen in varying quantities was found in 5 to 50% of the aggregates, with signs of early nodular fibrosis. In 3/10
monkeys no or little collagen was present. No collagen fibers were observed in aggregates in the lung of monkeys exposed to
Hydrated Silica (gel) and only very few after exposure to the precipitated form. The authors concluded that early nodular
fibrosis indicated that Silica is more detrimental than either form of Hydrated Silica. The smaller particle size of Silica be a
contributing factor. A review of this study noted that the monkeys were transported in bags that had contained asbestos and
that suspect particles in the lungs were identified as mica and kaolin.16 Quartz or asbestos fibers could not be ruled out.89
In a third study by this research group, male Hartley guinea pigs (n = 20) were exposed to the test materials described
above for 5.5 to 6 h/d, 5 d/week for 12 months.89 A few macrophages containing particles of Silica were observed in the
lungs and lymph nodes, similar to the findings in rats (see above).
Silica
In a 6 month study, 25 Wistar rats (half males and half females) were exposed to Silica in inhalation chambers
(average 1.5 mg/ft3 [53 mg/m3]; most measurements ranged from 0.7 to 2.4 mg/ft3 [25 to 85 mg/m3]; particle size not
provided).86 The rats were exposed to aerated Silica for 8 h/d then had passive exposure (dust settling) for the remaining 16
h. The exposure was for 5 d/week for 6 months followed by 6 months of recovery. Rats were periodically killed and
necropsied. The control group (n = 42) was in normal air and killed and necropsied at 6 and 12 months.
In the test group, 11/25 (44%; further details not provided) died, mostly during the Silica exposure. The death rate
decreased during the recovery period. The majority of the rats died from pulmonary vascular obstruction and emphysema
beginning at the 4th month. Focal pigmentation was conspicuous after 3 months of exposure with profusely scattered small,
dark-pink discrete but irregular subpleural foci of reaction. Congestion of the lungs was dominant after 3 months. There was
lymph node enlargement after 3 months. There was an incipient tendency toward pulmonary emphysema after 4 months of
exposure with lung distension and superficial alveoli dilation. Atelectasis was noted in some rats after 4 to 5 months.
Histological examination revealed invasion of the lymphatic system of the lung by mononuclear macrophages
forming clusters of plasma cells and lymphocytes. There was infiltration of large vacuolated cells within the alveolar spaces;
the cytoplasm had a foamy appearance with macrophages fused to giant cells. There were large vacuolated cells within the
alveolar spaces, with the cytoplasm having foamy appearance, macrophages apparently fused to giant cells. There was
progressive nodule formation in the lung parenchyma and peri- and paravascular, in some cases parabronchiolar distribution
and accumulation, consisting of central macrophages and surrounding plasma cells, some nodules enveloped by an epithelial
layer of cells. Some necrosis was noted in the central zone of the nodules; there was progressive tendency toward fibrosis in
the nodules and evidence of progressive emphysematous processes around the nodules. Average Silica load in the lung
increased to 1.5 mg/lung after 3 months and remained at that level through exposure. At the end of recovery, the level
reduced to 0.3 mg/lung. The authors concluded that the lowest observed adverse effects level (LOAEL) was 53 mg/m3.86
Rats (strain and number not provided) were exposed to aerosolized Silica (hydrophilic; 50 to 55 mg/m3) for 12
months.20 Rats were killed and necropsied periodically and after 5 months recovery. At 3 days, there was 0.25 mg Silica in
the lung and 0.5 mg at 6 weeks. At 12 months, ~1% of the total administered respirable Silica was observed in the lungs.
Initial accumulation was rapid and dropped off between week 18 and 12 months (0.5 mg at 6 weeks; 1.2 mg at 18 weeks;
1.37 mg at 12 months). At 6 weeks, the mediastinal lymph nodes contained ~ 0.02 mg Silica and 0.13 at 12 months. After 5
months of recovery, the Silica in the lungs decreased to 0.16 mg/lung (88% reduction) and 0.047 mg/lymph node (> 50%
reduction).
Rats (strain and number not provided) were exposed to aerosolized Silica (hydrophobic; 50 mg/m3; particle size not
provided) for 5 h/d, 2 d/week for 8 and 12 months.20 The lungs retained 1.448 mg Silica (1.3% of exposure) and 1.759 mg
(1.1%), respectively. The lymph nodes retained 0.05 and 0.113 mg, respectively. After 12 month exposure and 1 month
recovery, the lungs contained 1.1 mg Silica (37.5% elimination) and the lymph nodes contained 0.16 mg. After 3 months
recovery, the lungs contained 0.43 mg and the lymph nodes 0.12 mg. After 5 months recovery, the lungs contained 0.41 mg
(76.7% elimination) and the lymph nodes 0.13 mg.
Rats (strain and number not provided) were exposed to aerosolized Silica (hydrophobic; 100 mg/m3; particle size not
provided) for up to 1 year.20 Silica content of the lungs and the lymph nodes was 4.33 and 0.132 mg at 3 months, 6.71 and
0.214 mg at 5 months, and 11.46 and 0.378 mg, respectively. After 6 months of recovery, 55.5% of the Silica was eliminated
from the lungs. Lymph node elimination could not be observed.
Male rats (strain and number not provided) were exposed to aerosolized Silica (hydrophobic; 0, 10, 50, or 150 mg/m3;
particle size not provided) for 6 h/d, 5 d/week for 12 months.20 The low dose had no effect. The mid- and high-dose groups
had white foci on the lung surfaces and collections of foamy macrophages within the alveoli. The peribronchial lymph nodes
were enlarged.
Male and female albino guinea pigs were exposed to aerosolized Silica (average concentration 53 mg/m3; ranging 25
to 85 mg/m3; 85% between 1 to 10 µm) in 3 experiments.90 The whole body exposure was for 8 h/d with the remaining 16 h
as passive exposure (dust settling). In experiment 1, the guinea pigs (n = 40) were exposed to the Silica up to 24 months,
with a few killed and necropsied every 2 months. In experiment 2, the guinea pigs were exposed for 12 (n = 15) or 24 (n =
18) months with variable recovery periods up to 12 months. In experiment 3, the guinea pigs (n = 17) were exposed for 12
months, followed by a 1 month recovery period, then re-exposure for 8 to 24 h. A control group of 80 guinea pigs were
sampled and necropsied from 1 to 36 months.
Two guinea pigs died from non-experimental causes. Overall, the chronic reaction of the lung tissue was established
by 4 months of exposure. There was focal pigmentation after 1 month. Lymph nodes were enlarged by 1 month and did not
increase over time, including hepatic lymph nodes. There was a tendency for lung emphysema after 4 to 8 months of
exposure. Atelectasis was observed histologically. The dominant response was bronchial and peribronchiolar intra-alveolar
accumulations of giant cells. At 8 to 12 months there was incipient atrophy of infiltrated alveoli which apparently led to
compensatory expansion of adjacent alveoli. There was a combined effect of atelectasis and consolidation around bronchioli,
but at the expense of bronchioli distortion. Incipient fibrosis around bronchioli and shrunken alveoli was noted at this stage.
There was a marked tendency toward cuboidal epithelization of atelectactic alveoli by the end of the second year of exposure.
In the lymphoid tissue, medullary hyperplasia with the formation of slight amounts of reticulum was prominent during the
second year of exposure. No inflammation, sinus catarrh, or fibrosis were noted in the lymph nodes. In the recovery phase
after 12 months of exposure, there was progressive recovery beginning almost immediately. There were no macroscopically
visible anomalies after 1 year of recovery. Residual sequelae of the tissue reactions were emphysema, mural fibrosis, and
bronchiolar and bronchial ectasia stenosis. The authors concluded that chronic exposure to amorphous Silica was non-lethal
to guinea pigs, but caused significant inflammatory reactions and pulmonary lesions, however, without apparent disability of
the animals.90
New Zealand white rabbits (n = 10) were exposed to aerosolized Silica (53 mg/m3; ranging from 25 to 85 mg/m3; 1 to
10 µm) for 8 h/d for 12 months.91 There was a 6 and 12 month recovery period. There was progressive functional
incapacitation and increased hematocrits observed in the majority of the rabbits, possibly due to the combined effect of
pulmonary vascular obstruction and emphysema. Blood pressure changes (both increases and decreases) were observed in
the majority of the animals which partially recovered with discontinuation of treatment. Essential pulmonary changes
included peribronchiolar cellular catarrh, mural cellular infiltration along with deposition of reticulum and some collagen, the
formation of peri-vascular cellular nodules, ductal stenosis, and emphysema. During recovery, the cellular reactions and
emphysema regressed but minor focal alveolar mural collagen persisted.
Monkeys (Macacus mulatta; n = 5) were exposed to aerosolized Silica (15 mg/m3; particle size not provided) for up to
12 months.92 A monkey was killed and necropsied at 3 and 6 months. The remaining monkeys were killed and necropsied
after 12 months of exposure. There were 15 untreated control monkeys. Body weight gains decreased and activity decreased
during the initial exposures. At 3 months, emphysema was detectable. There was considerable cellular infiltration of the
alveoli and alveolar septa was associated with distention of alveoli or accumulation of exudate and macrophages. After 12
months, the lesions were marked pulmonary emphysema, alveolar wall sclerosis, vascular occlusions, and cor pulmonale.
Cor pulmonale was attributed to the emphysema and alveolar wall destruction. Tracheobrochial lymph nodes were slightly
enlarged but not fibrotic. The Silica content remained low and decreased over time.
Male cynomolgus monkeys (Macaca fascicularis; number not provided) were exposed to aerosolized Silica
(hydrophobic; 0, 10, 50, or 100 mg/m3; particle size not provided) for 6 h/d, 5 d/week for 12 months.20 Recovery was 2 or 24
months. The low dose had no effect. The mid- and high-dose groups had interstitial fibrosis, which did not resolve or
progress during recovery. Peribronchial lymph nodes were enlarged.
DEVELOPMENTAL AND REPRODUCTIVE TOXICITY (DART) STUDIES

Calcium Silicate (250 to 1600 mg/kg) had no discernible effect on nidation or on maternal or fetal survival in
rabbits.2 Magnesium Aluminum Silicate (6000 mg/kg) had neither a teratogenic nor adverse effects on the mouse fetus.
Female rats receiving 20% Kaolin diet exhibited maternal anemia but no significant reduction in birth weight of the
pups was recorded. Zeolite produced no adverse effects on the dam, embryo, or fetus in either rats or rabbits at any
dose level (74 or 1600 mg/kg). Zeolite had no effect on female rat reproductive performance.
Rats given Sodium Silicate (600 and 1200 ppm of added Silica) in the drinking water in reproductive studies
produced a reduced number of offspring; 67% of controls at 600 ppm and to 80% of controls at 1200 ppm.3 Three
adult rats injected intratesticularly and subcutaneously with 0.8 mM/kg of Sodium Silicate showed no morphological
changes in the testes and no effect on the residual spermatozoa in the ductus deferens.
Silica
No adverse reproductive effects were reported in a dietary study of Silica (500 mg/d) in rats.70 Male and female rats
(n=40) were fed the test material for 6 months. After 4.5 months, 5 females were mated. Litter size, birth weights,
morphology, and development of offspring were similar to controls.
In another study, pregnant female mice were fed up to 1340 mg/kg Silica for 10 days (specific gestation days not
provided).70 There were no effects on nidation or on maternal or fetal survival. Fetal abnormalities were similar to controls.
The same results were reported for rats (up to 1350 mg/kg for 10 days), hamsters (up to 1600 mg/kg for 5 days) and rabbits
(up to 1600 mg/kg for 13 days).
In a subchronic dietary study that also investigated reproductive effects, Silica (500 mg/kg/d) was administered to
female Wistar rats (number not reported) for 6 months.28 The female rats were mated with male rats at weeks 8 and 17. The
male rats were also consuming 500 mg/kg/day. The rats were weighed periodically, blood sampled monthly (except during
pregnancy), and observed daily. The progeny from both matings were examined for abnormalities. At 6 months, the rats
were killed and necropsied except for 5 rats which had a 3 week treatment-free period prior to being killed and necropsied.
Reproductive performance was similar between groups. Pathological examination revealed no differences between
the groups. At the first mating, 6 control and 9 treatment dams became pregnant; 7 from each group became pregnant at the
second mating. There were no treatment-related effects in litter size, birth weight, physical parameters, or behavior.
Development of progeny during lactation was without adverse effects; weight gains were normal. No treatment related
effects were found during gross pathology. The authors conclude that the oral NOEL was > 500 mg/kg for developmental
and reproductive toxicity.28
GENOTOXICITY STUDIES
No increase in mutation frequencies were seen in the Salmonella TA-1530 or G-46 assay and no significant
increase in recombinant activity in the Saccharomyces D3 assay treated with Calcium Silicate.2 A subacute dose of 150
mg/kg of Calcium Silicate produced 3% breaks in bone marrow cells arrested in c-metaphase. In a metaphase spread
of bone marrow cells, Calcium Silicate produced no significant increase in the number of aberrations compared to
controls and in a dominant lethal assay did not induce any dominant lethal mutations. In the S. typhimurium LT2 spot
test (TA98, TA100, TA1535, TA1537, and TA1538) with or without metabolic activation, Magnesium Aluminum Silicate
and Hectorite were found to be nonmutagenic. In primary hepatocyte cultures, the addition of Attapulgite at 10 µg/cm2
caused significant increases in UDS in rat pleural mesothelial cells. Zeolite particles (< 10 µm) produced statistically
significant increase in the percentage of aberrant metaphases, mostly chromatid breaks.
Sodium Metasilicate was nonmutagenic in a DNA damage and repair assay without metabolic activiation
using B. subtilis.3 Sodium Silicate was nonmutagenic in studies using E. coli strains B/Sd-4/1,3,4,5 and B/Sd-4/3,4.
Genotoxicity data are summarized in Table 8. Aluminum Silicate, Hydrated Silica, Silica, Sodium Metasilicate,
Sodium Silicate, and Zinc Silicate were not genotoxic in Ames tests, HPRT gene mutation assays, or chromosome aberration
tests.8,11-13,16,20,28,93-96 Potential genotoxicity was observed in Montmorillonite in an Ames test and a cytokinesis block
micronucleus cytome assay.97,98 Genotoxicity studies of Hydrated Silica at up to 5000 mg/kg in mice and rats were
negative.20
Mutagenic Inhibition
Aluminum Calcium Sodium Silicate
In a study of mutagenic inhibition, aflatoxin (2.5 mg/kg) was incorporated into rat feed with Aluminum Calcium
Sodium Silicate (hydrated; 0.5%).50 The feed was given to groups of 10 Sprague-Dawley rats for 15 days, after which the
animals were killed and bone marrow samples were collected for chromosomal analysis. In the marrow of the rats given
aflatoxin alone, structural and numerical aberrations of chromosomes, mainly chromatid breaks and chromatid gaps, were
observed. In the rats that received Aluminum Calcium Sodium Silicate, these effects were decreased for every category of
aberration except polyploidy.
CARCINOGENICITY STUDIES
The International Agency for Research on Cancer (IARC) has ruled Attapulgite fibers > 5µm as group 2B,
possibly carcinogenic to humans, and fibers < 5µm as group 3, not classified as to their carcinogenicity to humans.99
The natural Zeolites (clinoptilolite, phillipsite, mordenite, and nonfibrous Japanese zeolite) and synthetic Zeolites
cannot be classified as to their carcinogenicity to humans (group 3) according to IARC.
Silica
IARC concluded that amorphous Silica is not classifiable as to its carcinogenicity to humans based on inadequate
evidence in humans and inadequate evidence of increased tumors in animals.99
Oral
Hydrated Silica
In a carcinogenicity study, groups of 10 male and 10 female B 6 C 3 F 1 mice received Hydrated Silica in their feed.84
In the female mice, the frequency of adenocarcinoma in the lungs was 1/16 (6.25%) for the control group and 1/19 (5.3%),
0/20 (0%), and 1/20 (5%) for the low, mid and high dose groups. In the males, the frequency of adenocarcinoma in the lungs
was 1/16 (6.25%) for the control and 2/17 (11.8%), 3/14 (21.4%), and 3/16 (18.8%) for the low, mid, and high dose groups.
There was low correlation of hyperplastic nodules/hepatocellular carcinoma/hemangioma/fibrosarcoma in the treatment
groups compared to the controls. The authors concluded that the non-neoplastic lesions were of no toxicological
significance.
Silica
In a 2-year dietary study, Wistar rats (n = 40; 20 males and 20 females) received 100 mg/kg Silica (pyrogenic) in
their feed.28 The rats were weighed before and after treatment. At the end of the treatment period, the rats were killed and
necropsied. There were no clinical signs of toxicity observed during the treatment period. The rates of tumors observed in
the treated rats were comparable to historical controls. The authors concluded that there were no carcinogenic effects from
the daily ingestion of Silica in this study.
Inhalation
Hydrated Silica
The potential carcinogenic effects of aerosolized Hydrated Silica (< 5 µg particle size) was studied in tumor-
susceptible mice (n = 75) starting at 3 months of age.100 The mice received 0.5 g/d Hydrated Silica once/h, 6 h/d for 5 d/week
for a year. The mice were allowed to live out their natural life span up to 917 days for the start of the experiment. The
incidence of primary lung tumors was 7.9% in the control group and 21.3% in the treated group in mice that lived 10 months
or longer. There was no obvious fibrosis in the lung tissue; however, there were fibrotic nodules in the trachea-bronchial
lymph nodes in > 50% of the mice. The authors suggested that most of the Silica dust was removed by cilia action through
the trachea and also through the lymphatic system. Half of the treated mice had overgrowth of the mediastinal connective
tissue covering the trachea-bronchial nodes which occurred in only 10% of the controls. In the treated group, 29.5% had an
increase in incidence of overgrowth or hyperplasia of the trachea-bronchial lymph nodes compared to 14.3% of the controls.
Intratracheal
Silica
The carcinogenic potential of Silica (3 mg in 0.9% PBS; 0.01 to 0.03µm) was studied in 40 female SPF Wistar
rats.101 The rats received the test material intratracheally 5 times weekly and were observed until death or the 30th month
when they were killed and necropsied. A second group of 40 had Silica at the same dose instilled 10 times weekly. Controls
(n = 48) were untreated. The survival rates were 37/ 40 for group 1, 35/40 for group 2, and 46/48 for the control. The period
of time after the first treatment in which 50% of the rats died was 113 and 112 weeks in the first and second groups and 113
weeks in the control group. The percentage of rats with macroscopic lung tumor(s) was 13.5% in the first group, 2.9% in the
second group, and 6.5% in the control group. The percentage of rats with macroscopic lung tumor(s) which are probably not
a metastasis of other tumors located elsewhere was 8.1% in the first group, none in the second group, and none in the control
group. The percentage of rats with benign tumors in the second group was 5.7% and there were none in the control group;
this was not analyzed in the first experiment. Neither group had malignant tumors. The percentage of rats with tumors that
were metastases of other tumors was 14.3% in the treatment groups 13.0% in the control group.
OTHER RELEVANT STUDIES

Immune Response
Hydrated Silica
Hydrated Silica (1 to 4 mg in saline; ~15 µm particle size) was injected subcutaneously 2 to 8 times in 28
volunteers.102 Biopsies were taken from day 1 to 6 months. Granulomatous inflammation was observed within 7 days and
persisted for months. The authors suggested that this was a particular type of foreign body response to a fibrogenic agent and
not typical epithelioid cell nodules.
DERMAL IRRITATION AND SENSITIZATION STUDIES

Magnesium Aluminum Silicate (4%) was a weak primary skin irritant in rabbits and had no cumulative skin
irritation in guinea pigs.2 No gross effects were reported in any of these studies. Sodium Magnesium Silicate (4%) had
no primary skin irritation in rabbits and had no cumulative skin irritation in guinea pigs. Hectorite was nonirritating to
the skin of rabbits in a Draize primary skin irritation study. Applications of 2 g of Magnesium Aluminum Silicate made
to the skin of two humans daily for 1 week caused no effects.
Dermal irritation of Potassium Silicate, Sodium Metasilicate, and Sodium Silicate ranged from negligible to
severe, depending on the species tested and the molar ratio and concentration tested.3 Sodium Metasilicate/carbonate
detergent (37% Sodium Metasilicate) mixed 50/50 with water was considered a severe skin irritant when tested on
intact and abraded human skin. Detergents containing 7%, 13%, and 6% Sodium Silicate mixed 50/50 with water,
however, were negligible skin irritants to intact and abraded human skin. Sodium Silicate (10% of a 40% aqueous
solution) was negative in a repeat-insult predictive patch test in humans. The same aqueous solution of Sodium Silicate
was considered mild under normal use conditions in a study of cumulative irritant properties. Sodium Metasilicate and
Sodium Silicate were studied in modified soap chamber tests. No burning or itching was observed and low erythema +
edema scores were noted. Sodium Metasilicate and Sodium Silicate, tested in elbow crease studies and semioccluded
patch tests, produced low grade and transient irritation.
Sodium Metasilicate was negative in the local lymph node assay (LLNA), but a delayed-type hypersensitivity
response was observed in mice.3
In vitro and animal dermal irritation and animal sensitization data are summarized in Table 9. Aluminum Silicate
and Zinc Silicate were predicted to be not irritating in EpiDermTM skin assays.8,13 In rabbit studies, the irritation potential of
Potassium Silicate (up to 36%) and Sodium Metasilicate (up to 97%) were dependent on concentration.10,11,15 Very slight to
no irritation was observed dermal irritation studies in rabbits with Hydrated Silica (at up to 50% solution in olive oil) and
Silica (up to 12%solution in methyl ethyl cellulose).16,20 Aluminum Silicate (up to 25%) and Zinc Silicate (up to 50%) were
not sensitizing in LLNA studies.8,13 Potassium Silicate (30%) and Hydrated Silica (20%) was not sensitizing in guinea pig
sensitization tests.10,103 Hydrated Silica (up to 45%) and Silica (21.74% in formulation) were not sensitizing in human repeat
insult patch tests (HRIPT).16,70,104,105
OCULAR IRRITATION STUDIES

