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 65). 

In its comments, IASC recommends clarifications for the Aloe vera, whole leaf extract listing. 

IASC recommended that the aloe vera material be identified as "Aloe vera, 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 comments state.

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."