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Another Perspective: Press Releases and Statements Regarding the fragrance industry's press conference in Halifax, Nova Scotia Media Advisory
Betty Bridges, RN:
The industry
USA:
Additional information for your edification: Health Canada Code | US FDA Code FDA Petition RE: Warning labels on fragrances
National Post article:"Scent summit is sunk by a mere whiff of perfume"
Various articles on Halifax |
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Press Releases and Statements Also includes the Fragrance Industry's Statement and Ad for their "counterattack" Conference in Halifax Plus a link to Materials Used in Perfumery where you can see for yourself the 70% - 100% Aroma Chemicals
NSAEHA MCS Referral and Resources June 19, 2000 Strict Embargo of this information until10:00 a.m.Tuesday, June, 20, 2000 webposted 6/22/00, bw
For more information contact:
Hosted by:
Date: June 20, 2000 The CCTFA has professed a desire to create a dialogue on fragrance issues in a calm and open forum between the industry and stakeholders of Nova Scotia. Yet, the CCTFA's recent responses to requests and invitations from stakeholders led the above organisations to decide it was necessary to provide this press conference to be sure that important and relevant scientific and medical information is heard.
Background: Nova Scotia has caught the attention of the fragrance industry because of our widespread scent free programs. The international media picked up on some exaggerated articles that claimed we have scent police, kick elderly ladies off busses & out of city hall, that a student was handed over to the RCMP & almost got a criminal record, that we believe DDT and perfume are the same, and many other twists of the truth! Halifax City Hall, NS Tourism (vacationers fear being arrested!) NSAEHA and others spent much effort doing interviews and correcting the misinformation. Something good has come from this. There is now international awareness of the topic. We got calls internationally from those wanting to know how to get scent free programs in place.
EISC first met with CCTFA (last week) to request that their morning presentations be expanded to include our input). They declined. Then they declined our request for a round table discussion in the afternoon. Then they declined a public debate for the evening. The alternate press conference was the obvious choice, but we had to embargo the press releases so as to avoid counter actions. There was a very busy week of preparation. Betty and her husband drove here from Virginia! Albert flew in the evening before - in time for the final press kit preparations and planning session at a barbecue at Eric's. Judith sent out the embargoed media releases bearing the logos of the four organizations, and we followed up with phone calls to alert the press. The only regret was that Judy couldn't come. She had been central to the planning stages. On the day, Mr Low, president of the CCTFA said they were in Halifax to educate people on responsible perfume use. He said the industry recognizes some people claim to be very sensitive to fragrances, and he hopes they are getting medical treatment. He strongly suggest you wear perfume "responsibly" by keeping it within your "scent circle". (THAT would be a feat!) There was no acknowledgement, that I saw, of the prolific everyday use of fragrances in many products besides perfumes. They use no carcinogens or toxic chemicals, said Mr Low. They claim to test all fragrances, (but they don't make the tests or the ingredients public due to trade secrets). They are completely safe, said Mr Low. As safe as your food, said Mr Low. Safer than E.Coli or areas with high traffic death rates (!!), said another. Mr Low said their sales in NS had dropped but were now up to normal rates again (to suggest this tempest in a teapot has passed) and he explained away the scent programs here as fads! They assert that it isn't a health and safety issue, but seem to ignore strong evidence to the contrary from many reputable sources. They do not make public their ingredients or details of their own testing. It seems they do not realize that "trust me" doesn't work very well since most of us have been around to witness the tobacco industry say "trust me, its safe" and same for silicon breast implant issue and lots of others. There were two security guards outside the elevator and one in the hall outside the room! One of our people was walking along with a government dept rep who asked one of the guards why they were in the hotel "Is if because of the fragrance meeting??" affirmative. "But this is HALIFAX!" (incredulous). Our NSAEHA team did us proud! Suits and suitcases and facts and figures and teamwork. NO one could call us rude or ill-informed or "activists" as the industry likes to do. Ten media came to our press conference and that is a lot for Nova Scotia! Eric Slone, (who was voted our interim president at the last board meeting) was moderator and read the NSAEHA statement and EISC statement. Betty spoke well next and then Albert finished it off with style. They did a tremendous job. We can't thank them enough for coming here at considerable personal sacrifice and at short notice. SO, we left our press conference to go to the CCTFA's and we were all stopped at the door! What was that about an open forum for dialogue? We had allowed them at our press conference. No matter. We had prepared the press well in our press conference with all the facts and questions they needed, and also several stayed afterward and kept Betty and Albert busy with interviews until 2:30! There were interviews on CBC TV and ATV Live at Five, Shaw (Cable 10) will air theirs in Halifax in Saturday at 9:30, Sackville area Thursday 6pm, Friday 9:30am 12 noon and 5 pm. There were balanced articles in all 4 major papers: Chronicle Herald, Daily News, National Post and Globe and Mail. Canadian Press did one too. CBC radio did news clips all PM and I am not sure how long into the evening. CJCH interviewed Mr Low and Karen R. Wednesday a.m. and did clips in each news broadcast over the morning. I did not hear if other radio stations did pieces. The CCTFA has announced a major public awareness campaign here for the next month. Please write or call into media when you see misinformation, or to give positive feedback. Scent free programs benefit all of us and all help is needed to keep the progress we have made these past years. P.S. how heartwarming it was to have donations from $100 to $500 US even, coming in from all over North America from groups and individuals who share our fight, who recognized this was important, and who are rooting for us. We need NEVER feel alone out here hanging off the edge of the continent. We could use more help to cover the costs. Still need about $400.00.... Please mail your donations, marked "Halifax Scent Action" or something similar, to
Environmental Illness Society of Canada (EISC )
EISC,
Hosted by: Nova Scotia Allergy and Environmental Health Association (NSAEHA) MCS Referral and Resources, Baltimore, MD, USA Fragrance Products Information Network, Virginia, USA Environmental Illness Society of Canada (EISC), Ottawa Date: June 20, 2000 Time: 10:30 a.m. Caution is warranted. The CCTFA has professed a desire to create a dialogue on fragrance issues in a calm and open forum between the industry and stakeholders of Nova Scotia.