A 4% solution of Magnesium Aluminum Silicate and a 4% solution of Sodium Magnesium Silicate caused
minimal eye irritation in a Draize eye irritation test.2 Bentonite caused severe iritis after injection into the anterior
chamber of the eyes of rabbits. When injected intralamellarly, widespread corneal infiltrates and retrocorneal
membranes were recorded. In a primary eye irritation study in rabbits, Hectorite was moderately irritating without
washing and practically nonirritating to the eye with a washout. Rats tolerated a single dose of Zeolite without any
adverse reaction to the eye.
Potassium Silicate was nonirritating in two acute eye irritation studies in rabbits.3 Sodium Metasilicate
(42.4% water) was corrosive to the rabbit eye. Sodium Silicate was a severe eye irritant in acute eye irritation studies.
A skin freshener (10% of a 40% aqueous solution) containing Sodium Silicate was nonirritating. Sodium Silicate in
another three Draize eye irritation studies was highly irritating, irritating, and nonirritating, respectively.
In vitro and animal ocular irritation data are summarized in Table 10. Aluminum Silicate (tested pure) was predicted
to be not irritating using the hen's egg test chorioallantoic membrane (HET-CAM) method.13 Sodium Metasilicate
(concentration not reported) was predicted to be corrosive in an in vitro method using rabbit eyes, and Zinc Silicate (20%)
was predicted to be irritating in a bovine corneal opacity and permeability (BCOP) test.8,11 Potassium Silicate was not
irritating to slightly irritating when tested at up to 35% in rabbit eyes.10,15 Hydrated Silica (concentration not provided) and
Silica were not irritating to slight irritating in rabbit eyes.20,28,69,70
CLINICAL STUDIES
The effects of orally administered Silica and Hydrated Silica (as 1250 mg of Silica in apple juice) to 2 groups of 6
volunteers (5 males and female in each group).16 The solutions were consumed in 2 doses, morning and midday on the same
day. The total urine was collected daily and analyzed. During the 4 days post-treatment, changes of renal Silica secretion
were not observed. Daily Silica increments in urine after ingestion ranged between 7 and 23 mg. For Silica, the individual
baseline values of the pre-test phase were very variable and individually different; mean excretion rates ranged from 25 to 87
mg/day. In the post-treatment phase, individual mean excretion rates ranged from 32 to 61 mg/day. For Hydrated Silica, the
individual baseline values of the pre-test phase were very variable and individually different; mean excretion rates ranged
from 16 to 71 mg/day. In the post-treatment phase, individual mean excretion rates ranged from 20 to 81 mg/day. Overall,
increases in excretion were not unequivocally detectable. The authors noted that the small apparent increases were in marked
contrast to the high dose of 2500 mg Silica applied.
Case Reports
Colloidal Sodium Metasilicate was fatal to one man and neutralized Sodium Silicate produced vomiting, diarrhea,
and gastrointestinal bleeding in another man in separate case reports of oral ingestion.3
Sodium Metasilicate
Acute kidney injury was reported in a 52-year-old man who had ingested approximately 150 ml of a plate developer
solution containing Sodium Metasilicate.106 The patient also developed severe upper airway obstruction due to laryngeal
edema, severe inflammation of the upper gastrointestinal tract with narrowing of the esophagus and pyloric region. The
patient succumbed to his injuries a few months after ingestion.
Reactive airway dysfunction syndrome was reported in 43-year-old man who had inhaled dishwasher detergent
powder containing Sodium Metasilicate.107 The patient was employed as an apprentice cook and accidentally inhaled the
detergent while preparing to use an institutional dishwasher.
Occupational Exposure
Occupational exposure to mineral dusts has been studied extensively. Fibrosis and pneumoconiosis has been
documented in workers involved in the mining and processing of Aluminum Silicate, Calcium Silicate, Zirconium
Silicate, Fuller’s Earth, Kaolin, Montmorillonite, Pyrophyllite, and Zeolite.
Bentonite
In a toxicological and epidemiological review of Bentonite, the authors concluded Bentonite is probably not more
toxic than any other particulate. However, because some forms may contain variable amounts of respirable crystalline Silica,
prudent management and adherence to occupational exposure limits is appropriate.108
Hydrated Silica
In an occupational study, 78 workers (aged 21 to 67 years; average 34.23 years) were examined who had been
exposed to precipitated Silica from 1941 to 1959.109 Dust concentrations ranged from 0.35 to 204 mg/m3. There was no
evidence of silicosis or other pulmonary disease.
Workers (n = 165) exposed to Hydrated Silica with a mean of 8.6 years (44 workers had been exposed a mean of 18
years [10-35 years]) were examined for adverse effects.110 Dust levels varied from <1 to 10 mg/m3 with some higher
intermittent levels. Examination included spirograms, respiratory questionnaires, and chest radiographs. Cough and dyspnea
correlated with level/time of smoking and not Silica exposure. There were no correlations between yearly change of
pulmonary function and dose or time of exposure. The workers with the mean exposure time of 18 years had pulmonary
function similar to the rest of the group. There was radiographic evidence of minimal pneumoconiosis that was biased due to
prior exposure to limestone. None of the 143 workers with exposure only to Silica showed radiographic evidence of
pneumoconiosis.
Another study examined workers (n = 41) exposed to Hydrated Silica and compared them to a control group.111 The
examination included blood gas analysis and chest radiographs. There was a reduction in forced expiratory flow in the
exposed group. There was no correlation between the exposure index and pulmonary function. The authors concluded that
smoking and exposure to Silica synergize to induce small airway disease.
In another unpublished occupational study of workers in Hydrated Silica factories (1952 to 1981), there was no
silicosis in workers employed for 1 to >20 years (mean 13.2 years).16 There were negative results in hematology, urine
analysis, lung functions, and chest x-rays.
In an unpublished study of workers (n = 78) in a factory that manufactured Hydrated Silica pigment between 1941 and
1959, dust concentrations ranged from 0.35 to 205 mg/m3.16 No evidence of silicosis or other pulmonary disease was
observed. The incidence of illness and injuries were similar to other workers in this plant.
In an unpublished study, 150 workers in a Hydrated Silica factory were examined by pulmonary function test and
x-ray.20 The workers were exposed for ≥ 6 h/d for at least 5 continuous or discontinuous years. The mean duration was 12.2
years. The control group had been exposed for a maximum of 3 continuous or discontinuous months. The mean ages for the
experimental and control groups were 43.1 and 44.3 years, respectively. There were no differences in the distributions and
types of dysfunctional measurements observed between exposed and non-exposed groups. There were no differences in the
mean percentage of predicted pulmonary function values between exposed and non-exposed groups. None of the x-rays
showed signs of pneumoconiosis or fibrosis.

In an investigation of occupational Silica exposure, workers were exposed to Silica (3 factories) or Hydrated Silica (2
factories).20 There were 510 current workers with at least 1 month exposure studied. Complete data sets were collected from
397 workers. Data were also collected from 178 men who were no longer working in the factories. Unexposed workers
totaled 210. Chronic bronchitis rates were within expected ranges for all group but somewhat higher in exposed subjects.
Differences between factories were absent. The percentage of subjects with obstruction or restriction in breathing were
similar between plants. Bronchial hyperresponsiveness was within expected levels. Chest radiographs showed no increased
risk of pneumoconiosis in exposed subjects compared to controls. Relevant pleural thickening was not observed. The
authors concluded that occupational exposure to Silica was not a health risk.
Silica
The Occupational Safety and Health Administration (OSHA) permissible exposure limit (PEL) to amorphous
Silica is 80 mg/m3 or 20 millions of particles per cubic foot air averaged over an 8-h work shift.112 The National Institute
for Occupational Safety and Health recommended exposure limit (REL) for respirable Silica is 6 mg/m3.
Workers (n = 215) with exposure to Silica between 1947 and 1959 were studied using chest x-rays.113 Exposure
ranged from 15 to 100 mg/m3, 2 to 6 mg/m3, and 3 to 7 mg/m3, depending on workstation. Hairline actuation of the
interlobar fissures, suggesting slight interlobar pleuritis, was the only remarkable sign. There were no signs of silicosis.
In an unpublished study, 29 workers in a silicone products manufacturing plant were surveyed.20 Silica
exposure ranged from 0.15 to 10 mg/m3 with a mean of 1.7 mg/m3. Ten of 15 workers in the room temperature
vulcanizing rubber area complained of upper respiratory tract irritation. In the heat curable rubber compounding area,
the potential exposure to Silica was greater, some of the workers complained about eye irritation, nausea, headaches, or
rashes, none reported upper or lower respiratory problems.
Workers (n = 200) with intensive and regular contact with Silica from 1972 to 2000 were evaluated.16 There
was no evidence of skin allergy caused by the Silica. There were signs of irritation attributed to the desicative and
defatting properties of Silica which resulted in skin dryness which could be controlled by regular use of skin-protection
ointment.
An occupational study of workers (n = 143) exposed to Silica from 1959 to 1985 was performed.16 Exposure
ranged from 1 to 34 years. There were complaints of some disorder or exhibition of abnormalities in lung function or
histology in 54/143 (36%) of the workers. Dry cough, expectoration or dyspnea was reported in 34/54 of these workers.
A total of 42/54 (78%) of these workers had some possible confounding factor (i.e., smoking). Radiological examination
did not show any signs of fibrotic disease. Spirometric examination showed obstructive and/or restrictive ventilation
disturbances in 24 workers. Most of the adverse findings were associated with confounding factors such as smoking.
In an unpublished occupational exposure study, x-rays were take of 99 workers who had manufactured Silica
for various amounts of time.16 The x-rays revealed no evidence of any occupational disease, including silicosis.
Zeolite
In a safety assessment of synthetic Zeolites used in detergents, the author concluded that these ingredients are safe
for consumers under the conditions of recommended use.114 The author further stated that due to irritant effects of
undiluted Zeolite material on mucous membranes and the respiratory tract, the exposure of workers should be controlled.
SUMMARY
This report assesses the safety of 40 Silica and Silicate ingredients as used in cosmetics. The majority of these
ingredients function as abrasives, absorbents, bulking agents, and/or deodorant agents in cosmetic products. The Panel
previously reviewed the safety of Aluminum Silicate, Calcium Silicate, Magnesium Aluminum Silicate, Magnesium
Silicate, Magnesium Trisilicate, Sodium Magnesium Silicate, Zirconium Silicate, Attapulgite, Bentonite, Fuller’s Earth,
Hectorite, Kaolin, Lithium Magnesium Silicate, Lithium Magnesium Sodium Silicate, Montmorillonite, Pyrophyllite,
and Zeolite in a report that was published in 2003. The Panel concluded that these ingredients were safe as used in
cosmetic products. In accordance with its procedures, the Panel evaluates the conclusions of previously-issued reports
every 15 years, and it has been at least 15 years since this assessment has been issued. This report has been reopened to
add additional ingredients, including several that were also previously reviewed: Potassium Silicate, Sodium
Metasilicate, and Sodium Silicate (published in 2005 with the conclusion that these ingredients were safe for use in
cosmetic products in the practices of use and concentration described in the safety assessment when formulated to avoid
irritation)4 and Silica, Alumina Magnesium Metasilicate (now called Magnesium Aluminometasilicate), Aluminum
Calcium Sodium Silicate, Aluminum Iron Silicates, Hydrated Silica, and Sodium Potassium Aluminum Silicate
(finalized in 2009 with the conclusion that these ingredients are safe as cosmetic ingredients in the practices of use and
concentrations as described in the safety assessment).
According to 2018 VCRP data, Silica has the most reported uses in cosmetic products, with a total of 8024; the
majority of the uses are in leave-on makeup preparations and eye makeup preparations. Kaolin has the second most
reported uses in cosmetic products, with a total of 1794; the majority of the uses are also in leave-on makeup
preparations and eye makeup preparations. The reported numbers of uses for the remaining ingredients in this report are
much lower. The uses for both of these ingredients have greatly increased since the original safety assessments were
finalized: in 2009, Silica was reported to have 3276 uses and in 1998, Kaolin was reported to have 509 uses. The results
of the concentration of use survey conducted in 2018 by the Council indicate Kaolin has the highest reported maximum
concentration of use; it is used at up to 53% in “other” manicuring products and up to 35% in rinse-off “other” skin care
preparations. Zeolite is used at up to 37.8% in in paste masks and mud packs and up to 35.7% in hair tonics, dressings
and other hair grooming aids. According to the original safety assessments, the maximum use concentration for Kaolin
was 100% in leave-on “other” skin care preparations and the maximum use concentration for Hectorite was 100% in
rinse-off skin cleansing preparations (the maximum leave-on concentration was 15% in makeup foundations). Silica was
reported to be used at up to 44% in eye shadows.
Hydrated Silica in water and Potassium Silicate (30%) had dermal LD 50 s greater than 5 g/kg in rabbits and rats,
respectively. In oral rat studies, the LD 50 s for Aluminum Silicate (concentration not reported), Calcium Silicate (20%),
Hydrated Silica (26% in water), Potassium Silicate (concentration not reported), Silica (in stock diet 1:4 w/w), Sodium
Magnesium Aluminum Silicate (concentration not reported), and Sodium Silicate were > 2 g/kg, > 10g/kg, 40 g/kg, > 5
g/kg, > 10 g/kg, > 2 g/kg, and up to 8.65 g/kg, respectively. An oral LD 50 for Sodium Silicate in mice was 6.60 g/kg.
Orally administered Aluminum Calcium Sodium Silicate had no adverse effects up to 800 mg/kg in mice. In inhalation
studies, the LC50s for Hydrated Silica (30% SiO 2 ), Potassium Silicate (30%), and Silica (concentration not reported) in
rats were > 3300 mg/m3, > 2060 mg/m3, and > 191,300 mg/m3, respectively.
No adverse effects were reported in a 3 week dermal study of Silica (up to 10 g/kg/d) in rabbits. In short-term oral
studies, the NOAEL for Hydrated Silica was > 24.2 g/kg/d in a 14 day dietary study in rats. Mild gastrointestinal effects
were the only adverse effects reported in a 2 week study of Montmorillonite in human subjects that received up to 3.0
g/day of the test material. The NOEL was 500 mg/kg/d in a 5 to 8 week dietary study in rats that were fed up to 16,000
mg/kg/d Silica. In subchronic oral studies, the NOEL was 4000 mg/kg/d in a 13 week dietary study in rats fed Hydrated
Silica at up to 4000 mg/kg/d. No adverse effects were reported in rats that received 40 mg/kg/d Montmorillonite for 90
days (no further details provided). No clinical signs of toxicity or gross or microscopic changes were reported in a 13
week dietary study in rats that received up to 3500 mg/kg/d Silica.
Aluminum Silicate, Hydrated Silica, Silica, Sodium Metasilicate, Sodium Silicate, and Zinc Silicate were not
genotoxic in Ames tests, HPRT gene mutation assays, or chromosome aberration tests. Potential genotoxicity was
observed in Montmorillonite in an Ames test and a cytokinesis block micronucleus cytome assay. Genotoxicity studies
of Hydrated Silica at up to 5000 mg/kg in mice and rats were negative.
Carcinogenic effects were not reported in oral studies of Hydrated Silica in mice or Silica in rats. An inhalation
study of Hydrated Silica in mice and an intractracheal study of Silica in rats also were negative for carcinogenicity.
Aluminum Silicate and Zinc Silicate were predicted to be not irritating in EpiDermTM skin assays. In rabbit studies,
the irritation potential of Potassium Silicate (up to 36%) and Sodium Metasilicate (up to 97%) were dependent on
concentration. Very slight to no irritation was observed dermal irritation studies in rabbits with Hydrated Silica (at up to
50% solution in olive oil) and Silica (up to 12%solution in methyl ethyl cellulose). Aluminum Silicate (up to 25%) and
Zinc Silicate (up to 50%) were not sensitizing in LLNA studies. Potassium Silicate (30%) and Hydrated Silica (20%)
was not sensitizing in guinea pig sensitization tests. Hydrated Silica (up to 45%) and Silica (21.74% in formulation) were
not sensitizing in HRIPT.
Aluminum Silicate (tested pure) was predicted to be not irritating using the HET-CAM method. Sodium
Metasilicate (concentration not reported) was predicted to be corrosive in an in vitro method using rabbit eyes, and Zinc
Silicate (20%) was predicted to be irritating in a BCOP test. Potassium Silicate was not irritating to slightly irritating
when tested at up to 35% in rabbits eyes. Hydrated Silica (concentration not provided) and Silica were not irritating to
slight irritating in rabbit eyes.
A 2-week clinical oral study of Montmorillonite resulted in only mild gastrointestinal complaints in 50 subjects.
Case reports of severe injury were reported from ingestion and inhalation of Sodium Metasilicate. Occupational
exposures to Bentonite and Zeolite should be limited. Workers in environments with aerosolized Silica had few signs of
silicosis or pulmonary disease up to 100 mg/m3. Smoking and exposure to Silica synergize to induce small airway
disease. Exposure to Hydrated Silica also had no evidence of silicosis or pulmonary disease. There were signs of dermal
irritation due to the desiccative and defatting properties of Silica.
ORIGINAL REPORT DISCUSSIONS

2003 Silicates Report
The CIR Expert Panel determined that the data provided in this report are sufficient to assess the
safety of the tested ingredients: Aluminum Silicate, Calcium Silicate, Magnesium Aluminum Silicate,
Magnesium Silicate, Magnesium Trisilicate, Sodium Magnesium Silicate, Zirconium Silicate, Attapulgite,
Bentonite, Fuller’s Earth, Hectorite, Kaolin, Lithium Magnesium Silicate, Lithium Magnesium Sodium Silicate,
Montmorillonite, Pyrophyllite, and Zeolite. The Panel did note a concern about inhalation of these ingredients
due to reported cases of pneumoconiosis and fibrosis in humans and pulmonary lesions in animals. However,
extensive pulmonary damage in humans was the result of direct occupational inhalation of the dusts and
lesions seen in animals were affected by particle size, fiber length, and concentration. The Panel recognizes
that most of the formulations are not respirable and of the preparations that are respirable, the concentration
of the ingredient is very low. Even so, the Panel considered that any spray containing these solids should be
formulated to minimize their inhalation.
2005 Potassium Silicate, Sodium Metasilicate, and Sodium Silicate Report

The CIR Expert panel determined that the data provided in this report are sufficient to address the
safety of the tested ingredients Potassium Silicate, Sodium Metasilicate, and Sodium Silicate. The Panel
recognized the irritation potential of these ingredients, especially in leave-on products. However, because
these ingredients have limited dermal absorption and Sodium Metasilicate is a GRAS direct food substance,
the Panel deemed the ingredients safe as currently used, when formulated to avoid irritation.
2009 Silica and Related Ingredients Report

The CIR Expert Panel emphasized that the Silica considered in this safety assessment is synthetic
amorphous Silica (gel, hydrated, and fumed/pyrogenic) and does not include any form of crystalline Silica.
The Panel recognizes that there are data gaps regarding use and concentration of these ingredients.
However, the overall information available on the types of products in which these ingredients are used and at
what concentrations indicate a pattern of use, which was considered by the Expert Panel in assessing safety.
The Panel was concerned about the possibility of iron atoms reaching the lungs if Aluminum Iron
Silicates were to be used in a spray. In the absence of inhalation toxicity data, the Panel determined that
Aluminum Iron Silicates can be used safely in hair sprays, because the ingredient particle size is not
respirable. The Panel reasoned that the particle size of aerosol hair sprays (38 μm) and pump hair sprays
(>80 μm) is large compared to respirable particulate sizes (10 μm). The Panel recognizes that most of the
formulations are not respirable and of the preparations that are so, the Panel considered that any spray
containing these solids should be formulated to minimize their inhalation potential. Aluminum Iron Silicates is
safe as a cosmetic ingredient because the particles for aggregates and agglomerates that are too large to be
respirable.
The Panel determined that silicosis was not an issue since crystalline Silica is not used in cosmetics.
FIGURES
Silicon Tetrachloride Vapor
H2/O2
1800 °C
Primary Particles
Molten spheres of silicon dioxide
Diameter: 7-21 nm
Surface area: 400-130 m2/g
Collision/Irreversible fusion
Amorphous state due to rapid cooling
Secondary Particle
Branched 3-dimensional aggregates
Cooling Further collisions/

(below 1710 °C) Reversible entanglement
Agglomerates
Calcination
Removal of residual HCl to < 200 ppm
Collection Optional proprietary

densing process
(to raise bulk density)
Bagging
Figure 1. Process for the manufacture of Silica (pyrogenic form).1

