The International Aloe Science Council (IASC) submitted comments
in response to the Office of Environmental Health Hazard Assessment (OEHHA)
April 23 Notice of Intent to List Aloe
vera, whole leaf extract as known to the state to cause cancer
under California's Safe Drinking Water and Toxic Enforcement Act (Proposition
In its comments, IASC recommends clarifications for the Aloe vera, whole leaf
IASC recommended that the aloe vera material be identified as
non-decolorized whole leaf extract" and specifically exclude Aloe vera decolorized
whole leaf extract, Aloe
vera decolorized leaf juice; Aloe vera gel; Aloe vera gel extract,
or Aloe vera latex.
In addition, the IASC comments recommend that OEHHA clarify in the listing that
the only relevant route for exposure is oral consumption.
The NTP conducted a 2-year feeding study in both rats and mice
using an extract of aloe vera whole leaf that retained the complete latex
constituent. The results of this study are presented in NTP Technical Report
577 (NTP TR 577), dated August 2013. NTP TR 577 clearly and appropriately
identified the substance studied as "a Nondecolorized Whole Leaf Extract
of Aloe Barbadensis [sic] Miller (Aloe Vera)" in the website abstract.1
This is important as it differentiates the NTP test substance from the vast
majority of commercial aloe vera leaf extracts available in the marketplace,
which have been decolorized/purified in order to remove the latex anthraquinoid
constituents present in non-decolorized whole leaf extracts.
"This differentiation with respect to the test substance was
endorsed in comments provided to NTP by the IASC regarding the TR 577 draft
report ("Comments of the International Aloe Science Council on the
National Toxicology Program's Draft Report TR 577, April 4, 2011"). IASC
strongly encourages OEHHA to incorporate this same precise nomenclature in the
proposed Proposition 65 listing and any related publications on and discussion
relating to aloe vera non-decolorized whole leaf extracts," IASC's
IASC's comments conclude that "the appropriate title of
"Aloe vera, non-decolorized whole leaf extract" to identify the
listed ingredient with an appropriate description, and exclusions."