Record to Date:
As a result of the CCTFA responses, the above organizations decided it was necessary to provide this press conference to be sure that important and relevant scientific and medical information is heard.
Over recent months the city of Halifax and its citizens have been portrayed in the international media as silly hysterics. Incidents have been twisted and sensationalized, the health issues around fragrance chemicals have been scoffed at or minimized, factual information and research supporting reduction of fragrance use has been ignored, and individuals/spokespersons have been misquoted, misrepresented and actually had fabricated words and actions attributed to them.
It may be interesting to note some common techniques that have been
identified when the profits of an industry or agency are threatened by
health evidence. Examples have been seen in the anti-cigarette smoke issue
and the silicon breast implants health issue. These are:
NSAEHA would like to express encouragement and gratitude to the Mayor's Office and to provincial and Halifax Tourism staff for setting the misconceptions straight and supporting the local scent programs while answering the international calls that came as a result of the misleading media articles. We do not have a legislated ban on fragrances here. An 84 year old woman was not "booted out" of City Hall, or "bullied by misplaced guilt". The Duncan MacMillan student was not "handed over to the RCMP" and did not "nearly get a criminal record". No one claims fragrance chemicals include DDT. We don't have "scent police". There was no placard-bearing march on City Hall by people wearing gas masks! Such talk must sell newspapers, though! Like the Mayor's office, other supporters of scent programs have been doing many interviews to set things straight. We have also received many calls from places as far away as the UK, California, and Australia asking how to put scent-free programs in place in their areas. Nova Scotia's voluntary fragrance reduction programs are based on a high level of awareness among Nova Scotians about the impacts of indoor air pollution on health, and a willingness to care for those whose health is impacted. Many symptoms from migranes to brain fog can be triggered by fragrance chemicals. Research from the US FDA shows 72% of asthmatics experience respiratory symptoms when exposed to fragrances. Because 17% of our Nova Scotian school children have asthma, it makes sense to limit scents. - 30 -
Fragrance Products Information Network
Environmental Illness Society of Canada (EISC )
The June 21, National Post article about the phenomenally successful Press Conference we organized with three other NGOs (non government organizations). At article bottom, notice that EISC is NP Link. It ensured that coverage was balanced. That was the goal of the whole effort. Reports from as far away as Hong Kong and Australia are now coming out 'balanced'. [See "Scent summit is sunk by a mere whiff of perfume - Halifax 'hotspot' for nasal-rights movement" by Graeme Hamilton, National Post http://www.nationalpost.com/search/story.html?f=/stories/000621/323529.html.] Funds are still needed to cover heavy Press Conference and travel expenses. Anyone wanting a pledge form should email the EISC for one. The E-commerce site on EISC WebPage is being set up to receive secure VISA and M/C donations. Look for e-donating coming soon on the EISC site. Donors will indicate if they are giving to the EISC for its programs or, to the coalition to cover Press Conference expenses. Many thanks,
Judy Spence
Rebuttal Press Conference
Fragrance Products Information Network MCS Referral and Resources Environmental Illness Society of Canada
The 1986 OTTAWA CHARTER for Health Promotion is a Charter for Action to Achieve Health for All by the Year 2000 and Beyond. Ottawa's own WHO charter was part of a new public health movement around the world. Health Promotion is the process of enabling people to increase control over, and to improve, their health. The prerequisites and prospects for health cannot be ensured by the health sector alone. More importantly, health promotion demands coordinated action by all concerned: by governments, by health and other social and economic sectors, by nongovernmental and voluntary organization, by local authorities, by industry and by the media. Health promotion goes beyond health care. It puts health on the agenda of policy makers in all sectors and at all levels, directing them to be aware of the health consequences of their decisions and to accept their responsibilities for health. Health promotion policy requires the identification of obstacles to the adoption of healthy public policies in non-health sectors, and ways of removing them. The aim must be to make the healthier choice the easier choice for policy makers as well.
Health cannot be separated from other goals.
Health promotion supports personal and social development through providing information, education for health, and enhancing life skills. By so doing, it increases the options available to people to exercise more control over their own health and over their environments, and to make choices conducive to health. This mandate should support the needs of individuals and communities for a healthier life, and open channels between the health sector and broader social, political, economic and physical environmental components.