TABLES
Table 1. Definitions and functions of the ingredients in this safety assessment.5
Ingredient & CAS No. Definition & Structure Function(s)
Activated Clay Activated Clay is the inorganic compound obtained by heating natural Absorbents; Bulking
aluminum silicate with sulfuric acid. Agents
Aluminum Calcium Sodium Aluminum Calcium Sodium Silicate is a complex silicate refined from Bulking Agents
Silicate naturally occurring minerals.
1344-01-0
Aluminum Iron Calcium Aluminum Iron Calcium Magnesium Germanium Silicates is a ceramic Anticaries Agents;
Magnesium Germanium Silicates powder consisting mainly of silicon dioxide, aluminum oxide, ferric Antifungal Agents;
oxide, calcium oxide, magnesium oxide and germanium oxide. Antimicrobial Agents;
Antioxidants
Aluminum Iron Calcium Aluminum Iron Calcium Magnesium Zirconium Silicates is a ceramic Bulking Agents
Magnesium Zirconium Silicates powder consisting mainly of silicon dioxide, aluminum oxide, ferric
oxide, calcium oxide, magnesium oxide and zirconium oxide.
Aluminum Iron Silicates Aluminum Iron Silicates is a ceramic powder consisting mainly of Abrasives; Bulking
silicon dioxide, aluminum oxide, and ferric oxide. Agents
Aluminum Silicate Aluminum Silicate is a complex inorganic salt that has a composition Abrasives;
1327-36-2 consisting generally of 1 mole of alumina and 1 to 3 moles of silica. Absorbents;
Anticaking Agents;
Bulking Agents:
Opacifying Agents;
Slip Modifiers
Ammonium Silver Zeolite Ammonium Silver Zeolite is the ammonium salt of the product obtained Absorbents; Deodorant
by the reaction of silver nitrate and Zeolite. Agents; Preservatives
Ammonium Silver Zinc Ammonium Silver Zinc Aluminum Silicate is a complex silicate formed Absorbents; Deodorant
Aluminum Silicate from the reaction of zinc nitrate, Ammonium Nitrate , and Silver Agents; Preservatives
Nitrate with Zeolite.
Attapulgite Attapulgite is a variety of Fuller's Earth found typically near Attapulgas, Abrasives;
12174-11-7 Georgia. It is characterized by having a chain structure rather than the Absorbents; Bulking
1337-76-4 usual sheet structure of other clay minerals. Agents; Opacifying
Agents; Viscosity
Increasing Agents -
Aqueous
Bentonite Bentonite is a native hydrated colloidal aluminum silicate clay. Absorbents; Bulking
1302-78-9 Agents; Dispersing
Agents -
Nonsurfactant;
Emulsion Stabilizers;
Opacifying Agents;
Viscosity Increasing
Agents - Aqueous
Calcium Magnesium Silicate Calcium Magnesium Silicate is a synthetic silicate clay consisting Absorbents; Deodorant
12765-06-9 chiefly of calcium and magnesium silicates Agents
Calcium Silicate Calcium Silicate is a hydrous or anhydrous silicate with varying Absorbents; Bulking
1344-95-2 proportions of calcium oxide and silica. Agents; Opacifying
Agents
Fuller’s Earth Fuller's Earth is a non-plastic variety of kaolin containing an aluminum Abrasives;
8031-18-3 magnesium silicate. Absorbents;
Anticaking Agents;
Bulking Agents;
Opacifying Agents
Gold Zeolite Gold Zeolite is the product obtained by the reaction of gold chloride Absorbents; Cosmetic
with Zeolite. Astringents; Skin
Protectants; Skin-
Conditioning Agents -
Miscellaneous
Hectorite Hectorite is one of the montmorillonite minerals that are the principal Absorbents; Bulking
12173-47-6 constituents of bentonite clay. Agents; Dispersing
68084-71-9 Agents -
Nonsurfactant;
Opacifying Agents;
Agents - Aqueous

Hydrated Silica Hydrated Silica is the inorganic oxide that conforms generally to the Abrasives;
10279-57-9 formula SiO 2 ∙ xH 2 O. Absorbents;
112926-00-8 Anticaking Agents;
1343-98-2 (silicic acid) Bulking Agents;
63231-67-4 Opacifying Agents;
7631-86-9 Oral Care Agents;
Skin-Conditioning
Agents – Misc.;
Agents - Aqueous
Kaolin Kaolin is a native hydrated aluminum silicate with an approximate Abrasives;
1332-58-7 composition of Al 2 O 3 ∙ 2SiO 2 ∙ 2H 2 O. Absorbents;
Anticaking Agents;
Bulking Agents;
Opacifying Agents;
Skin Protectants; Slip
Modifiers
Lithium Magnesium Silicate Lithium Magnesium Silicate is a synthetic silicate clay consisting Binders; Bulking
37220-90-9 mainly of lithium and magnesium silicates. Agents; Viscosity
Increasing Agents -
Aqueous
Lithium Magnesium Sodium Lithium Magnesium Sodium Silicate is a synthetic silicate clay Bulking Agents;
Silicate consisting mainly of lithium, magnesium and sodium silicates. Viscosity Increasing
53320-86-8 Agents - Aqueous
Magnesium Aluminometasilicate Magnesium Aluminometasilicate is the inorganic compound consisting Absorbents;
12408-47-8 of varying amounts of magnesium oxide, aluminum oxide and silica. Anticaking Agents;
Bulking Agents;
Opacifying Agents;
Slip Modifiers;
Agents – Aqueous;
Agents – Nonaqueous
Magnesium Aluminum Silicate Magnesium Aluminum Silicate is a complex silicate refined from Absorbents;
12199-37-0 naturally occurring minerals. Anticaking Agents;
12511-31-8 Bulking Agents;
Opacifying Agents;
Slip Modifiers;
Agents - Aqueous
Magnesium Silicate Magnesium Silicate is an inorganic salt of variable composition which Absorbents;
1343-88-0 consists mainly of MgO ∙ SiO 2 ∙ xH 2 O . Anticaking Agents;
Bulking Agents;
Opacifying Agents;
Slip Modifiers;
Agents - Aqueous
Magnesium Trisilicate Magnesium Trisilicate is the inorganic compound that conforms Abrasives;
14987-04-3 generally to the formula 2MgO ∙ 3SiO 2 ∙ xH 2 O. Absorbents;
Anticaking Agents;
Bulking Agents;
Opacifying Agents;
Slip Modifiers;
Agents - Aqueous
Montmorillonite Montmorillonite is a complex aluminum/magnesium silicate clay. Abrasives;
1318-93-0 Absorbents; Bulking
Agents; Emulsion
Stabilizers; Opacifying
Agents; Viscosity
Increasing Agents -
Aqueous
Potassium Silicate Potassium Silicate is a potassium salt of silicic acid. Corrosion Inhibitors
1312-76-1

Pyrophyllite Pyrophyllite is a naturally occurring mineral substance consisting Absorbents; Colorants;
113349-10-3; 113349-11-4; predominantly of a hydrous aluminum silicate represented as Al 2 O 3 ∙ Opacifying Agents
113349-12-5; 12269-78-2; 4SiO 2 ∙ H 2 O.
141040-73-5; 141040-74-6
Silica Silica is the inorganic oxide that conforms to the formula SiO 2 . Abrasives;
112945-52-5 Absorbents;
60676-86-0 Anticaking Agents;
7631-86-9 Bulking Agents;
Dispersing Agents –
Nonsurfactant;
Opacifying Agents
Silver Copper Zeolite Silver Copper Zeolite is the product obtained by the reaction of Zeolite Absorbents; Deodorant
130328-19-7 with silver nitrate and cupric nitrate. Agents
168042-42-0
Sodium Magnesium Silicate Sodium Magnesium Silicate is a synthetic silicate clay with a Binders; Bulking
composition mainly of magnesium and sodium silicate. Agents
Sodium Magnesium Aluminum Sodium Magnesium Aluminum Silicate is the complex silicate obtained Absorbents
Silicate by the reaction of Sodium Silicate and Sodium Aluminate in an aqueous
12040-43-6 solution of Magnesium Nitrate.
Sodium Metasilicate Sodium Metasilicate is the inorganic salt that conforms to the formula Chelating Agents;
6834-92-0 Na 2 SiO 3 . Corrosion Inhibitors
Sodium Potassium Aluminum Sodium Potassium Aluminum Silicate is a complex silicate refined from Bulking Agents
Silicate naturally occurring minerals, or derived synthetically.
12736-96-8
66402-68-4
Sodium Silicate Sodium Silicate is a sodium salt of silicic acid. Buffering Agents;
1344-09-8 Corrosion Inhibitors;
pH Adjusters
Sodium Silver Aluminum Silicate Sodium Silver Aluminum Silicate is the complex silicate obtained by Absorbents; Deodorant
the reaction of sodium silicate with sodium aluminate in an aqueous Agents
solution of sodium nitrate, sodium hydroxide and silver nitrate.
Titanium Zeolite Titanium Zeolite is the product obtained by the reaction of Zeolite with Absorbents; Light
titanium tetrachloride. Stabilizers; Skin-
Conditioning Agents –
Misc.
Tromethamine Magnesium Tromethamine Magnesium Aluminum Silicate is a reaction product of Viscosity Increasing
Aluminum Silicate Tromethamine and Magnesium Aluminum Silicate. Agents - Aqueous
Zeolite Zeolite is a hydrated alkali aluminum silicate. Absorbents; Deodorant
1318-02-1 Agents
Zinc Silicate Zinc Silicate is an inorganic salt consisting of variable amounts of zinc Deodorant Agents
13597-65-4 oxide and silica.
Zinc Zeolite Zinc Zeolite is the product obtained by the reaction of Zeolite with zinc Absorbents; Cosmetic
chloride. Astringents; Skin
Protectants; Skin-
Conditioning Agents -
Miscellaneous
Zirconium Silicate Zirconium Silicate is the inorganic compound that conforms to the Abrasives; Opacifying
10101-52-7 formula ZrSiO 4 . Agents
1344-21-4
Table 2. Physical and chemical properties

Property Value Reference
Aluminum Silicate
13
Physical Form Light brown to brown, odorless beads
2
Formula Weight (Da) 162.05 - 426.05
2
Density (g/ml @ 20ºC) 3.156; 3.247
Attapulgite
2
Physical Form White, gray, or transparent, dull, elongated, lath-shaped crystals in bundles
that comprise thin sheets of minute interlaced fibers; surface is protonated and
hydrated
2
Density (g/ml) 2.2
Bentonite
2
Physical Form Crystalline, claylike material, available as an odorless, pale buff or cream to
grayish-colored fine powder, which is free from grit; dioctahedral
2
Formula Weight (Da) 359.16
2
pH 9.5-10.5 (2% aqueous solution)
Calcium Silicate
2
Physical Form White or slightly cream-colored free-flowing powder
2
14
Density (g/ml @ 25ºC) 0.227
14
Melting Point (ºC) 1710
14
Water Solubility (mg/l @ 20ºC) 260
Fuller’s Earth
2
Physical Form Nonplastic variety of Kaolin; sheet structure
Hectorite
2
Physical Form Translucent colorless mineral when mined and turns white when dried;
tridecahedral
2
Specific Gravity (g/ml) 2.65
2
pH 8.5 (5% slurry)
Kaolin
2
Physical Form White or yellowish white, earthy mass or white powder; unctuous when moist
2
Magnesium Aluminum Silicate
2
Physical Form Off-white to creamy white small flakes or micronized powder
2
2
pH 9.0-10.0 (5% aqueous solution)
Magnesium Silicate
2
Physical Form Fine, white, odorless, tasteless powder, free from grittiness
Magnesium Trisilicate
2
Physical Form Fine, white, odorless, tasteless powder, free from grittiness
Potassium Silicate
3
Physical Form Yellowish to colorless, translucent to transparent, hygroscopic
10
Density (g/ml @ 20ºC) 1.26-1.60
10
Vapor Pressure (mmHg @ 1175ºC) 0.00772
10
Silica
28
Physical Form White fluffy powder
115
16
112
Specific Gravity (g/ml) 2.65
112,115
Vapor Pressure (mmHg) 0
16,112,115
Melting Point (ºC) ~1700-1710
115
Boiling Point (ºC) 2230
16
Water Solubility (mg/l @ 20ºC) 15-68
16
pH 4-9
Sodium Magnesium Silicate
2
pH 8.5-10.5 (2% aqueous dispersion)
9
Physical Form White powder
9
9
Melting Point (ºC) > 400
9
Water Solubility (mg/l @ 20ºC) 2.24
Sodium Metasilicate
3
Physical Form Nonahydrate, efflorescent platelets
3
3
Density (g/ml) 2.614
Table 2. Physical and chemical properties

Property Value Reference
11
Vapor Pressure (mmHg @ 1175ºC) 0.00772
3
11
Water Solubility (g/l @ 20 ºC) 210
3
pH 12 (0.1% solution)
Sodium Silicate
3
Physical Form Colorless to white or grayish-white, crystal-like clumps or aqueous solutions
12
Density (g/ml) 1.26 - 1.71
12
Vapor Pressure (mmHg) 0.00120
12
Melting Point (ºC) 730 - 870
12
Water Solubility (mg/l @ 20 ºC) 115
3
Acidity/Alkalinity Strongly alkaline
Zeolite
2
Physical Form Crystalline, hydrated alkali-aluminum silicates
Zinc Silicate
61,63
Physical Form White crystals or white powder
63
61
Density (g/ml) 4.103
61
8
Water Solubility (µg/l @ 20 ºC) 162.01
Zirconium Silicate
2
Physical Form Bipyramidal crystals, colorless unless has impurities and radioactive
bombardment; red or various colored crystals
2
2
Density (g/ml) 4.56
2
pH 6-7.5 (10% aqueous slurry)
Table 3. Current (2018) and historical frequency and concentration according to duration and type of exposure for previously reviewed silicates2-4,30
Aluminum Calcium Sodium Silicate Aluminum Silicate
# of Uses Max Conc of Use (%) # of Uses Max Conc of Use (%)
2018 2009 2018 2008 2018 1998 2018 1999
Totals* 250 7 0.0001-26.3 0.4-6 68 10 2.8-4.6 0.5-37
Leave-On 250 7 0.0001-26.3 0.4-6 46 6 NR 0.5-3

Rinse-Off NR NR 1.8 NR 22 4 2.8-4.6 2-37
Diluted for (Bath) Use NR NR NR NR NR NR NR NR
Eye Area 65 NR 0.006-26.3 0.5 1 2 NR 0.5

Incidental Ingestion 125 NR 3.5-5.5 6 NR NR NR 37
Incidental Inhalation-Spray 13a; 3b 1a NR NR 6; 12a; 23b 1a NR NR
Incidental Inhalation-Powder 3; 3b 1 NR NR 23b NR NR NR
Dermal Contact 92 3 0.006-26.3 0.4-6 58 8 2.8-4.6 2-3
Deodorant (underarm) NR NR NR NR NR NR NR NR
Hair - Non-Coloring 1 NR NR NR 4 NR NR NR
Hair-Coloring NR NR NR NR 6 NR NR NR
Nail 32 4 0.0001-0.25 0.5 NR NR NR NR
Mucous Membrane 125 NR 3.5-5.5 6 4 NR 4.6 37
Baby Products NR NR NR NR NR NR NR NR
Attapulgite Bentonite
2018 1998 2018 1999 2018 1998 2018 1999
Totals* 4 10 NR 8 339 94 0.00002-29.7 0.5-80
Leave-On 1 5 NR 8 157 37 0.00008-15 0.8-8

Rinse-Off 3 5 NR 8 180 57 0.00002-29.7 0.5-80
Diluted for (Bath) Use NR NR NR NR 2 NR 0.14 5
Eye Area 1 NR NR NR 38 8 0.00025-2 0.8-5

Incidental Ingestion NR NR NR NR 7 NR NR NR
Incidental Inhalation-Spray NR NR NR 8b 1; 36a; 27b 5a; 7b 0.1 1-3a; 2-5b
Incidental Inhalation-Powder NR 5 NR 8b 3; 27b; 1c 7b 2-2.6; 2-5b
0.35-14.3c
Dermal Contact 4 10 NR 8 276 88 0.00002-29.7 0.5-80
Deodorant (underarm) NR NR NR NR 5a NR NR NR
Hair - Non-Coloring NR NR NR NR 16 4 0.1 NR
Hair-Coloring NR NR NR NR NR NR 17.3 NR
Nail NR NR NR NR 21 1 0.00008-0.88 1
Mucous Membrane NR NR NR NR 17 3 0.14-0.35 0.5-5
Baby Products NR NR NR NR 1 NR NR NR
Calcium Silicate Fuller’s Earth
2018 1998 2018 1999 2018 1998 2018 1999
Totals* 101 132 0.00013-20 0.3-10 15 3 NR NR
Leave-On 91 115 0.00013-5 0.3-10 3 1 NR NR

Rinse-Off 1 1 1.5-20 8 12 2 NR NR
Diluted for (Bath) Use 9 16 0.86-1.3 NR NR NR NR NR
Eye Area 7 11 1 1-8 1 NR NR NR

Incidental Ingestion NR 3 0.00013 0.5 1 NR NR NR
Incidental Inhalation-Spray 1b NR 0.005 NR 1b NR NR NR
Incidental Inhalation-Powder 61; 1b 75 0.25-5; 4.7-5c 0.3-10 1b NR NR NR
Dermal Contact 100 128 0.25-20 0.3-10 14 3 NR NR
Hair - Non-Coloring NR NR 1.5 NR NR NR NR NR
Hair-Coloring NR NR 0.005 NR NR NR NR NR
Nail 1 1 NR NR NR NR NR NR
Mucous Membrane 9 19 0.00013-1.3 0.5 2 NR NR NR
Hectorite Hydrated Silica*

2018 1998 2018 1999 2018 2009 2018 2008
Totals* 83 18 0.1-3.2 0.4-100 449 176 0.00001-33.8 0.001-34
Leave-On 59 10 0.1-3.2 0.7-15 197 90 0.0002-10 0.001-4

Rinse-Off 24 8 0.5 0.4-100 244 78 0.00001-33.8 0.01-34
Diluted for (Bath) Use NR NR NR NR 8 8 0.3-12 0.4-4
Eye Area 34 4 0.1-0.8 0.7 12 8 0.001-5.8 0.06-2

Incidental Ingestion NR NR NR NR 83 25 0.17-33.8 0.003-34
Incidental Inhalation-Spray 2a; 4b 1a NR 8b 13a; 10b 10a; 12b 0.45-0.9; 0.04-2a; 0.06-2b
8.9-23.7a
Incidental Inhalation-Powder 3; 4b NR 0.8-1.1c 8b 31; 10b 33; 12b 1; 0.0012-10c 2-4; 0.06-2b
Dermal Contact 62 10 0.1-3.2 0.4-100 333 117 0.0002-16 0.001-17
Deodorant (underarm) NR 1a NR 0.7a 1a NR 0.066 2a
Hair - Non-Coloring 8 NR NR 1 4 NR 0.00001-8.9 0.04-2
Hair-Coloring 1 5 NR NR 9 20 1.9-8.9 2
Nail 1 2 0.7 NR 16 13 0.75-5.5 1-2
Mucous Membrane NR 1 NR NR 249 50 0.0051-33.8 0.003-34
Baby Products NR NR NR NR NR NR 0.0041-0.005 NR
Kaolin Lithium Magnesium Silicate
2018** 1998 2018 1999 2018 1998 2018 1999
Totals* 1794 509 0.0001-53 0.01-100 2 NR 0.3-5 NR
Leave-On 1171 501 0.0001-53 2-100 2 NR 0.3-5 NR

Rinse-Off 609 7 0.0005-35 0.01-84 NR NR NR NR
Diluted for (Bath) Use 14 1 NR NR NR NR NR NR
Eye Area 515 231 0.75-27.2 3-48 NR NR NR NR

Incidental Ingestion 90 6 0.97-11.9 12-30 2 NR NR NR
Incidental Inhalation-Spray 69a; 84b NR 0.0096; 0.15-25a; 2-25a; 3b NR NR 0.4; 0.3a NR
4b
Incidental Inhalation-Powder 125; 84b; 3c 98 2-23.1; 4b; 1-25c 5-30; 3b NR NR 5c NR
Dermal Contact 1566 466 0.0005-35 0.01-100 NR NR 0.4-5 NR
Deodorant (underarm) 5a NR NR NR NR NR NR NR
Hair - Non-Coloring 41 5 0.0096-25 4-15 NR NR 0.3 NR
Hair-Coloring 25 1 0.4-31 NR NR NR NR NR
Nail 10 NR 0.0001-53 53-54 NR NR NR NR
Mucous Membrane 147 8 0.05-11.9 3-30 2 NR NR NR
Baby Products 3 NR NR NR NR NR NR NR
Lithium Magnesium Sodium Silicate Magnesium Aluminometasilicate

2018 1998 2018 1999 2018 2009 2018 2008
Totals* 56 NR 0.0005-6 NR 3 NR NR 0.002-0.01
Leave-On 35 NR 0.0005-6 NR 2 NR NR 0.002-0.01

Rinse-Off 21 NR 0.4 NR 1 NR NR NR
Eye Area 5 NR 0.0005-4 NR NR NR NR NR

Incidental Ingestion NR NR NR NR NR NR NR NR
Incidental Inhalation-Spray 4a; 2b NR 6a NR 1b NR NR 0.002-0.01b
Incidental Inhalation-Powder 2b NR 3c NR 1b NR NR 0.002-0.01b
Dermal Contact 31 NR 0.0005-4 NR 3 NR NR 0.002-0.01
Deodorant (underarm) NR NR 0.5 NR NR NR NR NR
Hair - Non-Coloring 12 NR 6 NR NR NR NR NR
Hair-Coloring NR NR NR NR NR NR NR NR
Nail 10 NR NR NR NR NR NR NR
Mucous Membrane NR NR NR NR NR NR NR NR
Magnesium Aluminum Silicate Magnesium Silicate
2018 1998 2018 1999 2018 1998 2018 1999
Totals* 917 632 0.0004-11 0.1-5 70 NR 0.001-21.6 NR
Leave-On 734 509 0.0008-11 0.1-5 68 NR 0.001-21.6 NR

Rinse-Off 183 122 0.0004-10 0.1-5 2 NR NR NR
Diluted for (Bath) Use NR 1 NR NR NR NR NR NR
Eye Area 207 76 0.0025-4.5 0.2-5 24 NR 3-21.6 NR

Incidental Ingestion 5 3 0.93 0.7 14 NR 10 NR
Incidental Inhalation-Spray 1; 144a; 148b 2; 106a; 75b 0.5-0.8a 0.3-5a,b 2a; 3b NR NR NR
Incidental Inhalation-Powder 30; 148b; 8c 75b 1; 0.3-11c 0.3-5b 5; 3b NR 1c NR
Dermal Contact 862 583 0.0004-11 0.1-5 55 NR 0.001-21.6 NR
Deodorant (underarm) 8a 5a 0.5-0.7 0.5-1a NR NR NR NR
Hair - Non-Coloring 15 10 0.19-0.8 1-2 NR NR NR NR
Hair-Coloring 6 1 NR 2 NR NR NR NR
Nail 1 2 NR NR 1 NR NR NR
Mucous Membrane 34 19 0.93 0.5-2 14 NR 10 NR
Baby Products 8 NR NR NR NR NR NR NR
Magnesium Trisilicate Montmorillonite

