Weaving Strong Leaders: Katie’s Story
Hi! My name is Katie Snell, and I worked with Women’s Voices for the Earth last year as a first-year law student at UC Law San Francisco. Throughout the year, I assisted Alex Scranton, WVE’s Director of Science and Research with drafting and editing a Citizens Petition to the U.S Food and Drug Administration (FDA) asking the Commissioner to develop product safety guidance for manufacturers of cosmetic products that have vaginal exposure to clarify how manufacturers can make safer products and avoid potential adverse effects on the vaginal microbiome.
The first step in my WVE journey was a meeting with Alex to learn about the organization, its mission, and the goal of the project. Immediately, I was excited! Alex was extremely welcoming, passionate about WVE, and knowledgeable about both the Citizen’s Petition process and the product safety guidance we are hoping to improve.
Alex’s breadth of knowledge was great for me because I was not familiar with the current regulations for manufacturing women’s intimate hygiene products. Because of my knowledge gap, I spent the next portion of the project researching. I read online articles, scientific journal articles, blog posts, product websites, and more to learn everything I could about the healthy bacteriumin the vaginal microbiome and how harmful chemicals in these products can have adverse impacts. I learned how intimate care products, such as douches, wipes, washes, sprays, and powders have a unique route of exposure to the body through sensitive vaginal tissue. I learned about lactobacillus and vaginal pH and how both of those important parts of vaginal health are discussed in advertisements. I also spent time reviewing past Citizen’s Petitions written by WVE and other organizations. I dug into statutes, like the Federal Food, Drug, and Cosmetic Act and the Fair Packaging and Labeling Act, to orient myself in the administrative regulations of the industry.
Ultimately, the Citizen’s Petition argues that developing product safety guidelines for the manufacturers of women’s hygiene products should be a priority of the FDA to ensure that all citizens’ health is taken seriously and protected. This is because there are currently a variety of hazardous ingredients in intimate care products, many of which inhibit the growth of the healthy bacteria lactobacilli in the vaginal microbiome. A disruption of vaginal lactobacilli can result in a multitude of health problems, such as vaginal infections, bacterial vaginosis, urinary tract infections, pelvic inflammatory disease, candidiasis, and more. Manufacturers are not required to test a product’s impact on the vaginal microbiome or meet any universal standards of ingredient safety. Yet, the products are marketed as safe and helpful to maintain vaginal health. Given this disparity, the Petition argues that the choice to use intimate care products should not put users’ health at risk.
It is also important to note that while this problem can affect any user of intimate care products, the industry’s unsafe manufacturing practices and targeted advertising adversely impact women of color and/or those in low economic classes. So, the industry has not only a health issue but also a pervasive environmental justice and equity issue. This was included in the Petition’s section on Disproportionate Impact.
Women’s Voices of the Earth has submitted the Citizen’s Petition, and it is now open for public comment, which means if you are passionate about ensuring the FDA holds manufacturers of intimate care products accountable so that we aren’t exposed to harmful chemicals that can disrupt our vaginal health, then submit your public comment today!
For those unfamiliar with the typical law school schedule, your first year of school is almost 100 percent focused on your classes. Besides being a member of student organizations and attending school-wide events, there are not as many extracurricular opportunities for first-year law students as there are for second and third-year students. However, you do have the opportunity to participate in the Pro Bono program, which is how I found Women’s Voices for the Earth.
I am so grateful for the opportunity to work on this project with WVE! I gained valuable research and writing skills and learned so much about the FDA’s product safety regulations and processes. I am proud to contribute to WVE’s mission to uplift environmental health and justice initiatives and support women across the country!