For more information about the 1986 Ottawa Charter for Health Promotion,
the First National Symposium on Multiple Chemical Sensitivity, Chronic
Fatigue Syndrome and Fibromyalgia: Environmentally-Triggered and Emerging
Illnesses,
Nova Scotia Leads the Way Implementing the Tenets of the Ottawa Charter For Health Promotion
Ottawa's W.H.O. Charter Is a Blueprint For Action OTTAWA -- Canadian health experts developed the Ottawa Charter for Health Promotion which embraced new paradigms in health promotion and asked people in all walks of life, nongovernmental and voluntary organisations, governments, the World Health Organisation and all other bodies concerned to join forces in introducing new strategies for health promotion in order to ensure that Health For All by the year 2000 will become a reality. Industry and government policy makers from all signatory countries were expected to adopt a new thinking about strategies that promote health. "Nova Scotia's institutions appear to have moved toward a more Socio-ecological approach to health by developing policies that recognise the inextricable links between people and their environment", says Judith Spence, RN, C.E.O. the Environmental Illness Society of Canada. "School boards, municipal, provincial and other bodies in Nova Scotia spent years consulting with community stakeholders before they developed a number of scensible public policies". The Ottawa Charter for health Promotion teaches that health is created and lived by people within the settings of their everyday life; where they learn, work and play and that it is ensured when the society one lives in creates conditions that allow the attainment of health by all its members. Resistance by special interest sectors like the perfume industry, was predictable and foreseen by the architects of the Ottawa Charter for Health Promotion: "decision makers must counteract the pressures towards harmful products, resource depletion, unhealthy living conditions and environments, and bad nutrition and, must focus attention on public health issues such as pollution, occupational hazards, housing and settlements". Nova Scotia's institutions have recognised the increase of sensitivity to fragrances and they took action. Through policy, they clearly demonstrate that people are their main health resource. Their awareness raising programs have supported Haligonians and have enabled them to keep themselves, their families and friends healthy. They accepted the community as the essential voice in matters of its health, living conditions and well-being. "This is exactly how health is promoted and it is how it can be achieved by 2000 for Nova Scotians with Environmental Illness", affirms Spence, "decision makers there have recognised health and its maintenance as being a major social investment and challenge and, its institutions have taken action, just as the Charter Canada promoted that it should". The EISC maintains that these steps must be taken to promote health for the over 15% of Nova Scotians who have asthma and/or Multiple Chemical Sensitivity. Health promotion goes beyond health care. It puts health on the agenda of policy makers in all sectors and at all levels, directing them to be aware of the health consequences of their decisions and to accept their responsibilities for health. Health promotion policy requires the identification of obstacles to the adoption of healthy public policies in non-health sectors, and ways of removing them. The aim must be to make the healthier choice the easier choice for policy makers as well. The Environmental Illness Society of Canada commends the Mayor and his staff, the Nova Scotia provincial Tourism Office and local schools boards for adopting policies that made them the focal point of media ridicule but which demonstrate that they place the health needs of their constituency ahead of the wants of special interests. "This truly most of the formula for achieving health. This, in addition to access to making specialised Environmental Medicine treatments available, will lead to "health for all by 2000 and beyond".
For more information about the 1986 Ottawa Charter for Health
Promotion, the First National Symposium on Multiple Chemical Sensitivity, Chronic
Fatigue Syndrome and Fibromyalgia: Environmentally-Triggered and
Emerging Illnesses, or, contact
Judith Spence (613) 728-9493, eisc@eisc.ca and , Toll Free: 877-313-EISC
Fragranced Products Information Network
http://www.ameliaww.com/fpin/HPVC_EURO.htm
Scent summit is sunk by a mere whiff of perfume Halifax 'hotspot' for nasal-rights movement Graeme Hamilton; Wednesday, June 21, 2000 or Search for "Scent summit" from within site, within 60 days. -- barb http://www.nationalpost.com/search/story.html?f=/stories/000621/323529.html
The fragrance industry has been quite vocal on the restriction of the use of fragranced products in Halifax, Nova Scotia. They have expressed indignant outrage at what they describe as a threat to individual freedoms. While it is asserted there are no scientific data to support concerns, there has been no presentation of scientific data on the part of the industry to dispel health concerns. And there has been little concern for the rights of those negatively impacted by fragranced products, nor any concern for consumers' "right to know" so that informed choices may be made. For all its assertions that scientific data to support concerns do not exist, there has been no opportunity for the scientific data that is available to be presented. There is an increasing body of scientific, medical, and industry literature that supports concerns over health, safety, and environmental aspects of fragrances. Rather than responsibly address these recognized issues the industry has chosen to play upon controversy of Multiple Chemical Sensitivity. There are mounting reasons for the industry to be concerned. A petition before the FDA in the U.S. asks that existing labeling laws be enforced. The publicity over the events in Halifax threatens the image and profits of the industry. In Europe changes that will require labeling of skin sensitizers are imminent. These are the reasons for the industry's great financial concern, which are thinly disguised by assertions that personal freedoms are at stake. Unfortunately, many of these issues have been misrepresented in the media coverage of the "scent debate" in Nova Scotia. Questions raised by the article "Cosmetics industry wafts into Nova Scotia's scent debate" by Jonathon Gatehouse from the Tuesday, April 25, 2000 issue of THE NATIONAL POST are addressed below along with a summary of concerns supported by scientific, medical, and industry data. Assertion #1: Fragrance has been used for centuries with few adverse effects. History of use indicates fragrances are safe. Rebuttal: Fragrant materials have been used for centuries. Up until the 1800s the primary use was medicinal, religious, and ceremonial purposes. These materials were thought to have powers to ward off disease and prevent harm. The elite used scented oils to enhance beauty. Cleopatra is famous for such use, but this use was limited to those with power. Up until the late 1800s the raw materials were obtained from plant and animal sources.(1) Modern fragrances are primarily synthetic materials developed since World War II.(2) Multiple fragranced products are now used on a daily basis.(3) Both materials exposed to and the amounts of exposure are vastly different from centuries ago nullifying any comparison and voiding any validity to history of use.
Rebuttal: Fragrance was used to mask the stench of unwashed bodies during a period when bathing and personal hygiene was greatly lacking, not as a part of personal hygiene. Perfumery as a distinct entity used strictly for its scent properties did not exist until about the 1800s.(1)
Rebuttal: There are actually considerable scientific data available to support bans on fragrances in certain environments. There is certainly enough evidence to support health, safety, and environmental concerns. A review of existing medical, scientific, and industry literature yields considerable data. Though in relationship to the use and exposure to fragrance materials, the available information is extremely sparse. This further reflects concerns of the fragrance industry's ability to adequately ensure the safety of its products with little oversight and regulation. These concerns are reflected by the analysis* of a popular perfume. Consider what chemicals are actually in a typical modern perfume. In 1999 several concerned individuals frustrated with the lack of available information had the popular fragrance Eternity by Calvin Klein analyzed by a company that is a member of the International Fragrance Association and specializes in the analysis of fragrance and flavors. Due to limited resources and the high cost of analysis, only one product could be analyzed. This particular perfume was chosen because it was frequently mentioned as triggering adverse symptoms and it was typical of modern products, which are very strong and long lasting. The analysis revealed substances that were present at levels down to .01% in the product. Forty-one substances were revealed. Available health and safety data was then researched on these materials. Available literature revealed that substances in the product included materials that were toxic, respiratory and skin irritants, respiratory and skin sensitizers, possible carcinogens, had central nervous system effects, and were possible hormone disruptors. The chemical, physical, and toxicological properties had not been thoroughly investigated on most of the materials. The material at the highest level; Iso E Super, a very common fragrance material, had no publicly available health and safety data.(4)
Based on this data the Environmental Health Network of California filed a petition [http://www.ehnca.org/www/FDApetition/bkgrinfo.htm] with the FDA asking that this perfume be declared misbranded because it contained materials, which the safety of had not be substantiated and it did not carry the warning label required by U.S. law. Over 900 comments/signatures have been sent in to the FDA supporting petition #99P-1340.(5) Though the FDA has not made a formal ruling on the petition, it has included in its year 2000 priorities the development of strategies to issue warnings for products formulated with ingredients for which the safety has not been established.(6)
Rebuttal: In order for there to be any resolution of problems, the industry must be willing to do much more than state its position. It must be willing to engage in open dialogue and address health, safety, and environmental concerns. It must refrain from using diversionary tactics to shift focus from well-established concerns to controversial health topics. Although health, safety, and environmental concerns have been raised for some time, the industry has chosen not to address these issues. Only since their profits and image have been threatened has there been any willingness to concede that fragrances can trigger health effects in some individuals.