2018 1998 2018 1999 2018 1998 2018 1999
Totals* 17 NR NR NR 177 NR 0.05-8.2 NR
Leave-On NR NR NR NR 101 NR 0.05-6 NR

Rinse-Off 17 NR NR NR 75 NR 0.5-8.2 NR
Diluted for (Bath) Use NR NR NR NR 1 NR NR NR
Eye Area NR NR NR NR 39 NR 0.3-2.8 NR

Incidental Ingestion NR NR NR NR 13 NR 1.7 NR
Incidental Inhalation-Spray NR NR NR NR 12a; 7b NR NR NR
Incidental Inhalation-Powder NR NR NR NR 5; 7b; 1c NR 2.5-6c NR
Dermal Contact 16 NR NR NR 145 NR 0.05-6 NR
Hair - Non-Coloring NR NR NR NR 9 NR 8.2 NR
Hair-Coloring 1 NR NR NR NR NR NR NR
Nail NR NR NR NR NR NR NR NR
Mucous Membrane NR NR NR NR 23 NR 0.5-1.7 NR
Baby Products NR NR NR NR 1 NR NR NR
Potassium Silicate Silica***
2018 2001 2018 1999/2000 2018 2009 2018 2008
Totals* 1 2 NR NR 8024 3276 0.000005-82 0.0000003-44
Leave-On NR 1 NR NR 7416 2937 0.0001-82 0.00004-44

Rinse-Off 1 1 NR NR 558 316 0.000005-21 0.0000003-16
Diluted for (Bath) Use NR NR NR NR 50 23 0.1-4 0.02-2
Eye Area NR NR NR NR 2403 867 0.00068-50 0.0004-44

Incidental Ingestion NR NR NR NR 1583 551 0.014-50 0.01-21
Incidental Inhalation-Spray NR NR NR NR 131; 473a; 382b 19; 247a; 183b 0.0001-2; 0.0005-6;
0.0042-14a; 0.00004-8a;
0.0042-14b 0.02-10b
Incidental Inhalation-Powder NR NR NR NR 507; 382b; 3c 248; 183b; 1c 0.016-66; 1-26; 0.02-10b
0.0042-14b;
0.08-82c
Dermal Contact 1 1 NR NR 5297 2298 0.0001-82 0.0000003-44
Deodorant (underarm) NR NR NR NR 31a 38a 0.0001-10.4 0.02-9a
Hair - Non-Coloring NR 1 NR NR 111 51 0.000005-4 0.0005-3
Hair-Coloring NR NR NR NR 187 149 0.0005-10 0.002-6
Nail NR NR NR NR 549 92 0.2-10 0.3-9
Mucous Membrane NR NR NR NR 1792 624 0.0005-50 0.0000003-21
Baby Products NR NR NR NR 7 2 0.0006-3 0.003-10
Sodium Magnesium Silicate Sodium Metasilicate

2018 1998 2018 1999 2018 2001 2018 1999/2000
Totals* 139 34 0.13-0.2 0.08-5 137 191 0.001-15 13-18
Leave-On 84 33 0.13 0.08-5 1 NR 0.001 NR

Rinse-Off 54 1 0.2 0.3-5 136 191 1.2-15 13-18
Diluted for (Bath) Use 1 NR NR NR NR NR 0.1 NR
Eye Area 13 13 NR 0.08-0.4 NR NR NR NR

Incidental Ingestion 9 1 NR 0.3-3 NR NR NR NR
Incidental Inhalation-Spray 37a; 5b 2a; 5b NR 1-5a; 0.1-5b 1a NR NR NR
Incidental Inhalation-Powder 7; 5b 4; 5b NR 0.4; 0.1-5b NR NR NR NR
Dermal Contact 127 31 0.13-0.2 0.08-5 NR 2 0.001-1.2 NR
Deodorant (underarm) NR NR NR 0.5a NR NR NR NR
Hair - Non-Coloring 2 1 NR NR 1 1 NR NR
Hair-Coloring NR NR NR NR 136 188 5-15 13-18d
Nail NR NR NR NR NR NR NR NR
Mucous Membrane 13 1 NR 0.3 NR NR 0.1 NR
Sodium Potassium Aluminum Silicate Sodium Silicate
2018 2009 2018 2008 2018 2001 2018 1999/2000
Totals* 12 1 0.36-1.1 0.001-4 91 22 0.017-35 0.06-55
Leave-On 10 NR 0.36-1.1 0.001-4 15 2 NR 0.6-1

Rinse-Off 2 1 NR NR 76 20 0.017-35 0.06-55
Eye Area NR NR 1.1 NR 4 1 NR NR

Incidental Ingestion NR NR NR NR 1 NR 0.44 0.6
Incidental Inhalation-Spray 5a NR NR NR 1a; 6b 1b NR NR
Incidental Inhalation-Powder NR NR 0.36c NR 6b 1b NR NR
Dermal Contact 12 1 0.36-1.1 NR 35 14 0.017-1.5 0.06-10
Hair - Non-Coloring NR NR NR NR 1 NR NR NR
Hair-Coloring NR NR NR NR 54 8 15-35 1-55e
Nail NR NR NR 0.001-4 NR NR NR NR
Mucous Membrane 1 NR NR NR 8 2 0.44-1.4 0.06-7
Baby Products NR NR NR NR NR NR NR 0.6
Zeolite NR = Not reported. S = Survey in progress.

# of Uses Max Conc of Use (%) † Because each ingredient may be used in cosmetics with multiple
2018 1998 2018 1999 exposure types, the sum of all exposure types may not equal the sum
Totals* 157 NR 0.0043-37.8 NR of total uses.
a.
It is possible these products may be sprays, but it is not specified
Leave-On 140 NR 0.03-35.7 NR
whether the reported uses are sprays.
Rinse-Off 17 NR 0.0043-37.8 NR b.
Diluted for (Bath) Use NR NR NR NR Not specified whether a powder or a spray, so this information is
captured for both categories of incidental inhalation.
c.
Eye Area 25 NR 0.032-3.6 NR It is possible these products may be powders, but it is not specified
Incidental Ingestion 3 NR 3 NR whether the reported uses are powders.
d.
Incidental Inhalation-Spray 3; 15a; 11b NR 1; 35.7a NR Hair bleaches were diluted from 13% to 18% to 7% to 14%
Incidental Inhalation-Powder 45; 11b NR 0.6-1.1; 0.5-1c NR before use.
e.
Dermal Contact 146 NR 0.0043-37.8 NR Hair bleaches were diluted from 16%-55% to 1%-20% before use.
Deodorant (underarm) NR NR NR NR *Includes entries for Hydrated Silica and Silicic Acid from the
Hair - Non-Coloring 8 NR 1-35.7 NR VCRP database.
Hair-Coloring NR NR 5 NR ** Includes entries for Kaolinite from the VCRP database.
Nail NR NR NR NR *** Includes entries for Silica; Silica, Amorphous; Silica, Fumed;
Mucous Membrane 5 NR 3 NR and Silicon Dioxide, Colloidal from the VCRP database.
Baby Products NR NR NR NR
Table 4. 2018 frequency and concentration of use according to duration and type of exposure for potential Silicate add-on
ingredients30
Ammonium Silver Zinc Aluminum Silicate Zinc Zeolite
Totals† 17 0.001 1 NR
Duration of Use
Leave-On 16 NR NR NR
Rinse Off 1 0.001 1 NR
Diluted for (Bath) Use NR NR NR NR
Exposure Type
Eye Area 13 NR NR NR
Incidental Ingestion NR NR NR NR
Incidental Inhalation-Spray NR NR NR NR
Incidental Inhalation-Powder 1 NR NR NR
Dermal Contact 17 0.001 NR NR
Deodorant (underarm) NR NR NR NR
Hair - Non-Coloring NR NR 1 NR
Hair-Coloring NR NR NR NR
Nail NR NR NR NR
Mucous Membrane NR NR NR NR
Baby Products NR NR NR NR
NR = Not reported. S = Survey in progress.
† Because each ingredient may be used in cosmetics with multiple exposure types, the sum of all exposure types may not equal the
sum of total uses.
Table 5. Ingredients not reported to be in use.30

Activated Clay
Aluminum Iron Calcium Magnesium Germanium Silicates
Aluminum Iron Calcium Magnesium Zirconium Silicates
Aluminum Iron Silicates*
Ammonium Silver Zeolite
Calcium Magnesium Silicate
Gold Zeolite
Pyrophyllite*
Silver Copper Zeolite
Sodium Silver Aluminum Silicate
Titanium Zeolite
Tromethamine Magnesium Aluminum Silicate
Zinc Silicate
Zirconium Silicate*
*Additionally, no uses were reported in original safety assessment.
Table 6. Acute toxicity studies

Ingredient/Concentration/Vehicle Dose/Study Protocol Results LD 50 or LC 50 Reference
Dermal
68
Bentonite (2/3 weight) and Zeolite (1/3 ~8 g applied on wounded At day 12 termination, Not measured
weight) in a hemostatic agent skin to 12 male Sprague- reduction in the length density
Dawley rats, another 12 of the blood vessels (31%) and
rats served as controls; diameter of the large and
wounds were circular, small vessels (38% and 16%,
full-thickness and 2 cm respectively) was observed in
in diameter; skin the rats that received the test
sampled excised and material; at day 21
evaluated stereologically termination, volume density of
after scarification; 6 rats both the dermis and collagen
from test group and 6 bundles was reduced by 25%
rats from control group in the treated rats when
were killed on days 12 compared to the controls;
and 21 authors concluded hemostatic
agent containing Bentonite
and Zeolite may cause
vasoconstriction and
inhibition of neoangiogenesis
16,20
Hydrated Silica; no further details 2000 mg/kg bw applied Details not provided > 2 g/kg
to intact and abraded
skin for 24 h; 10 New
Zealand white rabbits; no
further details
16
Hydrated Silica; in aqueous paste 4 different products; 16 Very slight erythema that Not reported
total New Zealand white disappeared after 2, 4, or 5
rabbits; applied to intact days for 3 products; no effects
and abraded skin under observed in the 4th product
occlusive patch; no
further details
16,20
Hydrated Silica; in water 2000, 3000, 4000, or Very slight erythema; no > 5 g/kg
5000 mg/kg in groups of systemic signs of toxicity or
4 New Zealand white organ toxicity
rabbits; 2 rabbits in each
group had abraded skin;
test site was covered
with occlusive patch for
24 h; no further details
10
30% Potassium Silicate solution in water; 5000 mg/kg bw applied Erythema and alopecia noted > 5 g/kg
molar ratio = 2.47 for 24 h to 5 male and 5 at application site of 4 females
female Sprague-Dawley and 1 male between days 1
rats; test sites were and 8; no other adverse effects
occluded during observation period or
necropsy
Oral
13
Aluminum Silicate in water; concentration 2000 mg/kg bw; 3 No mortality occurred from > 2 g/kg bw
not reported female Sprague-Dawley dosing; no clinical signs of
rats via gavage toxicity; no treatment-related
effects at necropsy
14
20% Calcium Silicate in feed 10 g/kg bw; 10 male and No mortality occurred from > 10 g/kg bw
10 female Wistar rats via dosing; no significant clinical
diet findings; no treatment-related
effects at necropsy
16,20
Hydrated Silica; in 5110 mg/kg; 5 male and No clinical signs of toxicity; > 5110 mg/kg
carboxymethylcellulose 5 female Wistar rats via no treatment-related effects at
gavage necropsy
16,20
Hydrated Silica; in aqueous suspension of 2000 or 5000 mg/kg bw; No clinical signs of toxicity; > 5000 mg/kg
1% carboxymethylcellulose 10 male and 10 female no treatment-related effects at
Sprague-Dawley rats per necropsy
single dose via gavage
16,20
Hydrated Silica; in 0.85% saline 10 to 5000 mg/kg bw; Distended stomachs with 470 mg/kg
male rats; no further bloody patches at the pyloric
details end were observed at necropsy
in animals that received > 100
mg/kg; at 5000 mg/kg,
vascular stomach and
reddened intestinal lining were

observed
16,20
Hydrated Silica; suspended (12.1% (w/v)) Male rats; no further No clinical signs of toxicity; > 5000 mg/kg
in 0.85% saline details no treatment-related effects at
necropsy
16,20
Hydrated Silica; in dispersion of 10% gum 5000 mg/kg; 5 male and No clinical signs of toxicity; > 5000 mg/kg
arabic in water 5 female rats; no further no treatment-related effects at
details necropsy
16,20
Hydrated Silica; in water 5620 mg/kg; 30 male No clinical signs of toxicity; > 5620 mg/kg bw
Sprague-Dawley rats via stools were white for 2 days
single gavage dose
16,20
Hydrated Silica; suspended in water (33% 10,000, 12,600, 15,800, No clinical signs of toxicity; > 20,000 mg/kg bw
w/w) or 20,000 mg/kg bw; 5 stools were white for 2 days
Sprague-Dawley rats per
sex per dose via gavage
16,20
Hydrated Silica; 30% neutralized with HCl Male rats; no further Details not provided 10,000 mg/kg bw
details
20
Hydrated Silica; in 1% aqueous gum 20,000, 25,200, or Details not provided > 31,800 mg/kg bw
arabic solution 31,800 mg/kg bw; 5 male
and 5 female Sprague-
Dawley rats per dose
group; no further details
20
Hydrated Silica; in olive oil 4000, 5040, or 6350 Details not provided > 6350 mg/kg bw
mg/kg bw; 5 male and 5
female Sprague-Dawley
rats per dose group; no
further details
20
Hydrated Silica; in water 10,000; 5 male and 5 Details not provided > 10,000 mg/kg bw
rats; no further details
20
Hydrated Silica; in water 10,000, 12,600, 15,800, Details not provided > 20,000 mg/kg bw
or 20,000 mg/kg bw; 5
Sprague-Dawley rats per
sex per dose; no further
details
20
Hydrated Silica; in saline 5000 mg/kg bw; male Details not provided >5000 mg/kg bw
Sprague-Dawley rats; no
further details
20
Hydrated Silica; in water 31,600 mg/kg bw; 5 male Details not provided > 31,600 mg/kg bw
Dawley rats; 24 h
observation; no further
details
16,20
Hydrated Silica; 26% in water; pH 4.5 10 male Sprague-Dawley Details not provided 40,000 mg/kg bw
rats; no further details
20
Hydrated Silica; in olive oil 5040, 6350, or 7900 Details not provided > 7900 mg/kg bw
mg/kg bw; 5 male and 5
rats per dose group; no
further details
15
Potassium Silicate; concentration and 3.30, 3.96, 4.75, 5.70, or Deaths per dose = 1/10 at 2.50 5.70 g/kg bw
vehicle not reported 6.86 g/kg bw; 5 male and ml/kg, 2/10 at 3.00 ml/kg,
5 female Cpb; Wu 2/10 at 3.60 ml/kg, 3/10 at
Wistar rats per dose; 4.32 ml/kg, and 10/10 at 5.20
method of delivery not ml/kg; sedation, signs of
reported abdominal discomfort,
sluggishness and
unconsciousness were all
reversible; no treatment-
related effects at necropsy
10
Potassium Silicate; undiluted; no further 5.0 g/kg bw in 3 female No deaths occurred following > 5.0 g/kg bw
details reported Sprague-Dawley rats via treatment; no clinical or gross
gavage macroscopic signs of toxicity
observed
69
Silica; no further details 1.00, 2.15, or 3.16 g/kg No gross signs of systemic > 3.16 g/kg bw
bw in 5 male albino rats; toxicity and no mortalities
no further details

70
Silica; no further details 30 male rats; no further No clinical signs of toxicity or > 5.62 g/kg bw
details mortalities during the 2 week
observation period
28
Silica; in olive oil or peanut oil 5040, 6350, or 7900 No clinical signs of toxicity or > 7900 mg/kg in
mg/kg in olive oil or unscheduled mortalities olive oil and > 5000
2500 or 5000 mg/kg in during the 4 week observation mg/kg in peanut oil
peanut oil; groups of 10 period; no treatment-related
Sprague-Dawley rats; no effects at necropsy
further details
16,20
Silica; in aqueous suspension of 1% 2000 or 3300 mg/kg bw No clinical signs or gross > 3300 mg/kg
methylhydroxyethyl cellulose in10 male and 10 female macroscopic signs of toxicity
Sprague-Dawley rats per observed
single dose via gavage
16,20
Silica incorporated into a stock diet at a 10 Wistar male/female No clinical signs of toxicity; > 10,000 mg/kg
ratio of 1:4 (w/w) rats; dosing period was no treatment-related effects at
24 h; no further details necropsy; stool grey in color
with normal consistently but
larger in size than normal
20
Silica (hydrophobic); in peanut oil 2500 or 5000 mg/kg bw; Details not provided > 5000 mg/kg
10 male and 10 female
further details
20
Silica (hydrophilic); in 0.5% 1000, 2750, or 3160 Details not provided > 3160 mg/kg
methylcellulose mg/kg bw; 5 male
Boltzman rats per dose
group; no further details
20
Silica (hydrophilic); in water 5 male and 5 female Details not provided > 5000 mg/kg bw
further details
16,20
Silica (hydrophilic); in corn oil 178, 316, 562, 1000, No adverse signs of toxicity > 3160 mg/kg bw
1780, or 3160 mg/kg bw; and no macroscopic lesions at
groups of 10 male Swiss necropsy
mice; via gavage
20
Silica (hydrophobic); in corn oil 5000 mg/kg b; 5 male Details not provided > 5000 mg/kg bw
Dawley rats; no further
details
20
Silica (hydrophobic); in corn oil 178, 316, 562, 1000, Details not provided > 3160 mg/kg bw
1780, or 3160 mg/kg bw;
groups of 10 male
Sprague Dawley rats; no
further details
20
Silica (hydrophobic); in distilled water 1000, 1590, 2510, 3980, Details not provided 9200 mg/kg bw
6310, or 10,000 mg/kg males; >10,000
bw; groups of 5 male and mg/kg bw females
5 female Sprague-
details
20
Silica (hydrophobic); in corn oil 5000 mg/kg bw; 5 male Details not provided > 5000 mg/kg bw
details
20
Silica (hydrophobic); in corn oil 5000 mg/kg bw; 5 male Details not provided >5000 mg/kg bw
details
20
Silica (hydrophobic); in polyethylene 2000 mg/kg bw; 5 male Details not provided > 2000 mg/kg bw
glycol 400 and 5 female Wistar rats;
no further details
9
Sodium Magnesium Aluminum Silicate in 2.0 g/kg bw in 6 female No deaths occurred following > 2.0 g/kg bw
water; no further details reported Sprague-Dawley rats via treatment; no clinical or gross
gavage macroscopic signs of toxicity
observed

12
Sodium Silicate; molar ratio 3.27; 3.43, 4.11, 4.93, 5.89, Deaths per dose = 0/10 at 3.43 5.15 g/kg bw
concentration and vehicle not reported 7.12, or 8.49 g/kg bw; 5 g/kg, 2/10 at 4.11 g/kg, 9/10 at
male and female Cpb:Wu 4.93, 5.89, and 7.12 g/kg, and
Wistar rats per dose via 10/10 at 8.49 g/kg; sedation,
gavage signs of abdominal
discomfort, sluggishness and
unconsciousness; no
treatment-related effects at
necropsy
12
Sodium Silicate in water; molar ratio = Male Wistar rats; no Breathing difficulties, 8.65 g/kg bw
3.38 additional details staggering gait, reduced
provided motility; additional effects not
reported
12
Sodium Silicate; molar ratio = 3.3; no Rats; no additional No details provided > 2.00 g/kg bw
additional details provided details provided
12
Sodium Silicate; molar ratio = 3.35; no Male mice; no additional No details provided 6.60 g/kg bw
additional details provided details provided
Inhalation
Hydrated Silica; no further details 10 or 100 mg/m3; 24 Transient inflammatory tissue Not reported 73
male CD rats; 6 h/d for 3 reaction observed in low dose

days followed by group at 24 h post-exposure
recovery periods of 1, 8, that resolved within 8 days;
30 or 90 days recovery in high dose group
similar to that in low dose
group
Hydrated Silica; 45% of particles < 5 µm; 691 mg/m3; 5 male and 5 Some decreased body weight > 691 mg/m3 16,20
surface area (SA) = 190 female Wistar rats; 4 h gain in females 2 days post-
whole body exposure; no exposure which resolved by
further details day 14; no abnormalities
observed at necropsy
Hydrated Silica; no further details 2200 mg/m3; 10 male One rat died 2 h after > 2200 mg/m3 16,20
Sprague-Dawley rats; 1 h exposure; irritation and

nose-only exposure; no dyspnea observed in most
further details animals; no further details
Hydrated Silica; no further details 3100 mg/m3; 2 male rats; Details not provided > 3100 mg/m3 20
4 h nose-only exposure;
no further details
Hydrated Silica (30% SiO 2 ); as mist; no 520 or 560 mg/m3; 2 No deaths; no further details > 560 mg/m3 20
further details male rats; 2.5 or 6 h

nose-only exposure;
preliminary test; no
further details
Hydrated Silica (5% SiO 2 ); as mist; no 760 mg/m3; male albino No deaths; no further details > 760 mg/m3 20
further details rats; 3.25 h whole body

exposure; no further
details
Hydrated Silica (20% SiO 2 ); as mist; no 2240 or 2500 mg/m3; No deaths; no further details > 2500 mg/m3 20
further details male albino rats; 4.2 h

whole body exposure; no
further details
Hydrated Silica (30% SiO 2 ); as mist; no 3300 mg/m3; male albino No deaths; no further details > 3300 mg/m3 20
further details rats; 1.5 h whole body

details
30% Potassium Silicate solution in water; 2.06 mg/l; whole body Animals had hunched posture > 2060 mg/m3 10
molar ratio 2.47 exposure for 4.4 h to 5 and hypoactivity during

male and 5 female exposure that reversed; no
Sprague-Dawley rats; deaths or adverse effects
particle size distribution during observation period or
= 4% at 9 µm, 8.3% at necropsy
5.8 µm, 11.1% at 4.7
µm, 12% at 3.3 µm, 32%
at 2.1 µm, 2.6% at 1.1
µm, 7.4% at 0.7 µm, and
2.6% at 0.4 µm

