Re: 99P-1340 -- Petition to Have Eternity eau de parfum declared "Misbranded"

Dear FDA Staff:

What I find highly ironic is that the unregulated fragrance industry came up with this bit of advice:

Everyone has a personal "scent circle": approximately an arm's length from the body. No one should be aware of your fragrance unless he or she steps inside your "circle." Fragrance should be one of the most subtle, personal messages you send to those with whom you come in contact. See http://www.fragrance.org/feature_tip_content.html (accessed 4/11/04)

It is not hard to find information on a body's adverse reaction to hydrocarbons. Read "fragrance," think hydrocarbon. Require your alert on all labels of all fragrances released to market without substantiation of safety. Not just safety for dermatological reactions to the primary user, but safety for nonusers so they don't suffer severe eczema flares and other dermatological signs of distress, including asthma, hives, rashes, burning and itching. Also, fragrances -- not only individual chemicals used, but as the mixtures are formulated -- should be tested for adverse events suffered by user and nonuser.

During the last 30 years or so, synthetic fragrances have been formulated to waft further and last longer, and they have been added to an ever increasing array of personal care and household and janitorial cleaning and maintenance products. Through advertising, the industry has enticed more people to use and wear more scents more places than ever before. The industry developed a public relations campaign and through it suggests people should observe their industry- determined " 'scent circle' ... approximately an arm's length from the body." Beautiful!

To point out the OBVIOUS, fragrances are volatile organic compounds and it's the nature of this
beast to NOT observe any "scent circle." Notice when you step into an elevator, and no one is
in sight but you know an odorovector had used that car before you because you are assaulted by the invisible,
noxious vapor trail left lingering. The toxic fragrance chemicals have become one with the air
you must breathe. Me too. And others.

Secondly, try to gain that arm's length when you are in your healthcare facility and the scented
nurse is drawing your blood, or your scented doctor is examing you, or the scented receptionist who is not only wearing perfume, lotion, deodorant, clothes volatilizing scented fabric softener, but who also has used highly scented hair gell, mousse or spray. Or, let's consider breathing at work, in school, in a crowded elevator, in a bank or post office, on crowded public transit ... in the theater . . . on a long plane flight. The list of chemical assault by perfume poisons are endless. Try to enjoy a fine meal in a restaurant. You wish to smell the aromas of the food and beverage. Yet you find you are faced with trying to dodge scented patrons, but even worse, you are faced with the host or hostess and servers, too. Restaurants should understand that dining is an
olfactory pleasure and that synthetic scents annihilate the scrumptious aromas from food and
beverage. And can cause a patron a death-defying asthmatic attack. (One hopes it is an attack that, bad as it may be, defies death!)

"Scent circle." Is that a clever ploy to off-load blame from the industry and put it squarely on the shoulders of the very people to whom they sell their products? How long will the people hold still for being blamed for wearing too much of a product that won't respect "scent circle" boundaries? If I were an unvalued customer, I'd switch to fragrance-free products . . . of course, there can be a problem trying to find truly fragrance-free or unscented products because the industry can add synthetic scents to products to mask other objectionable odors and then label these scented products "Fragrance-FREE" or "UNscented." But, there are ORGANICS.

Source: FDA'sCosmetic Safety: More Complex Than at First Blush
by Dori Stehlin"
* fragrance-free - products so labeled may still contain small amounts of fragrances to mask the fatty odor of soap or other unpleasant odors" http://vm.cfsan.fda.gov/~dms/cos-safe.html

So, how discouraging is all of this to those now requiring cleaner, safer air for access? Can we scramble up out of yet another abyss?

Let's give this idea of a "scent circle" a 180 degree flip. If users of scented products have an industry-declared "scent circle" that they are not supposed to exceed, then, by George, we have our own arm's length of distance that their chemical outgassings should not penetrate. (IF you are still working and your Human Resources manager is a scent user, I'd like to see how far you'd get claiming your "SCENT-FREE CIRCLE." You'd probably get booted right out the door.)

If you react to the toxic chemical scent concoctions used or worn by folks further away than your arm's length, be sure to claim your legitimate space of cleaner air. Of course, try to claim your arm's length while being examined by a scented doctor, or while having blood drawn by a scented nurse, while regestering for health care, attending a conference, at work, in school, in a crowded elevator, on a public transit conveyance, etc. Ad nauseam.