Rebuttal: Due to trade secret status of fragranced products, regulation is extremely limited. Ingredients in the fragrance portion of the product do not have to be revealed to anyone, including regulatory agencies. Other than a handful of materials, virtually anything can be used as a raw fragrance material. Testing for safety and health effects are not required before marketing.(7,8) U.S. law requires a warning label on products when safety has not been substantiated for all the ingredients in the final product.(7) By its own admission, the fragrance industry has tested less than half of the over 3000 raw materials in use.(8) This law is not enforced as virtually no fragrance products carry the required warning. Canadian law requires that labels warn of any avoidable hazards associated with the product that the consumer should be aware of.(9) There are known skin sensitizers used in fragrances that can cause skin allergy. No warning of this known hazard appears on labels. After years of work by dermatologists, new labeling requirements regarding skin sensitizers in fragranced products are imminent in Europe. The extent of this labeling requirement has not yet been determined or at least not made public. The U.S. and Canada will probably follow the European Commission's lead in labeling skin sensitizers. (10)
Rebuttal: In order to gauge what rank an allergen has, there must first be a way of measuring this. In dermatology, fragrances rank as one of the most common allergens and the numbers of people with skin allergies to fragrance continue to rise. Given the airways and lungs are generally more susceptible than the skin to allergens, it is prudent to consider that fragrances may also rank high as respiratory allergens. There is no available testing for fragrances as respiratory allergens, so there is no way to determine whether fragrances are the worst offenders. Until such testing is available, the only way to gauge how problematic fragrances are is by clinical and patient accounts. Fragranced products are frequently cited as triggers for asthma, allergies, and other problems. Virtually every organization and agency concerned with respiratory health list fragrances as triggers for asthma.(11,12) Testing needs to be developed to determine which fragrance materials are respiratory allergens. Until problematic materials are pinpointed and are eliminated from use, or listed on the label, the only way to avoid exposure to problematic materials is to avoid all exposures to fragranced products. Further, fragrances are volatile compounds that add to indoor air pollution. Indoor air quality affects everyone; and those with asthma, allergies, sinus problems, and other respiratory disorders are much more severely impacted. On the basis of air quality issues alone, restrictions on the use of fragranced products are prudent.(13) In Nova Scotia, fragrance reduction policies are part of an over all effort to reduce exposure to indoor air pollutants of all types from numerous sources.
Rebuttal: Personal rights are very relative because we do not live in the world alone. When personal rights collide, there has to be an evaluation of the situation. It causes the user no harm to refrain from using a scented product. For those that have adverse reactions, such use can cause great harm. When actions by one triggers illness in another, which prevents access to work, health care, and essential services, whose rights are being violated?
Rebuttal: The only interest of those seeking to limit the use of fragranced products in public spaces is health -- hardly a "special interest." Perhaps the special interest is an industry that wishes to maintain the status quo and not have to account for the effects of the products it produces.
Rebuttal: Certainly education is a very important aspect. Before responsible use can be accomplished, responsible products must be available. Use of multiple scented products is encouraged by the industry making subtlety impossible. The same industry that says one's fragrance should not be detected more than an arm's length away produces products, which when used as directed, permeate a room for hours. "Materials that combine high odor volume with high inherent strength are diffusive, in that they can be smelled at a great distance and are very effective at the dry-out stage". (Calkin RR, Jellinek JS. Perfumery: Practice and Principles; pages (166-167) (Wiley 1994).) Columnist Leah Mclaren claims she deliberately applied numerous fragranced products and went to the waiting area of Halifax Children's Hospital which had a fragrance ban. This children's hospital serves many asthmatics and others affected by fragrance chemicals. There should be no debate over fragrance bans in medical facilities as health care should be accessible for all. Such actions by a few demonstrate how mean-spirited people can be. It only takes the actions of one person using fragrance to undo the efforts of many that are willing to be courteous and responsible.(14)
Rebuttal: Present testing protocols are inadequate. Testing of individual raw materials do not reflect real use condition. Synergistic and modifying effects must be considered. Testing should be expanded to include respiratory, neurological and systemic effects. There needs to be in place an industrywide means of reporting adverse reactions to fragrances with a contact number listed on labels of products. This data could then be used to pinpoint problematic products and materials. The present program, in place to help dermatologist pinpoint ingredients in products to which their patients have adverse reactions, needs to be expanded to include both other adverse effects and practitioners. Consumers need to be educated that fragrance may trigger and exacerbate well known medical conditions such as asthma, allergies, and migraines. Labeling to this effect also needs to be included. Products need to be formulated so they are less diffusive and intrusive to others. Functional products need to be less highly scented and more should be offered without fragrance, including masking fragrance. Perhaps most important of all, the fragrance industry must be willing to responsibly address concerns raised. Avoiding these issues will in the long run cause great harm to the industry. With the present levels of fragrance use, problems will continue to rise. Refusal to address concerns casts great doubt on the industry's ability to regulate itself. Cooperation with those that are having adverse effects could greatly help the industry in the long run. A panel composed of people from the industry, the medical and scientific community, and of those having adverse symptoms from fragrance material needs to be formed to formally identify concerns. It is only through hard work and cooperative efforts that these complex and important issues can be resolved.