Silica (hydrophilic); 56% of particles < 5 139 mg/m3; 5 male and No clinical signs of toxicity > 139 mg/m3 16,20
µm; SA = 200 m2/g 5 female Wistar rats; 4 h and no organ abnormalities at

nose-only exposure; no necropsy
further details
Silica (hydrophilic); SA = 380 m2/g 0 or 207,000 mg/m3; 10 Vigorous cleansing activity, > 207,000 mg/m3 20
male albino rats per dose hypoactivity, abdominal

group;1 h nose-only respiration, gasping, nasal
exposure; no further exudation, closed eyes, crust-
details like material around nose and
mouth, and chalky fur up to 2
days post-exposure
Silica (hydrophilic); SA = 200 m2/g 0 or 191,300 mg/m3; Details not provided > 191,300 mg/m3 20
albino rats; 1 h nose-only

details
Silica (hydrophilic); particle size = 0.76 2080 mg/ m3; 5 male and Details not provided > 2080 mg/m3 16,20
µm; SA = 200 m2/g 5 female Sprague-

Dawley rats; 4 h nose-
only exposure; no further
details
Silica; particle size < 3 µm (84%); no 10 Sprague-Dawley rats; Clinical signs included nasal > 2.08 mg/m3 16
further details 4 h whole body discharge during exposure and

exposure; no further crusty eyes and nose and
details alopecia during the 14 d
observation period; reduced
body weight gain observed in
females in the first 3 days
post-exposure and then
returned to normal; discolored
lungs observed in 1 rat at
necropsy
Silica (hydrophobic); particle size = 1.4- 1094, 2863, 3730, or Details not provided 2863-3730 mg/m3; no 20
1.8 µm; SA = 80 m2/g 5382 mg/ m3; groups of 5 further details

male and 5 female
Wistar rats; 4 h whole
body exposure; no
further details
Silica (hydrophobic); particle size = 0.15 2280 mg/m3 ; 5 male and Details not provided > 2280 mg/m3 20
µm; SA = 130 m2/g 5 female rats; 1 h whole

body exposure; no
further details
Silica (hydrophobic); particle size < 5 µm 477 mg/m3; 5 male and 5 No mortalities during > 477 mg/m3 28
(56%) and > 7.7 µm (44%); SA = 200 female Wistar rats; 4 h exposure or observation
m2/g whole body exposure; period; body weights
rats were observed for 14 decreased during the first 2
days post-exposure and days after exposure before
periodically weighed; no returned to normal; necropsies
further details were unremarkable
Silica (hydrophobic); particle size = 0.36 0 or 4900 mg/m3; groups Details not provided < 4900 mg/m3; all 20
µm; SA = 200 m2/g of 5 male and 5 female animals died at this

Sprague-Dawley rats; 4 h dose
further details
Silica (hydrophobic); particle size = 0.54 0 or 2190 mg/m3; groups Details not provided < 2190 mg/m3; all 20
µm; SA = 200 m2/g of 5 male and 5 female animals died at this

Sprague-Dawley rats; 4 h dose
further details
Silica (hydrophobic); particle size = 0.48 0, 1260, 2830, or 6280 Details not provided 1260-2830 mg/m3; no 20
µm; SA = 200 m2/g mg/m3; groups of 5 male further details

Dawley rats; 1 h whole
body exposure; no
further details
Silica (hydrophobic); no further details 250 mg/m3; groups of 10 Clinical signs of toxicity > 250 mg/m3 20
male Swiss mice; 6 h included preening and

whole body exposure; no occasional prostration; no

further details significant findings at
necropsy
male Wistar rats; 6 h included preening, hunching

whole body exposure; no and occasional prostration; no
necropsy
male English short hair included preening;

guinea pigs; 6 h whole consolidation observed in the
body exposure; no lungs of 2/9 animals; no
necropsy
Silica (hydrophobic); no further details 670, 690, 710, 1540, or Details not provided > 3150 mg/m3 20
3150 mg/m3; 10 male

albino rats per group; 1 h
details
Silica (hydrophobic); particle size = 1.175- 210, 540, or 2100 All animals died in high dose 540 mg/m3 20
1.275 µm; SA = 130 m2/g mg/m3; groups of 5 male group within 2.5 h of
and 5 female Wistar rats; exposure; necropsy of this
4 h whole body group discovered eye opacity,
exposure; no further lung enlargement with red
details areas, and white material in
the nasal turbinates; in the
mid-dose group, 7/10 animals
died during exposure;
necropsy of mid-dose group
discovered opaque eyes, dark
enlarged lungs with red areas,
white material in nasal
turbinates, and red areas in the
intestines; all rats in low-dose
group survived; at necropsy,
low- dose group had dark
lungs with white and red areas
Silica (hydrophobic); particle size = 0.95- 90 or 840 mg/m3; groups Results similar as those listed 90-840 mg/m3 20
2.15 µm; SA = 300 m2/g of 5 male and 5 female above; no further details
Wistar rats; 4 h whole
body exposure; no
further details
Silica (hydrophobic); particle size < 0.2 350, 770, 2530, or 5300 All rats in 2530 and 5300 1650 mg/m3 20
µm; SA = 130 m2/g mg/m3; groups of 5 male mg/m3 dose groups died;
and 5 females Sprague- severe red discoloration of the
Dawley rats; 4 h whole lungs was noted in the rats
body exposure; no that died during the study; no
further details further details
Silica (hydrophobic); particle size = 7.2- 900 or 2200 mg/m3; 4/10 rats in high dose group > 2200 mg/m3 20
7.7µm; SA = 130 m2/g groups of 5 male and 5 died; severe discoloration of

females Sprague-Dawley the lungs was noted in the rats
rats; 4 h nose-only that died during the study;
exposure; no further surviving rats had normal
details lungs except 1 male and 2
females with trace
discoloration
Silica (hydrophobic); particle size < 900, 350, or 5000 Details not provided 90 mg/m3 20
0.1µm; SA = 300 m2/g mg/m3; groups of 5 male

and 5 females Sprague-
body exposure; no
further details
Silica (hydrophobic); particle size = 7.0- 400 or 600 mg/m3; Details not provided 500 mg/m3 20
7.1µm; SA = 300 m2/g groups of 5 male and 5

females Sprague-Dawley
rats; 4 h nose-only
details

Silica (hydrophobic); particle size < 80, 340, 1200, or 5000 Details not provided 800 mg/m3 20

body exposure; no
further details
Silica (hydrophobic); particle size = 6.3- 400, 700, or 2000 Details not provided 600 mg/m3 20

Dawley rats; 4 h nose-
only exposure; no further
details
Silica (hydrophobic); particle size =1-5 120, 400, 1370, or 3360 Details not provided 660 mg/m3 20
µm (83%) and 5-100 µm (17%); SA = 300 mg/m3; groups of 3 male

m2/g and 3 females Sprague-
body exposure; no
further details
Table 7. Repeated dose toxicity studies

Ingredient/Concentration/Dose/Vehicle Species/Strain/Cell Method Results Reference
Short-Term Dermal Toxicity
20
Silica; 0, 5, or 10 g/kg/d 2 male and 2 female albino Test material applied for No signs of systemic
rabbits per dose group; no 18 h/g, 5 d/week for 3 toxicity and no gross
further details weeks on intact and or microscopic
abraded skin; no further pathological findings;
details Silica content of
blood, urine, spleen,
liver, and kidney
similar to controls
Short-Term Oral Toxicity
16,20
Hydrated Silica; 7500 mg/kg/d; in feed 6 albino male rats; no further Dietary study where rats All animals lost
details received test material in weight during
feed 5 times per week for treatment, but gained
2 weeks over the weekend and
during post-
observation period; no
significant effects on
the organs
16,20
Hydrated Silica; 16.5 g/kg/d (10% w/w) Two groups of 5 male and 5 14 day dietary study; NOAEL > 24.2
in group 1 and 5.8 g/kg/d (5% w/w) and female Sprague-Dawley rats group1 received 16.5 g/kg/d; no clinical
24.2 g/kg/d (20% w/w) in group 2; in g/kg/d test material for 14 signs of toxicity or
feed days and group2 received significant changes in
5.8 g/kg/d for days 1-10 feed/water
and 24.2 g/kg/d for days consumption, body
11-14; pathological exam weight gains, or
not performed behavior
16,20
Hydrated Silica; 1500 mg/kg/d; in Female inbred rat; no further Daily gavage for 1 month No clinical signs of
aqueous solution details toxicity or significant
changes in feed
consumption, body
weight gain, or
behavior; Silica
content in liver = 1.5
µg, in kidney = 6.4 µg,
and in spleen = 5.3 µg
74
Montmorillonite; 1.5 g/day or 3.0 g/day 23 male and 27 female Oral study of the use of Mild gastrointestinal
in capsules human subjects the test material to protect effects reported with
against adverse effects of no statistical
the ingestion of aflatoxins; significance found
randomized and double- between the groups for
blinded study; blood and these effects; no
urine samples collected significant differences
before and after study in hematology, liver
and kidney function,
electrolytes in either
group
70
Silica; 0.2%, 1.0%, or 2.5% in feed Groups of 10male rats; no Dietary study 28 days in No adverse effects or
further details length; no further details unscheduled
mortalities; gross
necropsy findings
unremarkable
28
Silica; 0, 500, 1000, or 2000 mg/kg/d Groups of 5 male and 5 Dietary study 5 weeks in LOEL = 1000
with a 2 week stepwise increase to female Wistar rats length for low- and mid- mg/kg/d; NOEL =
16,000 mg/kg/d (approximately 25% dose groups and 8 weeks 500 mg/kg/d; high
feed intake) for high-dose group dose group had
significant reduction
in body weight
associated with
decreased feed intake;
no significant changes
in biological
parameters or
macroscopic findings;
at microscopic
examination, liver had
severe atrophy in the
epithelium
Table 7. Repeated dose toxicity studies

Ingredient/Concentration/Dose/Vehicle Species/Strain/Cell Method Results Reference
75
Silica; 0.8 g/kg/d in feed; no further 15 male and 15 female CD Dietary study 4 weeks in No treatment-related
details rats length; no further details effects observed
75
Silica; 0.8 g/kg/d in feed; no further Male and female Beagle Dietary study 4 weeks in No treatment-related
details dogs; no further details length; no further details effects observed
Subchronic Oral Toxicity
20
Hydrated Silica; 0, 250, 1000, or 4000 Groups of 10 male and 10 13 week dietary study NOEL = 4000
mg/kg/d (0%, 0.5%, 2%, or 8%); in feed female Wistar rats mg/kg/d; high dose
group had increased
feed intake associated
with a decreased feed
efficiency; increased
mean absolute and
relative weight for the
cecum in the high dose
group; no gross or
microscopic
pathological changes
in any dose group
76
Montmorillonite as an organo-modified Wistar rats; no further details 90-day oral study; no No adverse effects
clay; 40 mg/kg/d further details were observed in the
main organ tissues and
no significant effects
were observed in
blood clinical
biochemistry
parameters,
reduced/oxidized
glutathione ratio, or
interleukin-6 leakage
in serum
16,20
Silica (hydrophilic); 0, 700, 2100, or Groups of 15 male and 15 13 week dietary study NOAEL = 3500
3500 mg/kg/d ( 0%, 1%, 3%, or 5%); in female Charles River rats mg/kg/d; no clinical
feed signs of toxicity or
significant changes in
feed consumption or
growth rate; no gross
or microscopic
pathological changes;
no increase in Silica
content in the liver,
kidney, spleen, blood,
or urine after 45 or 90
d in the high dose
group
20
Silica (hydrophobic); 0, 1000, 2000, or Groups of 10 male and 10 13 week dietary study No clinical signs of
4000 mg/kg/d (0%, 1%, 2%, or 4%); in female Charles River rats toxicity; no gross or
feed microscopic
pathological changes;
no changes in
behavior or growth; a
minimal change in the
thyroid gland
morphology was
observed in the mid-
and high-dose males
Table 8. Genotoxicity studies

Ingredient/Concentration/Dose Species/Strain/Cell Method Results Reference
In Vitro
13
Aluminum Silicate in water, up to Salmonella typhimurium Ames test Not genotoxic
5017 µg/plate, with or without strains TA97a, TA98,
metabolic activation TA100, TA102, and
TA1535
13
Aluminum Silicate in DMSO; up Chinese hamster ovary HPRT gene mutation Not genotoxic
to 250 µg/ml without metabolic assay
activation; up to 500 µg/ml with
metabolic activation
16,20
Hydrated Silica; up to 10,000 S. typhimurium strains TA Ames test Negative; not
µg/plate with and without 98, TA100, TA1535, TA cytotoxic
metabolic activation 1537, and TA 1538
16,20
Hydrated Silica; concentration not S. typhimurium strain TA Ames test Negative
provided; without metabolic 1530, G-46
activation
16,20
Hydrated Silica; up to 10,000 Escherichia coli WP2 Tryptophan reversion Negative; not
µg/plate with and without cytotoxic
16,20
Hydrated Silica; concentration not Saccharomyces cerevisiae Forward mutation Negative
provided; without metabolic (D3)
activation
16,20
Hydrated Silica; 1-1000 µl/ml Human embryonic lung Chromosome aberration No significant
without metabolic activation cells (Wi-38) clastogenic activity
97
Montmorillonite; 15.65, 31.25 or Human hepatoma cell line Cytokinesis block Potentially
62.5 µg/ml (HepG2) micronucleus cytome genotoxic; an
assay increased number of
micro nuclei was
observed but there
were no effect
observed in
nucleoplasmic
bridges or nuclear
buds
93
Silica; up to 10 M; details not Bacillus subtilis Rec assay Negative
reported
93
Silica; up to 10 M; details not E. coli and S. typhimurium Ames test Not genotoxic
reported strains TA 98, TA 100, TA
1535, and TA 1538
16,20
Silica (hydrophobic); 1580 S. typhimurim strains TA Ames test Negative, not
µg/plate with and without 98, TA100, TA 1537 cytotoxic
16,20
Silica (hydrophilic); up to 10,000 S. typhimurium strains TA Ames test Negative; not
µg/plate with metabolic activation 98, TA 100, TA 1535, TA cytotoxic
1537, and TA 1538
16,20
Silica (hydrophilic); up to 5000 S. typhimurium strains TA Ames test Negative; not
µg/plate with and without 98, TA 100, TA 1535, TA cytotoxic
16,20
Silica (hydrophobic); up to 5000 S. typhimurium strains TA Ames test Negative; not
µg/plate with and without 98, TA 100, TA 1535, and cytotoxic
metabolic activation TA 1537, and TA 1538
16,20
16,20
16,20
16,20
metabolic activation TA 1537
16,20
metabolic activation TA 1537

94
Silica; up to 10 mg/plate in E. coli strain WP 2 and S. Ames test Not genotoxic
DMSO with and without typhimurium strains TA98,
metabolic activation TA100, TA1535, TA1537,
TA1538
28
Silica in a toluene extract; up to E. coli strain WP2uvrA Ames test; additional Not genotoxic
1580 µg/plate with and without and S. typhimurium strains test performed with
metabolic activation TA98, TA100, TA1535 epoxide hydrolase
inhibitor and glutathione
depletor 1,1,1-
trichloropropene-2,3-
oxide was added to the
activation mix in strain
TA98 to increase
sensitivity
16,20
Silica (hydrophobic); 5000 E. coli WP2 Tryptophan reversion Negative; not
16,20
Silica (hydrophobic); 5000 E. coli WP2 Tryptophan reversion Negative; not
Silica; up to 160 µg/cm3 Chinese hamster lung Micronucleus test Weak, but 95
fibroblasts significant, dose-

dependent induction
of micronuclei at
cytotoxic
concentrations; no
clastogenicity
observed in
conccentrations
lower than cytotoxic
levels
16
Silica; 19-300 µl/ml without Chinese hamster ovary Chromosomal aberration Negative
metabolic activation and 250-1000 (CHO) cells test
µl.ml with metabolic activation
16,20
Silica (hydrophilic); 38-300 µl/ml CHO cells Chromosome aberration No clastogenic
without metabolic activation and activity
250-1000 µl/ml with metabolic
activation
16
Silica; 10-250 µl/ml without CHO cells Hypoxanthine-guanine Negative
metabolic activation and 100-500 phosphoribosyl
µl/ml with metabolic activation transferase test
(HGPRT)
Silica; 68.9 and 137.9 µg/cm2 Chinese hamster Single-cell gel/Comet Dose-dependent 96
fibroblasts (V79) and assay increase in DNA

human embryonic lung migration in the gel
fibroblasts (HEL 299) in both cell lines
16,20
Silica; 0.3-1000 µl/ml; with and Primary rat hepatocytes Unscheduled DNA Negative; cytotoxic
without metabolic activation synthesis at 260-500 µl/ml
16,20
Silica (hydrophilic); 10-250 µl/ml CHO cells 6-Thioguanine resistance No significant
without metabolic activation and mutagenic activity
100-500 µl/ml with metabolic
activation
16,20
Silica (hydrophobic); 63-500 CHO cells Clastogenic activity No clastogenic
µl/ml with and without metabolic activity
activation
16,20
Silica (hydrophobic); 42-333 CHO cells Clastogenic activity No clastogenic
µl/ml with and without metabolic activity
activation
11
Sodium Metasilicate; up to 5000 S. typhimurium strains Ames test Not genotoxic
µg/plate, with or without TA98, TA100, TA 1535,
metabolic activation TA 1537 and Escherichia
coli WP2
11
Sodium Metasilicate; up to 675 Chinese hamster V79 cells HPRT gene mutation Not genotoxic
µg/ml without metabolic assay
activation and up to 1800 µg/ml
with metabolic activation

12
36% Sodium Silicate; molar ratio Chinese hamster V79 cells Chromosome aberration Not genotoxic
= 3.3; up to 156.3 µg/ml with and test
without metabolic activation
12
36% Sodium Silicate; molar ratio Chinese hamster V79 cells HPRT gene mutation Not genotoxic
= 3.35; up to 675 µg/ml without assay
metabolic activation and up to
1800 µg/ml with metabolic
activation
8
Zinc Silicate; 100, 316, 1000, S. typhimurium strains Ames test Not genotoxic
3160 or 5000 µg/plate with or TA98, TA100, TA102,
without metabolic activation TA1535, and TA1537
In Vivo
20
Hydrated Silica; 1.4-5000 mg/kg Mice (host) + S. Gene mutation (host No mutagenic
typhimurium TA 1530, G- mediated) method; a activity
46 (indicator) single or 5
intraperitoneal (i.p.)
injections of S.
typhimurium; cells
collected 3 h after last
administration
20
Hydrated Silica; 1.4-5000 mg/kg Mice (host) + S. cerevisiae Mitotic recombination No genotoxic
D3 (indicator) (host mediated); a single activity
or 5 i.p. injections of S.
cerevisiae; cells
collected 3 h after last
administration
20
Hydrated Silica; 1.4-5000 mg/kg Male Sprague-Dawley rats Chromosome aberration Negative
study with rat bone
marrow; animals were
killed at 6, 24, or 48 h
after dosing
20
Hydrated Silica; 1.4-5000 mg/kg Male Sprague-Dawley rats Chromosome aberration Negative
study with rat bone
marrow; animals were
killed at 6 h after dosing
20
Hydrated Silica; 1.4-5000 mg/kg 8 mated female Sprague- Dominant lethal Negative
Dawley rats mutation assay; animals
were killed 14 days after
mating for uterus
examination
20
Hydrated Silica; 1.4-5000 mg/kg 8 mated female Sprague- Dominant lethal Negative
Dawley rats mutation assay; animals
were killed 14 days after
mating for uterus
examination
Table 9. Dermal irritation and sensitization

