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The Environmental Health Network of California
Files Petition With the FDA



November 10, 1999

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

    Re: 99P-1340/CP 1
    Petition to Have Eternity eau de parfum Misbranded

Dear Sir or Madam:

I am writing regarding a petition filed in May 1999 by the Environmental Health Network to have Calvin Klein's "Eternity eau de parfum" declared misbranded. I have read and fully support the petition. I respectively request that FDA give this petition its utmost attention.

I am sensitive to many chemicals such as gasoline, new paint, new carpet, perfume/cologne, pesticides, new cars, rubber (such as car mats and tires) and the list goes on. I developed this sensitivity as a result of my work in a Federal building that was found to have very intolerable environmental conditions. I am very concerned that a product that I used to use, perfume/cologne, now causes similar reactions as other chemicals that now bother me, such as those listed above. I am continually surprised at some of the chemicals found in fragrance products as I continue my reading and research. Many of these are known or suspected carcinogens and/or are respiratory irritants.

I have many problems in the workplace and in public with exposure to fragrances. I work at the U.S. Nuclear Regulatory Commission in an air-tight office building (note I am responding to this petition as a member of the public). There are numerous employees that wear excessive amounts of cologne or perfume, to the point where one can smell them coming and can still smell the fragrance several minutes after they have passed down the hallway. There have been occasions where I have had to step off of an elevator due to people wearing too much fragrance, or the lingering odor is too strong for me to tolerate.

In public, I have had to change seats numerous times during movies, plays and symphony concerts to try to get away from fragrances. I have had to breathe through several layers of napkins over my nose and mouth during movies because of someone nearby wearing an excessive amount of fragrance and not being able to move due to all the seats being occupied. I have to plan my route to avoid the fragrance displays in department stores, often having to hold my breath until I am well past the display.

When I am exposed to heavy amounts of fragrances, I can get very ill. My symptoms include:

    - lungs tightening and burning;
    - extreme headache;
    - extreme fatigue to the point where it is difficult to stay awake;
    - muscle aches and weakness similar to that with the flu;
    - fogginess in the brain; and
    - difficulty communicating and concentrating.

Additionally, I will often end up with swollen lymph nodes and a sore throat. Any or all of these symptoms can last for an hour or two, or up to 2 days, depending on the level of exposure. In those cases where the exposure was severe, such as two long meetings during the day where someone was, or many people were, wearing excessive fragrance, I have ended up with bronchitis-like symptoms for 2-4 days.

I am just now learning of the great flexibility that the fragrance industry has in the ingredients that it uses in its products, and in the required labeling. I believe that this should be regulated much more tightly so that public health is protected. People need to know what is in products that they are using so that they can make informed choices. A first step would be to put a warning label on the product that the safety had not been determined. I truly believe that most people, like myself before I developed sensitivities, think that products on the market have received a full safety review and are completely safe. I never imagined that perfume/cologne would have such chemicals, many of which I consider quite toxic.

I am particularly concerned about issues such as this because I would not want anyone else to develop chemical sensitivities and have their lives impacted the way mine has been. My career potential has been limited and I no longer have the great flexibility in changing jobs. I have not been able to apply for several jobs within my agency that would be promotions because the position was located in a building that is undergoing renovation. I was not able to take a rotation to the Executive Director of Operations for the same reason.

I am a health physicist and most occupations are now no longer an option for me. Two examples: 1) I can no longer work around chemical laboratories as I would have to in a university setting; 2) I can no longer work in a hospital setting where I will be exposed to patients who will be wearing fragrance products and other problems that are unrelated to this petition.

I have problems traveling in my job due to the difficulty in finding hotels that have not been recently renovated. I have a lot of trouble in the air-tight office building in which I work, and hope I do not reach the point where I will no longer be able to work in that environment. I have trouble finding places to live due to restrictions. I have had to avoid going to certain gatherings with friends if I know there will be individuals there with a heavy amount-synthetic one.

One never knows what will trigger a person to develop chemical sensitivities. Mine was triggered by a "sick building." For someone else, it might be an acute or long term chronic exposure to a perfume/cologne that contained a toxic chemical.

Please evaluate this petition closely and take a hard look at the regulations to ensure that public health is protected.

Sincerely,

Torre Taylor



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The Environmental Health Network (EHN) [of California] is a 501 (c) (3) non profit agency and offers support and information for the chemically injured. EHN brings you topics on this page that need your immediate attention The URL for this page is http://www.ehnca.org/www/ehnact.htm