2. AROMA CHEMICALS AND THE FLAVOR AND FRAGRANCE INDUSTRY., Chemical Economics Handbook.) p. 503.5000 A. Laszlo P. Somogyi, Birgitta Rhomberg, Yasuhiko Sakuma 3. Fundamentals of cosmetic product safety testing; Cosmetics and Toiletries; (v111 n10) Start Page: p79(7) ISSN: 0361-4387; Romanowski, Perry Schueller, Randy 4. Petiton #99-1340 filed with the FDA by the Environmental Health Network of California 5. Petition can be viewed at: http://www.ameliaww.com/fpin/Petition.htm [or http://www.ehnca.org/www/FDApetition/bkgrinfo.htm] or http://www.fda.gov/ohrms/dockets/dailys/051199/cp00001.pdf 6. CFSAN 2000 Program Priorities: U. S. Food and Drug Administration Center for Food Safety and Applied Nutrition February 10, 2000 7. U.S. Food and Drug Administration Center for Food Safety and Applied Nutrition Office of Cosmetics Fact Sheet February 3, 1995. "FDA Authority Over Cosmetics" 8. Nitro musks in fragrance products: an update of FDA findings.(includes related article on self-regulation by the fragrance industry) Cosmetics and Toiletries; June 1996 (v111 n6) Start Page: p73(4) ISSN: 0361-4387; Wisneski, Harris S. Havery, Donald C. 9. AVOIDABLE HAZARD - Section 24 of the Cosmetic Regulations (Food and Drugs Act) Canada 10. FRAGRANCE ALLERGY IN CONSUMERS: A REVIEW OF THE PROBLEM ANALYSIS OF THE NEED FOR APPROPRIATE CONSUMER INFORMATION AND IDENTIFICATION OF CONSUMER ALLERGENS: SCCNFP/0017/98 Final December 1999 11. American Lung Association: Asthma Magazine Article: Wheezing at Work -- The Office Can be Home to an Assortment of Asthma Triggers by: Dawn Marvin and Jackie Trovato http://www.lungusa.org/pub/ast_article4.html ) 12. JAMA: What Triggers Asthma? Education and Support Center http://www.ama-assn.org/special/asthma/support/educate/triggers.htm 13. The Analysis of Perfumes and their Effect on Indoor Air Pollution By John J. Manura Presented at EAS, Somerset, NJ., November 1998) 14. Non-scents in Nova Scotia; LEAH McLAREN; The Globe and Mail; Saturday, April 29, 2000)
SUMMARY OF SCIENTIFICALLY-BASED CONCERNS ON FRAGRANCE SAFETY 1. By all accounts the fragrance industry is primarily self-regulated. Part of this self-regulation includes testing and evaluating the safety of fragrance materials. 2. Testing by the fragrance industry primarily focuses on skin effects. Individually, raw materials are tested which do not reflect actual use conditions. Present testing often fails to identify allergens found in actual use and clinical testing. Less than half of the materials in use have been tested for skin effects. Testing for respiratory, neurological, and systemic effects are not done. 3. 1-2% of the population has skin allergies to fragrances and the incidence is rising.(1) There is a direct correlation between use and development of allergy. Materials used in combinations have synergistic and modifying effects.(2,3) The only way to avoid fragrance allergens is to avoid all use of fragranced products as it is impossible to know if a particular allergen is in a product. For those that have symptoms triggered by indirect contact and airborne allergens, avoiding personal use of products is not enough. What is on surfaces and in the air can trigger symptoms.(4) For these people skin allergies can be disabling. 4. Absorption through the skin is a pathway for fragrance materials in the body.(5) Several fragrance chemicals have been found to enhance dermal absorption and to greatly facilitate the absorption of other materials into the skin.(6,7) It is not known if these materials have a similar effect on the airways. If they do, it could help explain why fragrances are so problematic and provide a plausible explanation for the increased susceptibility to allergens such as mites, which have been around for centuries. This is an area that needs to be studied. 5. The vast majority of materials used in fragrances are respiratory irritants. There are a few that are known to be respiratory sensitizers. Most have not been evaluated for their effects on the lungs and the respiratory system. Respiratory irritants are known to make the airways more susceptible to injury and allergens, as well as trigger and exacerbate such conditions as asthma, allergies, sinus problems, and other respiratory disorders. With the increase in asthma and other respiratory disorders, reduction in exposures to irritants is essential. In addition, there are a subset of asthmatics that are specifically triggered by fragrances suggesting fragrances not only trigger asthma, they may also cause it in some cases.(8,9,10) A recent Institute of Medicine study sponsored by the EPA put fragrances in the same category as second hand smoke as a trigger for asthma in school-age children and above.(11) This is especially significant, as there are relatively few studies on respiratory effects of fragrances. This suggests that the data that is available is strong. The study also indicates more study is needed in this area. Fragrance materials are readily absorbed into the body via the respiratory system and once in the body can have systemic effects, which can effect other body systems.(12) 6. Migraine headaches are frequently triggered by fragrances. Fragrances are known to modify cerebral blood flow. Several common fragrance materials are known to have potent sedative effects via inhalation.(13) Recent studies suggest fragrance materials can act on the same receptors in the brain as alcohol and tobacco altering mood and function.(14) Materials that were widely used for decades in the past had severe neurotoxic properties and accumulated in body tissues.