Ingredient/Concentration/ Test System Method Results Reference
Dose/Vehicle
Irritation – In Vitro
13
Aluminum Silicate; 25 mg in EpiDerm tissue EpiDerm human skin model; material Not irritating
Dulbecco’s phosphate buffered applied for 30 min
saline
8
Zinc Silicate; undiluted; 25 mg EpiDerm tissue EpiDerm reconstructed human Not irritating
epidermis model in accordance with
OECD Test Guideline 439; test material
applied to 0.63 cm2 test tissue for 60
min
Irritation – Animal
20
Hydrated Silica; 500 mg 3 rabbits; no further details Dermal irritation study; test site No signs of irritation
occluded for 4 h; skin intact
20
Hydrated Silica; 500 mg as a 12 rabbits; no further Dermal irritation study; test site No signs of irritation
23% solution in methyl ethyl details occluded for 24 h; skin intact and
cellulose abraded
20
Hydrated Silica; 33 mg 6 rabbits; no further details Dermal irritation study; test site Very slight erythema
occluded for 24 h; skin intact and on 4 abraded sites and
abraded 5 intact sites at 24 h
20
Hydrated Silica; 190 mg 6 rabbits; no further details Dermal irritation study; test site Very slight erythema
occluded for 24 h; skin intact and on 3 abraded sites and
abraded 4 intact sites at 24 h
20
Hydrated Silica; 500 mg as a 12 rabbits; no further Dermal irritation study; test site No signs of irritation
50% solution in olive oil details occluded for 24 h; skin intact and
abraded
20
Hydrated Silica; 500 mg 12 rabbits; no further Dermal irritation study; test site No signs of irritation
details occluded for 24 h; skin intact and
abraded
20
20
occluded for 24 h; skin intact and
abraded
20
Hydrated Silica (hydrophobic); 12 rabbits; no further Dermal irritation study; test site No signs of irritation
500 mg as a 50% solution in details occluded for 24 h; skin intact and
olive oil abraded
10,15
36% (weight) Potassium 1 female New Zealand Dermal irritation study in accordance Slightly irritating;
Silicate; molar ratio = 2.0; 0.5ml White rabbit with OECD Test Guideline 404; test transient erythema
in water material applied to shaved test site and observed cleared by
semi-occluded for 4 h before being day 5; primary dermal
rinsed off with water; test site examined irritation index (PDII)
for up to 5 days =1
10,15
33% (weight) Potassium 1 male New Zealand White Dermal irritation study in accordance Moderately irritating;
Silicate; molar ratio = 3.0; 0.5ml rabbit with OECD Test Guideline 404; test well-defined erythema
in water material applied to shaved test site and and very slight edema
semi-occluded for 4 h before being persisted for at least 5
rinsed off with water; test site examined days; PDII =3
for up to 5 days
10,15
35% (weight) Potassium 3 New Zealand White Dermal irritation study in accordance Not irritating; slight
Silicate; molar ratio = 3.4; 0.5ml rabbits; sex not reported with OECD Test Guideline 404; test erythema after 1 h that
in deionized water material applied to shaved test site and cleared after 48 h;
occluded for 4 h before being rinsed; PDII = 0.17
test site examined for up to 7 days
10,15
25% dilution of 35% (weight) 3 New Zealand White Dermal irritation study in accordance Not irritating; very
Potassium Silicate; molar ratio = rabbits; sex not reported with OECD Test Guideline 404; test slight erythema 24 and
3.4; 0.5 ml in deionized water material applied to shaved test site and 48 h after treatment;
occluded for 4 h before being rinsed; PDII = 0
10,15
25% dilution of 29% (weight) 5 New Zealand White Dermal irritation study in accordance Not irritating; PDII = 0
Potassium Silicate; molar ratio = rabbits; sex not reported with OECD Test Guideline 404; test
3.9; 0.5 ml in deionized water material applied to shaved test site and
occluded for 4 h before being rinsed;

Dose/Vehicle
10,15
29% (weight) Potassium 5 New Zealand White Dermal irritation study in accordance Not irritating; slight
Silicate; molar ratio = 3.9; 0.5 rabbits; sex not reported with OECD Test Guideline 404; test erythema cleared by
ml in deionized water material applied to shaved test site and 24 h ;PDII = 0.25
occluded for 4 h before being rinsed;
20
Silica (hydrophilic); 500 mg in 3 6 rabbits; no further details Dermal irritation study; test site No signs of irritation
ml saline occluded for 24 h; skin intact and on intact skin; slight
abraded erythema on 3 abraded
sites
20
Silica (hydrophilic); 500 mg 6 rabbits; no further details Dermal irritation study; test site Very slight erythema
moistened with saline occluded for 24 h; skin intact and on 1 intact site at 24 h;
abraded very slight to well-
defined erythema on
abraded sites; no sign
of erythema at 72 h
post-patch removal
16,20
Silica (hydrophilic); 500 mg as a 12 rabbits; no further Dermal irritation study; test site No signs of irritation
12% solution in methyl ethyl details occluded for 24 h; skin intact and
cellulose abraded
20
Silica (hydrophobic); 500 mg as 12 rabbits; no further Dermal irritation study; test site No signs of irritation
a 6% solution in methyl ethyl details occluded for 24 h; skin intact and
cellulose abraded
20
Silica (hydrophobic); 500 mg 6 rabbits; no further details Dermal irritation study; test site No signs of irritation
moistened with polyethylene occluded for 24 h; skin intact and
glycol abraded
20
Silica (hydrophobic); silane 6 rabbits; no further details Dermal irritation study; test site No signs of irritation
treated; 500 mg moistened with occluded for 24 h; skin intact and
corn oil abraded
20
Silica (hydrophobic); 500 mg in 6 rabbits; no further details Dermal irritation study; test site No signs of irritation
2 ml water occluded for 24 h; skin intact and
abraded
20
Silica (hydrophobic); 500 mg 6 rabbits; no further details Dermal irritation study; test site semi- No signs of irritation
11
Sodium Metasilicate 1 male New Zealand White Dermal irritation study in accordance Corrosive; necrosis
(anhydrous); 0.5 g in water rabbits with OECD Test Guideline 404; test observed; PDII = 8; no
material applied to shaved test site and erythema or edema
semi-occluded for 4 h before being observed when applied
rinsed; test site examined for up to 5 as dry powder
days
11
Sodium Metasilicate 1 female New Zealand Dermal irritation study in accordance Corrosive; necrosis
(pentahydrate); 0.5 g in water White rabbits with OECD Test Guideline 404; test observed; PDII = 8; no
material applied to shaved test site and erythema or edema
semi-occluded for 4 h before being observed when applied
rinsed; test site examined for up to 5 as dry powder
days
11
10% aq. Sodium Metasilicate; 3 rabbits; strain and sex Dermal irritation study in accordance Slightly irritating;
0.5 ml in water not reported with OECD Test Guideline 404; test severity of erythema
material applied to shaved test site and reduced but persisted
semi-occluded for 4 h before being through day2; edema
rinsed; test site examined for up to 72 h in 1 animal reversed
by day 2; PDII = 1.22
11
50% aq. Sodium Metasilicate; 3 rabbits; strain and sex Dermal irritation study in accordance Irritating; PDII = 3.67
0.5 ml in water not reported with OECD Test Guideline 404; test
material applied to shaved test site and
semi-occluded for 4 h before being
rinsed; test site examined for up to 72 h
11
57.5% (weight) Sodium 3 white landrace rabbits; Dermal irritation study in accordance Corrosive; 2/3 animals
Metasilicate (pentahydrate); 0.5 sex not reported with OECD Test Guideline 404; test had acute skin necrosis
g material applied to shaved test site and and the 3rd had
semi-occluded for 4 h before being pigmented necrosis;
rinsed; test site examined for up to 14 wounds persisted for
days more than 14 days;
PDII = 7.8

Dose/Vehicle
11
97% (weight) Sodium 3 white landrace rabbits; Dermal irritation study in accordance Corrosive; 2/3 animals
Metasilicate (anhydrous); 0.5 g sex not reported with OECD Test Guideline 404; test had acute skin necrosis
material applied to shaved test site and with well-defined
semi-occluded for 4 h before being edema; wounds
rinsed; test site examined for up to 14 persisted for more than
days 14 days; third animal
had wounds that were
observed at up to 72 h
but had healed by day
14;PDII = 5.1
11
Sodium Metasilicate; 3 New Zealand White Dermal irritation study in accordance Not irritating; 1/3
concentration not reported; fine rabbits; sex not reported with OECD Test Guideline 404; test animals had erythema
powder with pH of 12.4 tested material applied to shaved test site and and edema 1 h post-
undiluted; 0.5 g semi-occluded for 4 h before being treatment that cleared
rinsed; test site examined for up to 14 by 72 h; PDII = 0.17
days
11
83% (w/w) Sodium Metasilicate 3 male New Zealand Dermal irritation study in accordance Corrosive; erythema
as aqueous paste; pH 12.4; 0.5 hybrid rabbits with OECD Test Guideline 404; test persisted for at least 14
g/0.10 purified water; 0.3 ml material applied to shaved test site and days; edema observed
applied semi-occluded for 4 h before being 1 h post-treatment but
rinsed; test site examined for up to 14 cleared by 72 h;
days necrosis persisted 7-
14+ days;PDII = 4.67
Sensitization – Animal
13
0%, 5%, 10%, or 25% (w/v) 4 female CBA/CaOlaHsd Local lymph node assay (LLNA) Not sensitizing;
Aluminum Silicate in dimethyl mice/dose group stimulation indices
sulfoxide; application volume = (SI) below 3
25 µl
103
Hydrated Silica; 10% at 10 female Hartley albino Guinea pig maximization test Not sensitizing
induction, and 1%-20% at guinea pigs treated; 5
challenge; in distilled water guinea pigs control
10
30% Potassium Silicate solution; 20 male Hartley guinea Buehler sensitization test; animals were Not sensitizing
molar ratio = 2.47 pigs received test material; induced with undiluted test material and
10 animals served as challenged at 75%
control
8
0%, 10%, 25%, or 50% Zinc 6 female NMRI mice/dose LLNA Not sensitizing; SI
Silicate in acetone/olive oil (4:1; group below 1.4; irritant
v/v) response noted
Sensitization- Human
70
Hydrated Silica (micronized gel) 300 patients Dermal irritation and sensitization study; Non-irritating and
in a dusting powder; details not reported non-toxic; little or no
concentration and dose not sensitizing reactions
reported observed
104
17% Hydrated Silica in a facial 27 subjects (18 males, 9 HRIPT; test sites pre-treated with 25% Not sensitizing
mask (0.05 ml) females) sodium lauryl sulfate (SLS; aq.; 0.05 ml)
under occlusion for 24 h prior to
induction; occluded
16
45% Hydrated Silica; no further 20 subjects (10 males, 10 HRIPT; details not reported Not sensitizing
details reported females)
105
21.74% Silica in a facial powder 27 subjects (18 males, 9 HRIPT; test sites pre-treated with 25% Not sensitizing
in a 30% aq. solution females) SLS aq. (0.05 ml) under occlusion for 24
h prior to induction; occluded
Table 10. Ocular irritation

Dose/Vehicle
In Vitro
13
Aluminum Silicate tested pure; Lohmann Leghorn chicken HET-CAM method; treatment duration Not irritating
no vehicle; 164.3 mg eggs = 5 min
11
Sodium Metasilicate; New Zealand White rabbit In vitro rabbit eye study; treatment Corrosive
concentration not reported; eyes duration = 0.17 min; eyes studied for
undiluted; 50 mg opacity for up to 4 h post-treatment
8
Zinc Silicate; 20% suspension in Bovine corneas Bovine corneal opacity and Irritating; mean
750 µl of physiological saline permeability test (BCOP); exposure opacity score of 3
solution (0.9% NaCl) was 4 h corneas was 6.31;
mean fluorescein
retentation/leakage
score was < 0.01
Animal
20
Hydrated Silica; 40 mg instilled 3 rabbits; no further details Ocular irritation study; no further No signs of irritation
details
20
Hydrated Silica; 100 mg 3 rabbits; no further details Ocular irritation study; no further Slight redness at 24,
instilled details 48, and 72 h that
resolved by day 4;
mean score = 0.7
20
Hydrated Silica; 100 mg 8 rabbits; no further details Ocular irritation study; eyes rinsed after No signs of irritation
instilled 5 min in 3 rabbits or not rinsed in 5
rabbits
28
Hydrated Silica; 0.1 ml of 50% 8 male New Zealand white Ocular irritation study; eyes rinsed after No signs of irritation
dilution in olive oil rabbits 5 min in 3 rabbits or not rinsed in 5 in rinsed eyes; very
rabbits slight erythema
observed up to 24 h
after instillation
20
Hydrated Silica; 100 mg 9 rabbits; no further details Ocular irritation study; eyes rinsed after No signs of irritation
instilled 4s in 3 rabbits or not rinsed in 6 rabbits
20
Hydrated Silica; 100 mg 6 rabbits; no further details Ocular irritation study; no further No signs of irritation
instilled; 0.2 ml of 50% slurry details
20
Hydrated Silica; 9 mg instilled 9 rabbits; no further details Ocular irritation study; eyes rinsed after No signs of irritation
2s in 3 rabbits, 4 s in 3 rabbits, or not
rinsed in 3 rabbits
10,15
29% (weight) Potassium 6 New Zealand White Ocular irritation study in accordance Not irritating
Silicate; molar ratio = 3.9; 0.1 rabbits; sex not reported with OECD Test Guideline 405; eyes
ml in water not rinsed; observed for up to 7 days
post-treatment
10,15
25% dilution of 29% (weight) 6 New Zealand White Ocular irritation study in accordance Not irritating
Potassium Silicate; molar ratio = rabbits; sex not reported with OECD Test Guideline 405; eyes
3.9; 0.1 ml in deionized water not rinsed; observed for up to 7 days
post-treatment
10,15
35% (weight) Potassium 3 New Zealand White Ocular irritation study in accordance Slightly irritating;
Silicate; molar ratio = 3.4; 0.1 rabbits; sex not reported with OECD Test Guideline 405; eyes redness and chemosis
ml in water not rinsed; observed for up to 7 days of the conjunctivae
post-treatment (scores 1.0-1.3 and
1.3-1.5, respectively)
observed up to 7 days
post-treatment
10,15
25% dilution of 35% (weight) 3 New Zealand White Ocular irritation study in accordance Not irritating
Potassium Silicate; molar ratio = rabbits; sex not reported with OECD Test Guideline 405; eyes
3.4; 0.1 ml in water not rinsed; observed for up to 7 days
post-treatment
10
~30% Potassium Silicate in 3 New Zealand White Ocular irritation study; eyes not rinsed; Slightly irritating
water; molar ratio = 2.47; 0.1 ml rabbits; sex not reported observed for up to 7 days post-
treatment
20
Silica (hydrophilic); 100 mg 8 rabbits; no further details Ocular irritation study; eyes not rinsed No signs of irritation
instilled in 5 rabbits; eyes rinsed in 3 rabbits
after 5 min
69
Silica (hydrophilic); 3 mg 3 rabbits; no further details Ocular irritation study; no further Slight to mild
instilled details erythema that resolved
by 48 h
Table 10. Ocular irritation

Dose/Vehicle
20
Silica (hydrophilic); 3.5 mg 6 rabbits; no further details Ocular irritation study; no further Slight conjunctival
instilled details erythema or chemosis
in some animals at 24,
48 and 72 h; mean
score 0.6 and 0.1,
respectively; transient
corneal opacity
observed in 2 animals
at 4 h
70
Silica (hydrophilic); 9 mg Rabbis; no further details Draize ocular irritation study; rinsed Neat material was a
instilled; neat and in aqueous and unrinsed eyes; no further details mild irritant in
suspension; no further details unrinsed eyes (score =
2.4); no irritation in
rinsed eyes or those
treated with aqueous
suspension
20
Silica (hydrophilic); 100 mg 9 rabbits; no further details Ocular irritation study; eyes not rinsed No signs of irritation
instilled in 6 rabbits; eyes rinsed after 30s in 3 in rinsed eyes; mean
rabbits score 0.15; very slight
conjunctival erythema
up to 48 h
20
Silica (hydrophobic); 100 mg 8 rabbits; no further details Ocular irritation study; eyes not rinsed No signs of irritation
instilled in 5 rabbits; eyes rinsed after 5 min in 3
rabbits
20
instilled in 6 rabbits; eyes rinsed after 30 s in 3 in rinsed eyes; 2
rabbits unrinsed eyes had
slight erythema for 24
h after instillation;
mean score = 0.1 at 24,
48, and 72 h
20
Silica (hydrophobic); 3 mg 9 rabbits; no further details Ocular irritation study; eyes not rinsed Transient slight to
instilled in 3 rabbits, eyes rinsed after 2 s in 3 moderate conjunctival
rabbits, or after 4 s in 3rabbits erythema observed and
1 and 4 h post-
treatment that resolved
within 24 h
20
instilled in 6 rabbits; eyes rinsed after 30 s in 3
rabbits
20
Silica (hydrophobic); 10-20 mg 9 rabbits; no further details Ocular irritation study; eyes not rinsed No signs of irritation
instilled in 6 rabbits; eyes rinsed after 30 s in 3 in rinsed eyes; 2
rabbits unrinsed eyes had
slight erythema for 24
h after instillation;
mean score = 0.1 at 24,
48, and 72 h
20
instilled in 3 rabbits, eyes rinsed after 2 s in 3
rabbits, or eyes rinsed after 4 s in 3
rabbits
20
instilled in 6 rabbits; eyes rinsed after 4 s in 3
rabbits
70
Silica; 10 mg instilled; neat and Rabbits; no further details Ocular irritation study; some eyes Faint irritation in
in aqueous solution; no further rinsed after 2 s, 4 s, or not rinsed; no mucous tissues in eyes
details further details treated with neat
material and not
rinsed; no irritation in
eyes that were rinsed
and with aqueous
solution
28
Silica; 0.1 ml of 50% dilution in 8 male New Zealand white Ocular irritation study; eyes rinsed after No irritation
olive oil rabbits 5 min in 3 rabbits or not rinsed in 5
rabbits
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2018 FDA Raw Data

03B - Eyeliner ALUMINUM SILICATE 1
05E - Rinses (non-coloring) ALUMINUM SILICATE 1
05F - Shampoos (non-coloring) ALUMINUM SILICATE 1
05G - Tonics, Dressings, and Other Hair Grooming
Aids ALUMINUM SILICATE 2
06E - Hair Color Sprays (aerosol) ALUMINUM SILICATE 6
07A - Blushers (all types) ALUMINUM SILICATE 1
10A - Bath Soaps and Detergents ALUMINUM SILICATE 2
10E - Other Personal Cleanliness Products ALUMINUM SILICATE 2
12A - Cleansing ALUMINUM SILICATE 9
12C - Face and Neck (exc shave) ALUMINUM SILICATE 22
12D - Body and Hand (exc shave) ALUMINUM SILICATE 1
12F - Moisturizing ALUMINUM SILICATE 9
12H - Paste Masks (mud packs) ALUMINUM SILICATE 7
12I - Skin Fresheners ALUMINUM SILICATE 1
12J - Other Skin Care Preps ALUMINUM SILICATE 3
03B - Eyeliner ATTAPULGITE 1

12H - Paste Masks (mud packs) ATTAPULGITE 3
01B - Baby Lotions, Oils, Powders, and Creams BENTONITE 1

02A - Bath Oils, Tablets, and Salts BENTONITE 1
02D - Other Bath Preparations BENTONITE 1
03A - Eyebrow Pencil BENTONITE 1
03B - Eyeliner BENTONITE 8
03C - Eye Shadow BENTONITE 3
03D - Eye Lotion BENTONITE 2
03F - Mascara BENTONITE 19
03G - Other Eye Makeup Preparations BENTONITE 5
04C - Powders (dusting and talcum, excluding
aftershave talc) BENTONITE 1
05A - Hair Conditioner BENTONITE 2
05B - Hair Spray (aerosol fixatives) BENTONITE 1
Aids BENTONITE 11
05I - Other Hair Preparations BENTONITE 2
07B - Face Powders BENTONITE 2
07C - Foundations BENTONITE 10
07F - Makeup Bases BENTONITE 2
08E - Nail Polish and Enamel BENTONITE 20
08F - Nail Polish and Enamel Removers BENTONITE 1
09A - Dentifrices BENTONITE 3
09C - Other Oral Hygiene Products BENTONITE 4

10A - Bath Soaps and Detergents BENTONITE 6
10B - Deodorants (underarm) BENTONITE 5
10E - Other Personal Cleanliness Products BENTONITE 2
11E - Shaving Cream BENTONITE 1
11F - Shaving Soap BENTONITE 2
11G - Other Shaving Preparation Products BENTONITE 1
12A - Cleansing BENTONITE 23
12C - Face and Neck (exc shave) BENTONITE 23
12D - Body and Hand (exc shave) BENTONITE 4
12F - Moisturizing BENTONITE 20
12G - Night BENTONITE 2
12H - Paste Masks (mud packs) BENTONITE 135
12I - Skin Fresheners BENTONITE 1
12J - Other Skin Care Preps BENTONITE 12
13A - Suntan Gels, Creams, and Liquids BENTONITE 1
13C - Other Suntan Preparations BENTONITE 1
02A - Bath Oils, Tablets, and Salts CALCIUM SILICATE 6

02C - Bath Capsules CALCIUM SILICATE 1
02D - Other Bath Preparations CALCIUM SILICATE 2
03C - Eye Shadow CALCIUM SILICATE 7
aftershave talc) CALCIUM SILICATE 44
07A - Blushers (all types) CALCIUM SILICATE 16
07B - Face Powders CALCIUM SILICATE 17
07C - Foundations CALCIUM SILICATE 3
07F - Makeup Bases CALCIUM SILICATE 1
07I - Other Makeup Preparations CALCIUM SILICATE 1
08G - Other Manicuring Preparations CALCIUM SILICATE 1
12A - Cleansing CALCIUM SILICATE 1
12C - Face and Neck (exc shave) CALCIUM SILICATE 1
03G - Other Eye Makeup Preparations FULLER'S EARTH 1

07E - Lipstick FULLER'S EARTH 1
10A - Bath Soaps and Detergents FULLER'S EARTH 1
12A - Cleansing FULLER'S EARTH 3
12C - Face and Neck (exc shave) FULLER'S EARTH 1
12H - Paste Masks (mud packs) FULLER'S EARTH 8
03A - Eyebrow Pencil HECTORITE 2

03B - Eyeliner HECTORITE 20
03F - Mascara HECTORITE 11

03G - Other Eye Makeup Preparations HECTORITE 1
05A - Hair Conditioner HECTORITE 3
05E - Rinses (non-coloring) HECTORITE 1
05F - Shampoos (non-coloring) HECTORITE 2
Aids HECTORITE 1
05I - Other Hair Preparations HECTORITE 1
06D - Hair Shampoos (coloring) HECTORITE 1
07A - Blushers (all types) HECTORITE 3
07B - Face Powders HECTORITE 3
07C - Foundations HECTORITE 7
07D - Leg and Body Paints HECTORITE 1
07I - Other Makeup Preparations HECTORITE 2
08G - Other Manicuring Preparations HECTORITE 1
12A - Cleansing HECTORITE 8
12C - Face and Neck (exc shave) HECTORITE 3
12D - Body and Hand (exc shave) HECTORITE 1
12G - Night HECTORITE 1
12H - Paste Masks (mud packs) HECTORITE 9
12J - Other Skin Care Preps HECTORITE 1
01B - Baby Lotions, Oils, Powders, and Creams KAOLIN 3

