Wednesday, September 29, 1999

Dockets Management Branch
The Food and Drug Administration
Department of Health and Human Services, Rm. 1-23
12420 Parklawn Dr.
Rockville, MD 20857

by email: fdadockets@oc.fda.gov

Dear Food and Drug Administration:

I'm writing to petition your Administration to [declare] *Eternity* eau de parfum "misbranded", as a comment to Docket Number "99P-1340/CP 1". The basis of this petition is the lack of a warning label on the product informing consumers that all the materials in the product, and the product itself, have not been adequately tested for safety. Independent laboratory analysis of this product has revealed such chemicals as diethyl phthalate (suspected hormone disrupter with ability to accumulate in the fatty tissues of the human body through skin absorption); phenols (suspected carcinogens, may cause reproductive harm); benzoethanol(rated toxic, readily absorbed via skin, central nervous system effects); musks xylene and musk ketone (recently in the news as suspected carcinogens which accumulate in human and animal tissues) and skin and respiratory irritants.

As a citizen I have (or ought to have) a civil right to breathe clean air. I also should have the right to know what's in that air whenever feasible. When someone douses themselves with artificial cologne or perfume I am denied those rights. I also believe that all ingredients should be listed on any food, drug, or any product ingested, absorbed, or applied to the body. Consumers ought to have an informed choice about what goes in or on their bodies. Unfortunately, the law states that only certain chemicals have to be listed on the label, and that "fragrances" are protected from disclosure by Confidential Business Information, (CBI). However, CBI does not shield disclosure of substances that are known hazards (or should be known). Inadequate safety testing is no excuse for not labeling a hazardous ingredient or misbranding a product.

I urge your administration to do a more thorough analysis of Calvin Klein's "Eternity Eau de Parfum." Should your analysis confirm any of the results of independent studies it seems appropriate that this product ought not be allowed onto the market. Perfume manufactures could and should reformulate, because public health always comes first.

Sincerely,

Blake Brown
Sierra Club, San Francisco Bay Chapter
Toxics Committee Chair