(15,16,17) In spite of this most fragrance materials have never been tested for neurological effects. Olfactory pathways provide a direct route to the brain.(18) 7. Synthetic musk compounds bioaccumulate in human tissue and are only slowly excreted. These materials are found in blood, adipose tissue, and breast milk.(19) 8. Phthalates, suspected of being hormone disrupters are used as fixatives at relatively high levels.(20) 9. Citral has been found to cause enlargement of the prostate gland in animal models and has estrogenic effects.(21) 10. Other fragrance materials are probable carcinogens.(22) 11. Several fragrance chemicals when inhaled affect the immune response of the skin.(23) The systemic and long- term effects of most fragrance materials are not known. 12. There are environmental concerns as well. Fragrances are volatile compounds and some of every fragrance product used gets into the air. Given the widespread use and sheer numbers of products used this has a serious impact on indoor air quality. Not only is indoor air impacted, outdoor air is as well. A recent in Norway found fragrance in outdoor air, even in a remote area.(24) 13. Air is not the only concern as synthetic musk compounds contaminate aquatic environments and wildlife all over the world. Wastewater treatment does not remove fragrance chemicals.(25) Many of these materials are persistent in the environment, while others act as persistent because of the constant influx of materials.(26)
There are other concerns as well, which are impossible to cover in a short amount of time and space. More information can be found at the Fragranced Products Information Network's website: http://www.ameliaww.com/fpin/fpin.htm or you can contact me personally at bcb56@ix.netcom.com
SELECTED BIBILIOGRAPHY of SCIENTIFICALLY-BASED CONCERNS RELATED TO FRAGRANCE SAFETY 2. Johansen JD, Skov L, Volund A, Andersen K, Menne T. Allergens in combination have a synergistic effect on the elicitation response: a study of fragrance-sensitized individuals. Br J Dermatol. 1998 Aug;139(2):264-70. PMID: 9767240; UI: 99068953 3. Ford RA. Studies of the quenching phenomenon. Contact Dermatitis. 1992 Jul;27(1):60-1.. PMID: 1424601; UI: 93047926 4. Hayakawa R, Matsunaga K, Arima Y. Airborne pigmented contact dermatitis due to musk ambrette in incense. Contact Dermatitis. 1987 Feb;16(2):96-8. PMID: 3568644; UI: 87188939 5. Hawkins DR, Ford RA. Dermal absorption and disposition of musk ambrette, musk ketone and musk xylene in rats. Toxicol Lett. 1999 Dec 20;111(1-2):95-103. PMID: 10630705; UI: 20094401 6. Zhao K, Singh J. In vitro percutaneous absorption enhancement of propranolol hydrochloride through porcine epidermis by terpenes/ethanol. J Controlled Release. 1999 Dec 6;62(3):359-66. PMID: 10528073; UI: 99459174 7. Kanei N, Tamura Y, Kunieda H. Effect of Types of Perfume Compounds on the Hydrophile-Lipophile Balance Temperature. J Colloid Interface Sci. 1999 Oct 1;218(1):13-22. PMID: 10489275 8. Norback D, Bjornsson E, Janson C, Widstrom J, Boman G. Asthmatic symptoms and volatile organic compounds, formaldehyde, and carbon dioxide in dwellings. Occup Environ Med. 1995 Jun;52(6):388-95.PMID: 7627316; UI: 95353437 9. Millqvist E, Lowhagen O. Placebo-controlled challenges with perfume in patients with asthma-like symptoms. Allergy. 1996 Jun;51(6):434-9. PMID: 8837670; UI: 96434746 10. Baur X, Schneider EM, Wieners D, Czuppon AB. Occupational asthma to perfume. Allergy. 1999 Dec;54(12):1334-5. PMID: 10688444; UI: 20151152 11. Clearing the Air: Asthma and Indoor Air Exposures; Committee on the Assessment of Asthma and Indoor Air, Division of Health Promotion and Disease Prevention, Institute of Medicine 12. Lorig TS. EEG and ERP studies of low-level odor exposure in normal subjects. Toxicol Ind Health. 1994 Jul-Oct;10(4-5):579-86. PMID: 7778116; UI: 95296964 13. Buchbauer G, Jirovetz L, Jager W, Plank C, Dietrich H. Fragrance compounds and essential oils with sedative effects upon inhalation. J Pharm Sci. 1993 Jun;82(6):660-4. PMID: 8331544; UI: 93322933 14. Aoshima H, Hamamoto K. Potentiation of GABAA receptors expressed in Xenopus oocytes by perfume and phytoncid. Biosci Biotechnol Biochem. 1999 Apr;63(4):743-8. PMID: 10361687; UI: 99290038 15. Spencer PS, Bischoff-Fenton MC, Moreno OM, Opdyke DL, Ford RA. Neurotoxic properties of musk ambrette. Toxicol Appl Pharmacol. 1984 Sep 30;75(3):571-5. PMID: 6474483; UI: 84301013 16. Spencer PS, Sterman AB, Horoupian DS, Foulds MM. Neurotoxic fragrance produces ceroid and myelin disease. Science. 1979 May 11;204(4393):633-5. PMID: 432669; UI: 79159581 17. Furuhashi A, Akasaki Y, Sato M, Miyoshi K. Effects of AETT-induced neuronal ceroid lipofuscinosis on learning ability in rats. Jpn J Psychiatry Neurol. 1994 Sep;48(3):645-53. PMID: 7891432; UI: 95198389 18. Hastings L, et al. Olfactory primary neurons as a route of entry for toxic agents into the CNS. Neurotoxicology. 1991; 12(4): 707-714. 19. Liebl B, Ehrenstorfer S. [Nitro-musk compounds in breast milk]. Gesundheitswesen. 1993 Oct;55(10):527-32. German. PMID: 8268706; UI: 94093258 20. Gray LE Jr. Xenoendocrine disrupters: laboratory studies on male reproductive effects. Toxicol Lett. 1998 Dec 28;102-103:331-5. Review. PMID: 10022274; UI: 99144872 21. Geldof AA, Engel C, Rao BR. Estrogenic action of commonly used fragrant agent citral induces prostatic hyperplasia. Urol Res. 1992;20(2):139-44. PMID: 1372772; UI: 92205895 22. NTP Reports: TR-491 Toxicology and Carcinogenesis Studies of Methyleugenol (CAS NO. 93-15-2) in F344/N Rats and B6C3F1 Mice (Gavage Studies) 23. Hosoi J, Tsuchiya T. Regulation of cutaneous allergic reaction by odorant inhalation. J Invest Dermatol. 2000 Mar;114(3):541-4. PMID: 10692115; UI: 20156590 24. Kallenborn R, et al. Gas chromatographic determination of synthetic musk compounds in Norwegian air samples, Journal of Chromatography A, 846 (1999) 295-306 25. Rimkus GG. Polycyclic musk fragrances in the aquatic environment. Toxicol Lett. 1999 Dec 20;111(1-2):37-56. Review. PMID: 10630702; UI: 20094398