02A - Bath Oils, Tablets, and Salts KAOLIN 9
02D - Other Bath Preparations KAOLIN 2
03A - Eyebrow Pencil KAOLIN 20
03B - Eyeliner KAOLIN 26
03C - Eye Shadow KAOLIN 356
03D - Eye Lotion KAOLIN 6
03E - Eye Makeup Remover KAOLIN 1
03F - Mascara KAOLIN 62
03G - Other Eye Makeup Preparations KAOLIN 28
aftershave talc) KAOLIN 18
05A - Hair Conditioner KAOLIN 5
05F - Shampoos (non-coloring) KAOLIN 8
Aids KAOLIN 21
05I - Other Hair Preparations KAOLIN 6
06A - Hair Dyes and Colors (all types requiring caution
statements and patch tests) KAOLIN 1
06F - Hair Lighteners with Color KAOLIN 4
06G - Hair Bleaches KAOLIN 15
06H - Other Hair Coloring Preparation KAOLIN 5

07A - Blushers (all types) KAOLIN 66
07B - Face Powders KAOLIN 106
07C - Foundations KAOLIN 62
07D - Leg and Body Paints KAOLIN 10
07E - Lipstick KAOLIN 88
07F - Makeup Bases KAOLIN 9
07G - Rouges KAOLIN 8
07H - Makeup Fixatives KAOLIN 6
07I - Other Makeup Preparations KAOLIN 40
08A - Basecoats and Undercoats KAOLIN 1
08E - Nail Polish and Enamel KAOLIN 6
08G - Other Manicuring Preparations KAOLIN 3
09A - Dentifrices KAOLIN 1
09B - Mouthwashes and Breath Fresheners KAOLIN 1
10A - Bath Soaps and Detergents KAOLIN 22
10B - Deodorants (underarm) KAOLIN 5
10E - Other Personal Cleanliness Products KAOLIN 16
11C - Mens Talcum KAOLIN 1
11E - Shaving Cream KAOLIN 1
11F - Shaving Soap KAOLIN 2
11G - Other Shaving Preparation Products KAOLIN 2
12A - Cleansing KAOLIN 83
12C - Face and Neck (exc shave) KAOLIN 67
12D - Body and Hand (exc shave) KAOLIN 16
12F - Moisturizing KAOLIN 34
12G - Night KAOLIN 6
12H - Paste Masks (mud packs) KAOLIN 432
12I - Skin Fresheners KAOLIN 4
12J - Other Skin Care Preps KAOLIN 50
13A - Suntan Gels, Creams, and Liquids KAOLIN 1
13B - Indoor Tanning Preparations KAOLIN 1
02A - Bath Oils, Tablets, and Salts KAOLINITE 1

02C - Bath Capsules KAOLINITE 2
03C - Eye Shadow KAOLINITE 16
05F - Shampoos (non-coloring) KAOLINITE 1
07C - Foundations KAOLINITE 17
10A - Bath Soaps and Detergents KAOLINITE 5
12C - Face and Neck (exc shave) KAOLINITE 1
12F - Moisturizing KAOLINITE 1
12H - Paste Masks (mud packs) KAOLINITE 4
LITHIUM MAGNESIUM
07E - Lipstick SILICATE 2
LITHIUM MAGNESIUM
03F - Mascara SODIUM SILICATE 3
LITHIUM MAGNESIUM
03G - Other Eye Makeup Preparations SODIUM SILICATE 2
05G - Tonics, Dressings, and Other Hair Grooming LITHIUM MAGNESIUM
Aids SODIUM SILICATE 3
LITHIUM MAGNESIUM
05I - Other Hair Preparations SODIUM SILICATE 9
LITHIUM MAGNESIUM
07C - Foundations SODIUM SILICATE 3
LITHIUM MAGNESIUM
07D - Leg and Body Paints SODIUM SILICATE 1
LITHIUM MAGNESIUM
07I - Other Makeup Preparations SODIUM SILICATE 1
LITHIUM MAGNESIUM
08E - Nail Polish and Enamel SODIUM SILICATE 10
LITHIUM MAGNESIUM
12A - Cleansing SODIUM SILICATE 1
LITHIUM MAGNESIUM
12B - Depilatories SODIUM SILICATE 17
LITHIUM MAGNESIUM
12C - Face and Neck (exc shave) SODIUM SILICATE 2
LITHIUM MAGNESIUM
12F - Moisturizing SODIUM SILICATE 1
LITHIUM MAGNESIUM
12H - Paste Masks (mud packs) SODIUM SILICATE 3
MAGNESIUM ALUMINUM
01B - Baby Lotions, Oils, Powders, and Creams SILICATE 8
MAGNESIUM ALUMINUM
03A - Eyebrow Pencil SILICATE 20
MAGNESIUM ALUMINUM
03B - Eyeliner SILICATE 49
MAGNESIUM ALUMINUM
03C - Eye Shadow SILICATE 83
MAGNESIUM ALUMINUM
03D - Eye Lotion SILICATE 12
MAGNESIUM ALUMINUM
03F - Mascara SILICATE 28
MAGNESIUM ALUMINUM
03G - Other Eye Makeup Preparations SILICATE 15
04C - Powders (dusting and talcum, excluding MAGNESIUM ALUMINUM
aftershave talc) SILICATE 3
MAGNESIUM ALUMINUM
05A - Hair Conditioner SILICATE 2
MAGNESIUM ALUMINUM
05B - Hair Spray (aerosol fixatives) SILICATE 1
05F - Shampoos (non-coloring) MAGNESIUM ALUMINUM 3
SILICATE
05G - Tonics, Dressings, and Other Hair Grooming MAGNESIUM ALUMINUM
Aids SILICATE 8
MAGNESIUM ALUMINUM
05I - Other Hair Preparations SILICATE 1
MAGNESIUM ALUMINUM
06B - Hair Tints SILICATE 1
MAGNESIUM ALUMINUM
06H - Other Hair Coloring Preparation SILICATE 5
MAGNESIUM ALUMINUM
07A - Blushers (all types) SILICATE 34
MAGNESIUM ALUMINUM
07B - Face Powders SILICATE 27
MAGNESIUM ALUMINUM
07C - Foundations SILICATE 64
MAGNESIUM ALUMINUM
07D - Leg and Body Paints SILICATE 3
MAGNESIUM ALUMINUM
MAGNESIUM ALUMINUM
07F - Makeup Bases SILICATE 11
MAGNESIUM ALUMINUM
07G - Rouges SILICATE 1
MAGNESIUM ALUMINUM
07H - Makeup Fixatives SILICATE 1
MAGNESIUM ALUMINUM
07I - Other Makeup Preparations SILICATE 23
MAGNESIUM ALUMINUM
08E - Nail Polish and Enamel SILICATE 1
MAGNESIUM ALUMINUM
09A - Dentifrices SILICATE 2
MAGNESIUM ALUMINUM
10A - Bath Soaps and Detergents SILICATE 3
MAGNESIUM ALUMINUM
10B - Deodorants (underarm) SILICATE 8
MAGNESIUM ALUMINUM
10E - Other Personal Cleanliness Products SILICATE 26
MAGNESIUM ALUMINUM
11A - Aftershave Lotion SILICATE 6
MAGNESIUM ALUMINUM
11E - Shaving Cream SILICATE 1
MAGNESIUM ALUMINUM
11G - Other Shaving Preparation Products SILICATE 1
MAGNESIUM ALUMINUM
12A - Cleansing SILICATE 73
MAGNESIUM ALUMINUM
12C - Face and Neck (exc shave) SILICATE 67
MAGNESIUM ALUMINUM
12D - Body and Hand (exc shave) SILICATE 80
MAGNESIUM ALUMINUM
12E - Foot Powders and Sprays SILICATE 1
MAGNESIUM ALUMINUM
12F - Moisturizing SILICATE 100
12G - Night MAGNESIUM ALUMINUM 16
SILICATE
MAGNESIUM ALUMINUM
12H - Paste Masks (mud packs) SILICATE 66
MAGNESIUM ALUMINUM
12I - Skin Fresheners SILICATE 2
MAGNESIUM ALUMINUM
12J - Other Skin Care Preps SILICATE 40
MAGNESIUM ALUMINUM
13A - Suntan Gels, Creams, and Liquids SILICATE 3
MAGNESIUM ALUMINUM
13B - Indoor Tanning Preparations SILICATE 15
03B - Eyeliner MAGNESIUM SILICATE 8

03C - Eye Shadow MAGNESIUM SILICATE 14
03G - Other Eye Makeup Preparations MAGNESIUM SILICATE 2
07A - Blushers (all types) MAGNESIUM SILICATE 1
07B - Face Powders MAGNESIUM SILICATE 5
07C - Foundations MAGNESIUM SILICATE 2
07E - Lipstick MAGNESIUM SILICATE 14
07I - Other Makeup Preparations MAGNESIUM SILICATE 16
08E - Nail Polish and Enamel MAGNESIUM SILICATE 1
12C - Face and Neck (exc shave) MAGNESIUM SILICATE 2
12D - Body and Hand (exc shave) MAGNESIUM SILICATE 1
12F - Moisturizing MAGNESIUM SILICATE 2
12H - Paste Masks (mud packs) MAGNESIUM SILICATE 2
06G - Hair Bleaches MAGNESIUM TRISILICATE 1

12B - Depilatories MAGNESIUM TRISILICATE 16
01B - Baby Lotions, Oils, Powders, and Creams MONTMORILLONITE 1

02A - Bath Oils, Tablets, and Salts MONTMORILLONITE 1
03A - Eyebrow Pencil MONTMORILLONITE 2
03B - Eyeliner MONTMORILLONITE 3
03C - Eye Shadow MONTMORILLONITE 18
03E - Eye Makeup Remover MONTMORILLONITE 3
03F - Mascara MONTMORILLONITE 10
03G - Other Eye Makeup Preparations MONTMORILLONITE 3
aftershave talc) MONTMORILLONITE 1
05F - Shampoos (non-coloring) MONTMORILLONITE 6
Aids MONTMORILLONITE 1
05I - Other Hair Preparations MONTMORILLONITE 2
07A - Blushers (all types) MONTMORILLONITE 6
07B - Face Powders MONTMORILLONITE 4
07C - Foundations MONTMORILLONITE 11

07E - Lipstick MONTMORILLONITE 11
07F - Makeup Bases MONTMORILLONITE 4
07I - Other Makeup Preparations MONTMORILLONITE 1
09A - Dentifrices MONTMORILLONITE 1
09C - Other Oral Hygiene Products MONTMORILLONITE 1
10A - Bath Soaps and Detergents MONTMORILLONITE 8
10E - Other Personal Cleanliness Products MONTMORILLONITE 1
12A - Cleansing MONTMORILLONITE 20
12C - Face and Neck (exc shave) MONTMORILLONITE 4
12D - Body and Hand (exc shave) MONTMORILLONITE 2
12E - Foot Powders and Sprays MONTMORILLONITE 1
12F - Moisturizing MONTMORILLONITE 11
12H - Paste Masks (mud packs) MONTMORILLONITE 35
12J - Other Skin Care Preps MONTMORILLONITE 5
SODIUM MAGNESIUM
02C - Bath Capsules SILICATE 1
SODIUM MAGNESIUM
03A - Eyebrow Pencil SILICATE 1
SODIUM MAGNESIUM
03B - Eyeliner SILICATE 2
SODIUM MAGNESIUM
SODIUM MAGNESIUM
03F - Mascara SILICATE 1
SODIUM MAGNESIUM
03G - Other Eye Makeup Preparations SILICATE 2
SODIUM MAGNESIUM
05A - Hair Conditioner SILICATE 1
05G - Tonics, Dressings, and Other Hair Grooming SODIUM MAGNESIUM
Aids SILICATE 1
SODIUM MAGNESIUM
SODIUM MAGNESIUM
SODIUM MAGNESIUM
07C - Foundations SILICATE 1
SODIUM MAGNESIUM
07D - Leg and Body Paints SILICATE 1
SODIUM MAGNESIUM
SODIUM MAGNESIUM
07G - Rouges SILICATE 2
SODIUM MAGNESIUM
07H - Makeup Fixatives SILICATE 1
SODIUM MAGNESIUM
SODIUM MAGNESIUM
09A - Dentifrices SILICATE 1
SODIUM MAGNESIUM
09C - Other Oral Hygiene Products SILICATE 1
SODIUM MAGNESIUM
10A - Bath Soaps and Detergents SILICATE 1
SODIUM MAGNESIUM
10E - Other Personal Cleanliness Products SILICATE 2
SODIUM MAGNESIUM
12A - Cleansing SILICATE 5
SODIUM MAGNESIUM
12B - Depilatories SILICATE 8
SODIUM MAGNESIUM
12C - Face and Neck (exc shave) SILICATE 5
SODIUM MAGNESIUM
SODIUM MAGNESIUM
12H - Paste Masks (mud packs) SILICATE 35
SODIUM MAGNESIUM
12J - Other Skin Care Preps SILICATE 1
03A - Eyebrow Pencil ZEOLITE 2

03B - Eyeliner ZEOLITE 3
03C - Eye Shadow ZEOLITE 20
05B - Hair Spray (aerosol fixatives) ZEOLITE 3
05E - Rinses (non-coloring) ZEOLITE 1
05F - Shampoos (non-coloring) ZEOLITE 3
05I - Other Hair Preparations ZEOLITE 1
07A - Blushers (all types) ZEOLITE 32
07B - Face Powders ZEOLITE 45
07C - Foundations ZEOLITE 1
07E - Lipstick ZEOLITE 3
07I - Other Makeup Preparations ZEOLITE 4
10A - Bath Soaps and Detergents ZEOLITE 2
12A - Cleansing ZEOLITE 7
12C - Face and Neck (exc shave) ZEOLITE 9
12D - Body and Hand (exc shave) ZEOLITE 2
12F - Moisturizing ZEOLITE 14
12H - Paste Masks (mud packs) ZEOLITE 4
12I - Skin Fresheners ZEOLITE 1
12H - Paste Masks (mud packs) POTASSIUM SILICATE 1

Aids SODIUM METASILICATE 1
statements and patch tests) SODIUM METASILICATE 88
06F - Hair Lighteners with Color SODIUM METASILICATE 6
06G - Hair Bleaches SODIUM METASILICATE 41
06H - Other Hair Coloring Preparation SODIUM METASILICATE 1
03G - Other Eye Makeup Preparations SODIUM SILICATE 4

Aids SODIUM SILICATE 1
statements and patch tests) SODIUM SILICATE 12
06F - Hair Lighteners with Color SODIUM SILICATE 7
06G - Hair Bleaches SODIUM SILICATE 33
06H - Other Hair Coloring Preparation SODIUM SILICATE 2
09A - Dentifrices SODIUM SILICATE 1
10A - Bath Soaps and Detergents SODIUM SILICATE 5
10E - Other Personal Cleanliness Products SODIUM SILICATE 2
11E - Shaving Cream SODIUM SILICATE 1
12B - Depilatories SODIUM SILICATE 13
12C - Face and Neck (exc shave) SODIUM SILICATE 6
12J - Other Skin Care Preps SODIUM SILICATE 4
AMMONIUM SILVER ZINC

03C - Eye Shadow ALUMINUM SILICATE 13
07A - Blushers (all types) ALUMINUM SILICATE 2
07B - Face Powders ALUMINUM SILICATE 1
05F - Shampoos (non-coloring) ZINC ZEOLITE 1
ALUMINUM CALCIUM SODIUM

04C - Powders (dusting and talcum, excluding ALUMINUM CALCIUM SODIUM

aftershave talc) SILICATE 2

05I - Other Hair Preparations SILICATE 1





08E - Nail Polish and Enamel SILICATE 31

08G - Other Manicuring Preparations SILICATE 1

12D - Body and Hand (exc shave) SILICATE 3

ALUMINA MAGNESIUM
07G - Rouges METASILICATE 1
ALUMINA MAGNESIUM
12C - Face and Neck (exc shave) METASILICATE 1
ALUMINA MAGNESIUM
12H - Paste Masks (mud packs) METASILICATE 1
02A - Bath Oils, Tablets, and Salts HYDRATED SILICA 7
02D - Other Bath Preparations HYDRATED SILICA 1
03C - Eye Shadow HYDRATED SILICA 7
03F - Mascara HYDRATED SILICA 4
03G - Other Eye Makeup Preparations HYDRATED SILICA 1

aftershave talc) HYDRATED SILICA 3
05A - Hair Conditioner HYDRATED SILICA 1
05F - Shampoos (non-coloring) HYDRATED SILICA 2

Aids HYDRATED SILICA 1
06F - Hair Lighteners with Color HYDRATED SILICA 1
06G - Hair Bleaches HYDRATED SILICA 8

07A - Blushers (all types) HYDRATED SILICA 2
07B - Face Powders HYDRATED SILICA 28
07C - Foundations HYDRATED SILICA 36
07E - Lipstick HYDRATED SILICA 42
07F - Makeup Bases HYDRATED SILICA 4
07G - Rouges HYDRATED SILICA 1
07I - Other Makeup Preparations HYDRATED SILICA 6
08A - Basecoats and Undercoats HYDRATED SILICA 2
08E - Nail Polish and Enamel HYDRATED SILICA 12
08G - Other Manicuring Preparations HYDRATED SILICA 1
09A - Dentifrices HYDRATED SILICA 36
09C - Other Oral Hygiene Products HYDRATED SILICA 4
10A - Bath Soaps and Detergents HYDRATED SILICA 34
10B - Deodorants (underarm) HYDRATED SILICA 1
10E - Other Personal Cleanliness Products HYDRATED SILICA 113
12A - Cleansing HYDRATED SILICA 15
12B - Depilatories HYDRATED SILICA 14
12C - Face and Neck (exc shave) HYDRATED SILICA 5
12D - Body and Hand (exc shave) HYDRATED SILICA 4
12E - Foot Powders and Sprays HYDRATED SILICA 1
12F - Moisturizing HYDRATED SILICA 4
12G - Night HYDRATED SILICA 2
12H - Paste Masks (mud packs) HYDRATED SILICA 3
12I - Skin Fresheners HYDRATED SILICA 3
12J - Other Skin Care Preps HYDRATED SILICA 22
13A - Suntan Gels, Creams, and Liquids HYDRATED SILICA 3

01B - Baby Lotions, Oils, Powders, and Creams SILICA 3
01C - Other Baby Products SILICA 1
02A - Bath Oils, Tablets, and Salts SILICA 44
02C - Bath Capsules SILICA 1
02D - Other Bath Preparations SILICA 5
03A - Eyebrow Pencil SILICA 46
03B - Eyeliner SILICA 217
03C - Eye Shadow SILICA 1568
03D - Eye Lotion SILICA 77
03E - Eye Makeup Remover SILICA 6
03F - Mascara SILICA 296
03G - Other Eye Makeup Preparations SILICA 189
04A - Cologne and Toilet waters SILICA 23
04B - Perfumes SILICA 10

aftershave talc) SILICA 65
04E - Other Fragrance Preparation SILICA 64
05A - Hair Conditioner SILICA 9
05B - Hair Spray (aerosol fixatives) SILICA 3
05C - Hair Straighteners SILICA 3
05F - Shampoos (non-coloring) SILICA 47

Aids SILICA 31
05I - Other Hair Preparations SILICA 16

statements and patch tests) SILICA 81
06B - Hair Tints SILICA 12
06C - Hair Rinses (coloring) SILICA 1

06E - Hair Color Sprays (aerosol) SILICA 31
06F - Hair Lighteners with Color SILICA 8
06G - Hair Bleaches SILICA 25
06H - Other Hair Coloring Preparation SILICA 29
07A - Blushers (all types) SILICA 295
07B - Face Powders SILICA 437
07C - Foundations SILICA 436
07D - Leg and Body Paints SILICA 4
07E - Lipstick SILICA 1527
07F - Makeup Bases SILICA 84
07G - Rouges SILICA 58
07H - Makeup Fixatives SILICA 9
07I - Other Makeup Preparations SILICA 336
08A - Basecoats and Undercoats SILICA 7
08B - Cuticle Softeners SILICA 2
08C - Nail Creams and Lotions SILICA 5
08D - Nail Extenders SILICA 3
08E - Nail Polish and Enamel SILICA 480
08F - Nail Polish and Enamel Removers SILICA 1
08G - Other Manicuring Preparations SILICA 27
09A - Dentifrices SILICA 28
09C - Other Oral Hygiene Products SILICA 4
10A - Bath Soaps and Detergents SILICA 84
10B - Deodorants (underarm) SILICA 31
10E - Other Personal Cleanliness Products SILICA 75
11A - Aftershave Lotion SILICA 21
11E - Shaving Cream SILICA 11

11G - Other Shaving Preparation Products SILICA 5
12A - Cleansing SILICA 78
12B - Depilatories SILICA 4
12C - Face and Neck (exc shave) SILICA 278
12D - Body and Hand (exc shave) SILICA 99
12E - Foot Powders and Sprays SILICA 3
12F - Moisturizing SILICA 341
12G - Night SILICA 54
12H - Paste Masks (mud packs) SILICA 41
12I - Skin Fresheners SILICA 8
12J - Other Skin Care Preps SILICA 130
13A - Suntan Gels, Creams, and Liquids SILICA 8
13B - Indoor Tanning Preparations SILICA 26
13C - Other Suntan Preparations SILICA 4
SODIUM POTASSIUM
07C - Foundations ALUMINUM SILICATE 1
SODIUM POTASSIUM
07G - Rouges ALUMINUM SILICATE 3
SODIUM POTASSIUM
07I - Other Makeup Preparations ALUMINUM SILICATE 1
SODIUM POTASSIUM
10E - Other Personal Cleanliness Products ALUMINUM SILICATE 1
SODIUM POTASSIUM
12F - Moisturizing ALUMINUM SILICATE 5
SODIUM POTASSIUM
03C - Eye Shadow SILICA, AMORPHOUS 1

03F - Mascara SILICA, AMORPHOUS 1
07C - Foundations SILICA, AMORPHOUS 1
09A - Dentifrices SILICA, AMORPHOUS 1
12C - Face and Neck (exc shave) SILICA, AMORPHOUS 1
05I - Other Hair Preparations SILICA, FUMED 2
08E - Nail Polish and Enamel SILICA, FUMED 11
12D - Body and Hand (exc shave) SILICA, FUMED 1
01C - Other Baby Products SILICON DIOXIDE, COLLOIDAL 3
03C - Eye Shadow SILICON DIOXIDE, COLLOIDAL 2
07B - Face Powders SILICON DIOXIDE, COLLOIDAL 5
07C - Foundations SILICON DIOXIDE, COLLOIDAL 1
07E - Lipstick SILICON DIOXIDE, COLLOIDAL 18
07H - Makeup Fixatives SILICON DIOXIDE, COLLOIDAL 1
07I - Other Makeup Preparations SILICON DIOXIDE, COLLOIDAL 1
08D - Nail Extenders SILICON DIOXIDE, COLLOIDAL 1
08E - Nail Polish and Enamel SILICON DIOXIDE, COLLOIDAL 12
09A - Dentifrices SILICON DIOXIDE, COLLOIDAL 5
12F - Moisturizing SILICON DIOXIDE, COLLOIDAL 1
08G - Other Manicuring Preparations SILICIC ACID 1
09A - Dentifrices SILICIC ACID 1
10A - Bath Soaps and Detergents SILICIC ACID 11
12B - Depilatories SILICIC ACID 1
12J - Other Skin Care Preps SILICIC ACID 1

Memorandum
TO: Bart Heldreth, Ph.D.

