Understanding the distinction between hazard and risk is essential for making informed, rational decisions—and for avoiding unnecessary alarm or misinterpretation, especially when evaluating common consumer products found in our homes. Sensational headlines about the presence of heavy metals and glyphosate in Girl Scout Cookies or glyphosate in cereal grains understandably raise concern, often leaving consumers feeling confused or misled.

However, the mere presence of a toxin in a consumer product does not automatically equate to health risk. Without proper context or a clear understanding of the data presented in studies or media reports, it is easy to assume that the detection of a hazardous substance inherently signifies danger—when in fact, that is not necessarily true.

Headlines regarding presence of lead and arsenic in toothpaste have sparked public concern, leaving many questioning whether their daily brushing routine poses a health risk. The source of these reports is a study conducted by the consumer advocacy group Lead Safe Mama, LLC (LSM), which published laboratory results indicating that 51 over-the-counter toothpastes and tooth powders tested positive for cadmium, mercury, arsenic, and/or lead.”

The potential for metal contamination in toothpaste to pose a health and safety risk depends on the type and concentration of metals present. Such contamination can occur during manufacturing—through sources like raw materials, packaging, or inadequate quality control—or through improper storage. Metals occasionally detected in toothpaste include lead (Pb), mercury (Hg), cadmium (Cd), arsenic (As), chromium (Cr), and nickel (Ni). Young children may be more susceptible to exposure due to behaviors such as swallowing toothpaste and the potential for absorption through the oral mucosa. Additionally, their developing nervous systems and still-maturing detoxification pathways may make them more sensitive to certain toxic elements such as lead and mercury.

To begin with, arsenic, cadmium, and hexavalent chromium compounds are classified as human carcinogens. Lead and mercury are known neurotoxicants that can impair cognitive development in children and affect memory, concentration, and behavior in adults. In addition, cadmium, arsenic, and mercury are both nephrotoxic (harmful to kidneys) and hepatotoxic (harmful to liver), particularly with chronic exposure.

According to Lead Safe Mama, LLC (LSM), the goals of their laboratory testing initiative are twofold:

1. To identify products that are laboratory-tested and safer, enabling consumers to make science-informed decisions for their families; and
2. To flag products with high levels of toxicants for potential reporting to public health agencies (such as the FDA) in an effort to prompt recalls.

While the group emphasizes its commitment to promoting ‘science-informed choices’ and funds its testing initiatives through crowdfunding, the laboratory data it shares publicly often lacks essential context or explanation. As a result, it can be difficult—if not impossible—for the average consumer to accurately interpret the findings or make truly informed, science-based decisions.”

RHP analyzed the risks associated with exposure to metals in toothpastes to young children against established regulatory standards set forth by one or more of the following agencies: the U.S. Environmental Protection Agency (EPA), the European Food Safety Authority (EFSA), the Agency for Toxic Substances and Disease Registry (ATSDR), and the U.S. Food Drug Administration (FDA). The four toothpastes used in the Lead Safe Mama analysis included: Colgate Watermelon Burst Toothpaste, Orajel Training Toothpaste*, Orajel Kids Anticavity Toothpaste – Paw Patrol, and Tom’s of Maine Kid’s Natural Toothpaste. Cadmium levels were below detection limits for the 4 toothpastes used in the analysis. Cadmium levels in all four products were below the laboratory detection limits. For lead, mercury, and arsenic, the maximum reported concentrations were used in the exposure modeling. Estimated internalized and absorbed doses were then compared to health-based regulatory thresholds to assess potential risk to human health. The following assumptions and empirical data informed the exposure analysis:

Frequency (# occurrences per day):  3 times per day ¹

Mass used per occurrence: 0.8 g/occurrence ²

Fraction ingested (%): 35% ²

Fraction absorbed (%): 100%

Mass of child using the toothpaste: 15 kg ³

These risks were expressed as: the number of events that would have to occur on a daily basis to exceed the regulatory threshold. Findings of this analysis are shown in the table below:

As the results indicate, a child would need to brush their teeth more than 100 times per day to exceed the no-effect threshold for arsenic exposure (based on the highest detected concentration—40 parts per billion (ppb)—found in Tom’s of Maine Kids Natural Toothpaste); and approximately 3,000 times per day to exceed the no-effect threshold for mercury exposure (based on the highest detected concentration- 12 ppb- found in Orajel Kids Anticavity Toothpaste- Paw Patrol.)

Understanding Hazard vs. Risk

In the field of consumer product safety, distinguishing between hazard and risk is essential for effective hazard management, clear communication, and regulatory compliance. A hazard refers to the inherent properties of a substance that make it capable of causing harm—for example, the presence of metals in toothpaste. Hazards exist regardless of whether an exposure actually occurs. In other words, hazard describes what a substance can do, based on the potential health effects observed at exposure levels above those deemed safe by regulatory agencies.

In contrast, risk reflects the likelihood that a substance’s hazardous properties will cause harm under specific conditions of use—such as a child brushing their teeth more than 200 times per day. Risk is influenced by the nature, level, and duration of exposure, as well as the presence of any protective measures.

Understanding the distinction between hazard and risk is not merely academic; it carries real-world implications for occupational safety, chemical management, human health risk assessment, consumer product stewardship, and regulatory policy. The case of trace metals in toothpaste underscores the importance of this distinction—illustrating how the mere presence of a hazardous substance does not necessarily equate to a meaningful risk.

References

1. Consumer Product Ingredient Safety Exposure and Risk Screening Methods for Consumer Product Ingredients, 2nd Edition, Appendix II-A-3: Oral Exposure Parameters to Estimate Screening Exposures to Consumer Products — North America, American Cleaning Institute, Washington, DC, September 2010
2. Barnhart, W.E., Hiller, L.K., Leonard, G.J., Michaels, S.E. (1974) Dentifrice usage and ingestion among four age groups. J. Dental Res. 53(6):1317-1322.
3. U.S. EPA 1991a. Human health evaluation manual, supplemental guidance: “Standard default exposure factors”. OSWER Directive 9285.6‐03.