26. Daughton CG, Ternes TA Pharmaceuticals and personal care products in the environment: agents of subtle change? Environ Health Perspect 1999 Dec;107 Suppl 6:907-38
Additional Resources 2. PMID: 10380782; UI: 99308489 3. Anderson RC, Anderson JH. Acute toxic effects of fragrance products. Arch Environ Health. 1998 Mar-Apr;53(2):138-46. PMID: 9577937; UI: 98237047 4. Fragrances: Beneficial and Adverse Effects; Frosch PJ, Johansen JD, White, IR: Wiley 1998 5. IFRA Code of Practice (International Fragrance Association 1997) 6. Engelstein D, Shmueli J, Bruhis S, Servadio C, Abramovici A. Citral and testosterone interactions in inducing benign and atypical prostatic hyperplasia in rats. Comp Biochem Physiol C Pharmacol Toxicol Endocrinol. 1996 Oct;115(2):169-77. PMID: 9568365; UI: 98229786 7. Muller S, Schmid P, Schlatter C. Occurrence of nitro and non-nitro benzenoid musk compounds in human adipose tissue. Chemosphere. 1996 Jul;33(1):17-28. PMID: 8680828; UI: 96290864 8. Meador JP, Stein JE, Reichert WL, Varanasi U. Bioaccumulation of polycyclic aromatic hydrocarbons by marine organisms. Rev Environ Contam Toxicol. 1995;143:79-165. Review. PMID: 7501868; UI: 96118717 9. Kumar P, Caradonna-Graham VM, Gupta S, Cai X, Rao PN, Thompson J. Inhalation challenge effects of perfume scent strips in patients with asthma. Ann Allergy Asthma Immunol. 1995 Nov;75(5):429-33. PMID: 7583865; UI: 96075514 10. Scolnik M, Konichezky M, Tykochinsky G, Servadio C, Abramovici A. Immediate vasoactive effect of citral on the adolescent rat ventral prostate. Prostate. 1994 Jul;25(1):1-9. PMID: 8022706; UI: 94294277 11. RIFM 1992 Cross Reference List (Research Institute of Fragrance Materials 1992) 12. Cone JE, Shusterman D. Health effects of indoor odorants. Environ Health Perspect. 1991 Nov;95:53-9. PMID: 1821378; UI: 92331555 13. Ford RA, Api AM, Newberne PM. 90-day dermal toxicity study and neurotoxicity evaluation of nitromusks in the albino rat. Food Chem Toxicol. 1990 Jan;28(1):55-61. PMID: 2312014; UI: 90185485 14. Meynadier JM, Meynadier J, Peyron JL, Peyron L. [Clinical forms of skin manifestations in allergy to perfume]. Ann Dermatol Venereol. 1986;113(1):31-41. French. PMID: 3706986; UI: 86213586 15. Shim C, Williams MH Jr. Effect of odors in asthma. Am J Med. 1986 Jan;80(1):18-22. PMID: 3079951; UI: 86100530
16. Opdyke DL.
Safety testing of fragrances: problems and implications.
Clin Toxicol. 1977;10(1):61-77. PMID: 858226; UI: 77161141
Canadian Cosmetic, Toiletry and Fragrance Association (CCTFA) and the Scented Products Education and Information Association of Canada (SPEIAC)
By Betty Bridges, RN The fragrance industry, concerned about the efforts in Halifax to educate and implement voluntary fragrance free policies, has launched a public relations campaign. The Canadian Cosmetic, Toiletry and Fragrance Association (CCTFA) and the Scented Products Education and Information Association of Canada (SPEIAC) are organizing a media campaign to explain their position and counteract the concerns raised by those who see fragrances as a health concern. The CCTFA and SPEIAC held a meeting on June 20 in Halifax, Nova Scotia to address industry concerns over "anti-scent" policies. Invited to this meeting were delegates from Health Canada, scientific community, Halifax area public policy-makers, and individuals representing anti-scent movement. Several organizationsÝ in Canada were invited to send someone representing their groups. Albert Donnay of MCS Referral and Resources andÝ Betty Bridges, RN of the Fragranced Products Information Network were invited by the Environmental Illness Society of Canada (EISC) and The Nova Scotia Allergy and Environmental Health Association (NSAEHA) as their representatives. The presentations by CCTFA and SPEIAC focused on what they termed as "myths" about fragrances. There was a brief review of the "self-regulatory" process of the fragrance industry. It was also contended that there are no scientific data to support bans and health concerns related to fragranced products. Very little information was presented to dispell concerns and little to no scientific data was presented. There was a question and answer period after the presentation. The industry was unable to provide adequate answers to the questions posed.
A fragrance industry press conference was held after this. The Environmental Illness Society of Canada (EISC) and The Nova Scotia Allergy and Environmental Health Association (NSAEHA) as well as their representatives were not allowed into the industry press conference. But having attended the earlier press conference, the media was able to ask many of the hard questions and the industry's answers were often lacking. The media coverage has been quite good and over all, balanced. Both views have been presented. In the balance those concerned about fragrance safety have presented a great deal of scientific data to support concerns and the industry has present little other than public relations materials. This has greatly increased the visability of this issue, which is important.