Executive Director - Cosmetic Ingredient Review
FROM: Carol Eisenmann, Ph.D.

Personal Care Products Council
DATE: June 11, 2018
SUBJECT: Updated Concentration of Use by FDA Product Category: Silicates

Concentration of use by FDA Product Category – Silicates*
Attapulgite Tromethamine Magnesium Aluminum Silicate

Bentonite Activated Clay
Calcium Silicate Ammonium Silver Zinc Aluminum Silicate
Fuller's Earth Aluminum Calcium Magnesium Potassium
Hectorite Sodium Zinc Silicates
Kaolin Aluminum Iron Calcium Magnesium Germanium
Lithium Magnesium Silicate Silicates
Lithium Magnesium Sodium Silicate Aluminum Iron Calcium Magnesium Zirconium
Magnesium Aluminum Silicate Silicates
Magnesium Silicate Sodium Silicate
Magnesium Trisilicate Sodium Metasilicate
Montmorillonite Potassium Silicate
Pyrophyllite Sodium Magnesium Aluminum Silicate
Sodium Magnesium Silicate Zinc Silicate
Zeolite Ammonium Silver Zeolite
Zirconium Silicate Gold Zeolite
Sodium Silver Aluminum Silicate Zinc Zeolite
Ingredient Product Category Maximum
Concentration of Use
Bentonite Bath oils, tablets and salts 0.14%
Bentonite Eyebrow pencils 0.25%
Bentonite Eyeliners 0.25%
Bentonite Eye lotions 1.5%
Bentonite Mascaras 2%
Bentonite Other eye makeup preparations 0.00025%
Bentonite Hair sprays
Pump spray 0.1%
Bentonite Other hair coloring preparations 17.3%
Bentonite Face powders 2-2.6%
Bentonite Makeup bases 0.5%
Bentonite Nail polish and enamel 0.00008-0.88%
Bentonite Bath soaps and detergents 0.35%
Bentonite Skin cleansing (cold creams, cleansing 0.00002-8.4%
lotions, liquids and pads)
Bentonite Face and neck products
Not spray 0.35-13.7%
Bentonite Body and hand products
Not spray 0.35-14.3%
Bentonite Paste masks and mud packs 4-29.7%
Bentonite Other skin care preparations
Rinse-off 7-15%
Calcium Silicate Bath oils, tablets and salts 0.86-1.3%
Calcium Silicate Eye shadows 1%

Calcium Silicate Powders (dusting and talcum) 3%
Calcium Silicate Shampoos (noncoloring) 1.5%
Calcium Silicate Hair color sprays 0.005%
Calcium Silicate Blushers 3-5%
Calcium Silicate Face powders 0.25-5%
Calcium Silicate Foundations 1.3%
Calcium Silicate Lipstick 0.00013%
Calcium Silicate Skin cleansing (cold creams, cleansing 20%
Calcium Silicate Face and neck products
Not spray 4.7-5%
Calcium Silicate Suntan products
Not spray 0.5%
Hectorite Eyebrow pencils 0.3%
Hectorite Eyeliners 0.1-0.4%
Hectorite Eye shadows 0.27%
Hectorite Mascaras 0.5-0.8%
Hectorite Blushers 3.2%
Hectorite Nail polish and enamel 0.7%
Hectorite Skin cleansing (cold cream, cleansing 0.5%
Hectorite Face and neck products
Not spray 0.8%
Hectorite Body and hand products
Not spray 1.1%
Hectorite Paste masks and mud packs 0.5%
Kaolin Eyebrow pencils 0.78-27.2%
Kaolin Eyeliners 2-16%
Kaolin Eye shadows 2-15%
Kaolin Eye lotions 1-3%
Kaolin Mascaras 7-21.5%
Kaolin Other eye makeup preparations 0.75%
Kaolin Hair conditioners 2.5-5%
Kaolin Shampoos (noncoloring) 0.058%
Aerosol 0.0096%
Kaolin Tonics, dressings and other hair grooming 0.15-25%
aids
Kaolin Other hair preparations (noncoloring) 4.6%
Kaolin Hair lighteners with color 31%
Kaolin Hair bleaches 0.5%
Kaolin Other hair coloring preparations 0.4%
Kaolin Blushers 1.5-5%
Kaolin Face powders 2-23.1%
Kaolin Foundations 0.8-17.4%
Kaolin Lipstick 0.97-11.9%
Kaolin Makeup bases 4%

Kaolin Makeup fixatives 13.3%
Kaolin Other makeup preparations 1%
Kaolin Basecoats and undercoats (manicuring 0.0001%
preparations)
Kaolin Nail polish and enamel 0.17%
Kaolin Other manicuring preparations 35.7-53%
Kaolin Bath soaps and detergents 0.05%
Kaolin Shaving soap 1.5%
Kaolin Skin cleansing (cold creams, cleansing 0.0005-20.2%
Kaolin Depilatories 0.25%
Kaolin Face and neck products
Not spray 1-25%
Kaolin Body and hand products
Not spray 3.5-23%
Kaolin Foot powders and sprays 4%
Kaolin Paste masks and mud packs 2-33%
Kaolin Other skin care preparations
Rinse-off 35%
Lithium Magnesium Silicate Tonics, dressings and other hair grooming 0.3%
aids
Lithium Magnesium Silicate Face and neck products
Not spray 5%
Spray 0.4%
Lithium Magnesium Sodium Silicate Eyeliners 3%
Lithium Magnesium Sodium Silicate Eye shadows 4%
Lithium Magnesium Sodium Silicate Mascaras 1.4%
Lithium Magnesium Sodium Silicate Other eye makeup preparations 0.0005%
Lithium Magnesium Sodium Silicate Tonics, dressings and other hair grooming 6%
aids
Lithium Magnesium Sodium Silicate Deodorants
Not spray 0.5%
Lithium Magnesium Sodium Silicate Skin cleansing (cold creams, cleansing 0.4%
Lithium Magnesium Sodium Silicate Body and hand products
Not spray 3%
Magnesium Aluminum Silicate Eyebrow pencils 1.7-2%
Magnesium Aluminum Silicate Eyeliners 0.25-0.4%
Magnesium Aluminum Silicate Eye shadows 0.25-4.5%
Magnesium Aluminum Silicate Eye lotions 0.5-1%
Magnesium Aluminum Silicate Mascaras 0.15-0.5%
Magnesium Aluminum Silicate Other eye makeup preparations 0.0025-4%
Magnesium Aluminum Silicate Shampoos (noncoloring) 0.19%
Magnesium Aluminum Silicate Tonics, dressings and other hair grooming 0.5-0.8%
aids
Magnesium Aluminum Silicate Blushers 0.96-2%

Magnesium Aluminum Silicate Face powders 1%
Magnesium Aluminum Silicate Foundations 0.15-2.8%
Magnesium Aluminum Silicate Makeup bases 2.5%
Magnesium Aluminum Silicate Makeup fixatives 0.75%
Magnesium Aluminum Silicate Other makeup preparations 0.0008%
Magnesium Aluminum Silicate Dentifrices 0.93%
Magnesium Aluminum Silicate Deodorants
Not spray 0.5-0.7%
Magnesium Aluminum Silicate Aftershave lotions 0.5%
Magnesium Aluminum Silicate Skin cleansing (cold creams, cleansing 0.0004-10%
Magnesium Aluminum Silicate Face and neck products
Not spray 0.4-11%
Magnesium Aluminum Silicate Body and hand products
Not spray 0.3-1.6%
Magnesium Aluminum Silicate Moisturizing products
Not spray 0.9-1.5%
Magnesium Aluminum Silicate Night products
Not spray 0.6%
Magnesium Aluminum Silicate Paste masks and mud packs 0.0008-6%
Magnesium Aluminum Silicate Other skin care preparations
Leave-on 1.1%
Rinse-off 4.5%
Magnesium Aluminum Silicate Suntan products
Not spray 0.3-0.6%
Magnesium Silicate Eyebrow pencils 12-14.1%
Magnesium Silicate Eyeliners 4.5-20%
Magnesium Silicate Eye shadows 3-21.6%
Magnesium Silicate Foundations 0.001-4.5%
Magnesium Silicate Lipstick 10%
Magnesium Silicate Makeup fixatives 2.3%
Magnesium Silicate Other makeup preparations 19%
Magnesium Silicate Body and hand products
Not spray 1%
Montmorillonite Eyeliners 2.8%
Montmorillonite Eye shadows 0.3%
Montmorillonite Shampoos (noncoloring) 8.2%
Montmorillonite Blushers (all types) 1%
Montmorillonite Foundations 0.31%
Montmorillonite Lipstick 1.7%
Montmorillonite Bath soaps and detergents 0.5%
Montmorillonite Skin cleansing (cold creams, cleansing 0.6-2.5%
Montmorillonite Face and neck products
Not spray 2.5%
Montmorillonite Body and hand products

Not spray 6%
Montmorillonite Paste masks and mud packs 5%
Montmorillonite Other skin care preparations 0.05%
Sodium Magnesium Silicate Paste masks and mud packs 0.2%
Sodium Magnesium Silicate Other skin care preparations 0.13%
Zeolite Eyebrow pencils 3.6%
Zeolite Eyeliners 0.6%
Zeolite Eye shadows 0.6-1.1%
Zeolite Eye lotions 0.032%
Zeolite Hair sprays
Aerosol 1%
Zeolite Tonics, dressings and other hair grooming 35.7%
aids
Zeolite Hair bleaches 5%
Zeolite Blushers 0.6%
Zeolite Face powders 0.6-1.1%
Zeolite Foundations 0.25%
Zeolite Lipstick 3%
Zeolite Skin cleansing (cold creams, cleansing 0.0043%
Zeolite Face and neck products
Not spray 0.5-1%
Zeolite Paste masks and mud packs 28-37.8%
Zeolite Other skin care preparations 0.03-0.5%
Zeolite Suntan products
Not spray 0.25%
Ammonium Silver Zinc Aluminum Other skin care preparations
Silicate Rinse-off 0.001%
Sodium Silicate Hair dyes and colors 17.2%
Sodium Silicate Hair lighteners with color 15%
Sodium Silicate Hair bleaches 35%
Sodium Silicate Dentifrices 0.44%
Sodium Silicate Bath soaps and detergents 1.4%
Sodium Silicate Shaving cream 0.017-1.5%
Sodium Silicate Depilatories 1.2%
Sodium Metasilicate Bath oils, tablets and salts 0.1%
Sodium Metasilicate Hair dyes and colors 5%
Sodium Metasilicate Hair tints 15%
Sodium Metasilicate Hair bleaches 5-13%
Sodium Metasilicate Depilatories 1.2%
Sodium Metasilicate Other skin care preparations
Leave-on 0.001%
*Ingredients included in the title of the table but not found in the title of the table were included in the
concentration of use survey, but no uses were reported.
Information collected in 2018

Table prepared May 21, 2018
Updated June 11, 2018: Bentonite: skin cleansing high concentration changed from 3% to 8.4%; Calcium
Silicate: added skin cleansing and suntan products; Kaolin: added makeup bases; Magnesium Aluminum
Silicate: moisturizing products added 1.5% as the high concentration; Montmorillonite: skin cleansing
added 0.6% as the low concentration
Memorandum
TO: Bart Heldreth, Ph.D.

Executive Director - Cosmetic Ingredient Review
FROM: Carol Eisenmann, Ph.D.

Personal Care Products Council
DATE: October 26, 2018
SUBJECT: Council Concentration of Use Survey: Silica Ingredients

Concentration of Use by FDA Product Category – Silica Ingredients*
Aluminum Silicate Sodium Potassium Aluminum Silicate

Aluminum Calcium Sodium Silicate Calcium Magnesium Silicate
Aluminum Iron Silicates Silver Copper Zeolite
Hydrated Silica Silver Zinc Zeolite
Magnesium Aluminometasilicate Titanium Zeolite
Silica
Ingredient Product Category Maximum
Concentration of Use
Aluminum Silicate Bath soaps and detergents 4.6%
Aluminum Silicate Skin cleansing (cold creams, cleansing 2.8%
Aluminum Calcium Sodium Silicate Eyeliners 0.006-3%
Aluminum Calcium Sodium Silicate Eye shadows 26.3%
Aluminum Calcium Sodium Silicate Blushers 19.4%
Aluminum Calcium Sodium Silicate Foundations 9.3%
Aluminum Calcium Sodium Silicate Lipstick 3.5-5.5%
Aluminum Calcium Sodium Silicate Nail polish and enamel 0.0001-0.25%
Aluminum Calcium Sodium Silicate Other skin care products
Rinse-off 1.8%
Hydrated Silica Baby shampoos 0.005%
Hydrated Silica Other baby products 0.0041%
Hydrated Silica Bath oils, tablets and salts 0.3%
Hydrated Silica Other bath preparations 12%
Hydrated Silica Eyeliners 5.8%
Hydrated Silica Eye shadows 0.066-2.1%
Hydrated Silica Eye lotions 0.066%
Hydrated Silica Mascaras 0.001-0.28%
Hydrated Silica Other eye makeup preparations 1.8%
Hydrated Silica Hair conditioners 0.00001-0.02%
Hydrated Silica Hair sprays
Aerosol 0.45-0.9%
Hydrated Silica Shampoos (noncoloring) 0.00001%
Hydrated Silica Tonics, dressings and other hair grooming 8.9%
aids
Hydrated Silica Other hair preparations (noncoloring) 1%
Hydrated Silica Hair lighteners with color 1.9%
Hydrated Silica Hair bleaches 3%
Hydrated Silica Other hair coloring preparations 8.9%
Hydrated Silica Blushers 0.033-0.5%
Hydrated Silica Face powders 1%
Hydrated Silica Foundations 1.1-2.5%
Hydrated Silica Lipstick 0.17-3%
Hydrated Silica Makeup bases 0.2%
Hydrated Silica Basecoats and undercoats (manicuring 3%
preparations)
Hydrated Silica Nail polish and enamel 0.75-3%
Hydrated Silica Other manicuring preparations 5.5%
Hydrated Silica Dentifrices 10-33.8%
Hydrated Silica Mouth washes and breath fresheners 23.7%
Hydrated Silica Bath soaps and detergents 0.0051-2.5%
Hydrated Silica Deodorants
Not spray 0.066%
Hydrated Silica Aftershave lotions 0.0008%
Hydrated Silica Shaving cream 0.001%
Hydrated Silica Skin cleansing (cold creams, cleansing 0.006-16%
Hydrated Silica Face and neck products
Not sprays 0.0012-0.006%
Hydrated Silica Body and hand products
Not spray 0.54-10%
Hydrated Silica Moisturizing products
Not spray 1.4-5%
Hydrated Silica Other skin care preparations 0.11%
Hydrated Silica Suntan products
Not spray 0.0002-3%
Silica Baby shampoos 3%
Silica Other baby products
Rinse-off 0.0006%
Silica Bath oils tablets and salts 0.1-1%
Silica Other bath preparations 0.1-4%
Silica Eyebrow pencils 7.6-10%
Silica Eyeliners 2-20%
Silica Eye shadows 1.5-29.3%
Silica Eye lotions 0.077-1.1%
Silica Eye makeup removers 0.00068-0.003%
Silica Mascaras 0.0066-50%
Silica Other eye makeup preparations 0.075-10%
Silica Powders (dusting and talcum) 0.016-0.8%
Silica Other fragrance preparations 0.015%
Silica Hair conditioners 0.000005-0.1%
Silica Hair sprays
Aerosol 0.15-2%
Pump spray 0.012-1.5%
Silica Shampoos (noncoloring) 0.000095-2.6%
Silica Tonics, dressings and other hair grooming 0.0042-4%
aids
Silica Other hair preparations (noncoloring) 1-1.2%
Silica Hair dyes and colors 0.0005-4.2%
Silica Hair tints 6%
Silica Hair shampoos (coloring) 0.00082%
Silica Hair color sprays 0.55-0.6%

Silica Hair lighteners with color 0.47%
Silica Hair bleaches 1-6.8%
Silica Other hair coloring preparations 0.0005-10%
Silica Blushers 3-31.6%
Silica Face powders 1-66%
Silica Foundations 0.02-72%
Silica Lipstick 0.014-50%
Silica Makeup bases 10%
Silica Rouges 0.07-15%
Silica Makeup fixatives 0.25%
Silica Other makeup preparations 0.1-6%
Silica Basecoats and undercoats 0.5-6.2%
Silica Nail polish and enamel 0.2-10%
Silica Dentifrices 14.8-17.1%
Silica Mouth washes and breath fresheners 14%
Silica Other oral hygiene products 6%
Silica Bath soaps and detergents 0.0005-6%
Silica Deodorants
Not spray 0.009-10.4%
Aerosol 0.0001-0.084%
Silica Feminine hygiene deodorants 0.5-1%
Silica Aftershave lotions 0.25-2%
Silica Shaving cream 0.015%
Silica Other shaving preparations 0.2%
Silica Skin cleansing (cold creams, cleansing 0.0037-19.8%
Silica Depilatories 0.75-2%
Silica Face and neck products
Not spray 0.08-82%
Silica Body and hand products
Not spray 0.2-13%
Spray 2%
Silica Moisturizing products
Not spray 0.17-10%
Silica Night products
Not spray 0.0019%
Silica Paste masks and mud packs 0.25-21%
Silica Skin fresheners 0.4-4.8%
Silica Other skin care preparations 3.5-6%
Silica Suntan products
Not spray 4-7%
Pump spray 1.5%
Silica Other suntan preparations 0.65-2.3%
Sodium Potassium Aluminum Eye shadows 1.1%
Silicate
Sodium Potassium Aluminum Foundations 0.36%

Silicate
Sodium Potassium Aluminum Face and neck products
Silicate Not spray 0.36%
*Ingredients included in the title of the table but not found in the table were included in the
concentration of use survey but no uses were reported.
Information collected in 2018

Table prepared October 26, 2018

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Amended Safety Assessment of Silica and Silicates as Used in

Status: Draft Amended Report for Panel Review

© Cosmetic Ingredient Review

To: CIR Expert Panel Members and Liaisons

*Ingredients previously reviewed by the Panel.

The previous silicate reports are attached for your use:

Public Comment CIR Expert Panel Re-Review Rpt Status

Are new data cause to reopen?

15 proposed add-ons not

Draft FAR DRAFT FINAL

Table Different Conclusion

Final Amended Issue

Typical Search Terms

Potassium Silicate – 0 hits (CAS#10006-28-7), 5 hits, 0 relevant (CAS#1312-76-1)

appropriate qualifiers are used as necessary

September 9-10, 1999

Dr. Andersen noted that crystalline forms do exist.

The Panel agreed with Dr. Belsito’s proposal.

February 14-15, 2000

Potassium Silicate, Sodium Metasilicate, and Sodium Silicate

December 20-21, 1999

The Panel issued the following informal data request:

May 18-19, 2000

December 4-5, 2000

June 4-5, 2001

Silica and Silicates

June 29-30, 2009

DR. HATHAWAY: Correct.

DR. HATHAWAY: I believe so, yes.

DR. LIEBLER: So you're counting particles in microscopic fields. Right?

DR. HATHAWAY: I believe so, yes.

DR. BELSITO: Yes. This is before this SLR.

MR. PAVLICH: No, we haven't seen that.

DR. HILL: Clearly not toothpaste.

DR. HILL: Because of the particles produced by the spray.

DR. MARKS: Can you comment about granuloma formation?

DR. MARKS: I was thinking more in terms of application to damaged skin.

Belsito’s Team Meeting:

SPEAKER: (off mike)

MS. BECKER: Right. So table 12 continues -- started a page early.

DR. BELSITO: Oh, so table 12 on page 78 is really table 10.

MS. BECKER: Correct.

Okay, those are my comments. Curt and Paul?

MS. BECKER: Everything's in.

DR. SNYDER: That's everything?

DR. BERGFELD: Minimizing or deleting?

DR. LIEBLER: Excuse me?

DR. BERGFELD: Minimizing or deleting.

DR. LIEBLER: Minimizing.

DR. BERGFELD: Do you think leaving it in leads to confusion?

DR. BERGFELD: That will be really a very great delete.

DR. LIEBLER: Very brief, right, minimizing.

DR. BERGFELD: Okay, but --

MS. BECKER: But I saw fumed silica.

DR. SNYDER: That's all the tox data, is fumed siliar.

MS. BECKER: I guess.