For my money, having to proclaim our "NO-scent circle" in the workplace, in school, in healthcare settings, in places of worship, on public transit, in meetings, et al., can't hold a candle to our space -- our "NO-scent circle," if you please -- being invaded by all of the industry- installed fragrance and pesticide emitting devices. One comes in contact with these decided air polluters upon entering hotels, restaurants and who knows what all public venues. I have even been in a hotel lobby whose staff proudly proclaimed they dispense fragrance throughout the hotel. I contacted management, rest assured. Lest you think this is just too far fetched, see:
Chemical Market Reporter; Nov 29, 1999
Fragrance Foundation and Analysts Outline Lasting Growth Strategies.
(Statistical Data Included); Author/s: Peter Landau
http://www.findarticles.com/cf_0/m0FVP/22_256/57887294/print.jhtml

But some of the worst offenders healthwise are those bathroom dispensers that spritz as one leaves the cubicle. That way, people get blasted on their person as well as in their lungs. Dangerous! And, of course, those pollutants are released to the general air so someone just wanting to wash hands is also subjected to that blast of pollutants released when another person left the cubicle.

In my opinion, these modern scent and pesticide dispensing devices, especially those that send this poison out through the HVAC (Heating, Ventilating and Air Conditioning) system are an assault on public health -- our health --AND an invasion of our rights to breathe safer air, unpolluted by gratuitously added synthetic scents, which are petrochemical distillates. And, what pray tell, happens to our "NO-scent circle of an arm's length under such circumstances?

If YOU think the industry has its way with our government, our health, and our "NO-scent circle," please write to the US agencies such as the FDA, the EPA, and the CPSC. Strange as it may seem, their mission is to protect public health.

And, if all of this doesn't seem ludicrous enough, the industry has admitted to having just begun its first study of effects upon fragrance inhalation. See
Scents and sensitivities
What to know before buying a Valentine's Day perfume
By Francesca Lyman; Feb. 6, 2002; MSNBC CONTRIBUTOR
http://www.msnbc.com/news/702445.asp

Another article worth your time is Scents are InTOXICating by Sue Williams, who has written it for The Healthy Planet (http://thehealthyplanet.com/InTOXICating.htm). You may wonder about the industry
prescribed SCENT CIRCLE as you read, "I bank at a credit union and for over a year we have
been at war. Not because of any discrepancy in my account, but because of the overwhelming,
breathtaking fragrance inside. This odor permeates even the drive-up tubes and this toxic air
comes inside the vehicle whenever I open one to retrieve my deposit slip. ..."

Want more info? Read "Scents & Sensitivity" by Brandy E. Fisher in the Environmental Health Perspectives; Volume 106, Number 12; December 1998 at http://ehp.niehs.nih.gov/docs/1998/106-12/focus.html

You may also wish to ask yourself this question before you next use one of "your" -- manufactured, synthetically derived from petrochemicals -- signature scents or favorite scented product: Do Environmental Chemicals Harm Humans? by Dr. Mercola http://mercola.com/2004/mar/6/environmental_chemicals.htm. By the way, when you read this article, and learn of chemicals in breast milk, think MUSK. Synthetic musks are commonly used in the manufacture of fragrances. They are not only found stored in breast tissue and downstream in breast milk, but they are also found in the water downstream where they are also affecting fish and wildlife. By looking for safer products without petrochemical derived scents, you may be protecting your health and the health of fellow creatures on this planet.

Also, a "must read" is an article that was published in the International Flavours and Fragrance Journal: Fragrance: Emerging Health and Environmental Concerns
by Betty Bridges, RN at http://www.fpinva.org/FragranceReview.htm  

And now we learn: Due To Indoor Sources, Cancer Health Risk Significantly Underestimated by EPA's Ambient Model Estimates
I cannot help but wonder if some of those "indoor sources" aren't from volatilizing petrochemically derived fragrances . . . they do contain carcinogens. Analyze a few fragrances OR, look at the petition 99P-1340, filed on May 11, 1999 by EHN.

Sincerely, -- barb wilkie

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barb's views reflect only her opinion and do not necessarily reflect those of the Environmental Health Network or its boards.

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Do you suffer asthma, sinusitis, migraines,rhinitis (leaky beaky)?

Have you discovered that no matter what you do to follow doctor's orders to clean away those dreaded dust mites, you still have asthma, et al.?

Think about all of the modern fragrances that enter your life through personal care and cleaning products. Fragrances are made with toxic chemical formulations by an unregulated industry. They are at best "irritants" capable of causing or triggering asthma, and at worse may cause central nervous system disorders and cancer. By the bye, every time you see the word "irritant" associated with asthma or other diseases, think "poison." Irritant, as defined by my Oxford Dictionary, is poison.

See EHN's FDA Petition requesting the FDA require warning labels - the regulations exist, the FDA doesn't enforce them! http://www.ehnca.org/www/FDApetition/bkgrinfo.htm

Reference "Docket Number 99P-1340" and tell the FDA about illness you suffer because of fragrances.

E-mail: fdadockets@oc.fda.gov