Betty Bridges, RN
does not want you to know A rebuttal to the fragrance industry's publicity campaign By Betty Bridges, RN Halifax, Nova Scotia has been at the forefront of efforts to educate and increase awareness of health issues related to exposures to fragranced products. Realizing this was not an issue that was going to go away and indeed may spread to other areas, the fragrance industry launched a publicity campaign to discount health concerns that have been raised. The fragrance industry has found itself in a rather difficult position. It must appear sympathetic toward those claiming fragrances have negative consequences, while discounting the validity of what they are saying. On June 20, 2000 the industry came to Halifax to launch their publicity campaign. The Scented Product Education and Information Association of Canada (SPEIAC) sponsored an "education" forum in which representatives from Health Canada, the scientific community, Halifax policy makers, and individuals representing the anti-scent movement were invited. The press was not invited to this forum; instead a press conference was scheduled for later that morning. The forum consisted of a presentation by the fragrance industry representatives: Carl Carter of the Scented Product Education and Information Association of Canada (SPEIAC) and William R. Troy, Ph.D., Chair, Scientific Advisory Committee of the Fragrance Materials Association. Charles Low of the Canadian Cosmetic, Toiletry and Fragrance Association moderated the meeting. The industry contends that there is no scientific basis for fragrance bans, either voluntary or mandatory. After the presentation there was an opportunity for questions to be asked, but no opportunity for advocates of scent reduction policies to present the considerable scientific data that are available. Since no opportunity was given during the forum to formally present this scientific data to the industry, a point by point examination of the materials presented and questions raised by the industry's press release and ad follows. The public has a right to more than "sound bits" and publicity campaigns on which to base their opinions and health decisions. Response to SPEIAC Press Release and Ad Campaign
Assertion 1:
Reply:
Assertion 2:
Reply:
Assertion 3:
Reply:
Assertion 4:
Reply: Testing by the RIFM focuses on acute and oral toxicity as well skin effects. Testing is not routinely done for respiratory, neurological, and/or systemic effects. William "Bill" Troy, Ph.D. is a reputable scientist. He was working at Avon in 1975 when, during routine animal patch skin testing, it was discovered that something in the product was turning the skin of the animals blue. Further testing revealed that the chemical Acetylethyltetramethyltetralin (AETT) caused serious neurological conditions and discoloration of the skin and organs of animals and also penetrated the skin of humans. If there had not been a change in skin color, it may not have been discovered that this material was neurotoxic. Avon was the only company that used AETT whose testing discovered it posed a serious health risk. This material was widely used in fragrances and also used in lesser amounts in flavors. This demonstrates that present testing is not adequately protecting the public. AETT had been in common use for over 20 years when this discovery was made in 1975. Neither the company originally producing the material, nor any other companies using it had discovered it was severely neurotoxic. The industry "voluntarily" withdrew the material from use in 1977, with one company continuing to use it until 1978. There was no recall of products on the shelf or public notification. Usually the RIFM does not evaluate raw materials for safety until the patent expires. This means materials can be in common use for close to 20 years before being evaluated outside of the company producing them. Most of the testing done within a company is never made public. Once a material has been in use that long, it is often assumed to be safe, and other companies may mistakenly assume it has been adequately tested. Indeed the RIFM often uses the manufacture's data in the evaluation process. This also means that many of the newer synthetics that have been developed in the past few decades have not been independently evaluated. This is of special concern, because many of these materials are used at much higher levels than traditional materials. Much has been learned over the past few decades. It is now known that many materials once considered safe are not. More is known about toxicity and dangers than was known even a decade ago. Much more aggressive evaluation is necessary, not only of singular chemicals, but also combinations that are in common use. Neurological, respiratory, and systemic testing are needed. To contend that "there is no proof our products are not safe" is hardly the attitude expected from AN industry that is able to regulate itself. If the industry wants to continue to self-regulate and avoid increasing regulation it must leave no doubt that the products are safe for the user, those inadvertently exposed, and the environment.
Assertion 5:
Reply: Only the basic composition, such as the percentage of alcohol to the percentage of fragrance, has remained mostly unchanged. The "fragrance" portion of the product; however, is considerably different than it was even 30 years ago. In general, newer formulations are primarily made of synthetic fragrance oils, not essential oils from plants. History of use does not apply when newer materials are used and when the applications for these materials are different.
Assertion 6:
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Assertion 7:
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Assertion 8:
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Assertion 9:
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Assertion 10:
Reply: It must be further considered that because of the widespread use of many fragranced products both in personal and environmental applications there is always a background of "fragrance" in the air. Considering only singular products does not adequately address the problems. Air fresheners, scented cleaners, laundry products, and toiletries as well as products such as perfumes that are used primarily for scent must be taken into account. Many fragranced products are deliberately formulated to be high impact. This means they diffuse into the air quickly and can be detected even before encountering the individual wearing them and long after that individual has left. It is ironic that the industry is advocating a solution that it should know will never work.
Betty Bridges,RN bcb56@ix.netcom.com
NOTE: SPEIAC held its own press conference. However the activists from NSAEHA, EISC, MCS R&R and FPIN were not allowed to attend. Reportedly, it broke up earlier than anticipated as the industry had no concrete facts. It is interesting to note that SPEIAC was invited to the press conference joinly held by NSAEHA, EISC, MCS R&R and FPIN. -- barb News Release: For Immediate Release ANTI-SCENT POLICIES ARE NOT BASED ON FACTS, SAYS SCENT EDUCATION ASSOCIATION Halifax, June 20, 2000 - Policies to discourage the use of scented products are not based on fact, says the Scented Product Education and Information Association of Canada (SPEIAC). The Association today announced that it is sponsoring a public education program in the Halifax region over the coming month to address the lack of accurate information on the subject. "The anti-scent policies - both formal and informal - that are prevalent in the Halifax area appear to be based on an appalling lack of factual information," said Carl Carter, Communications Director of SPEIAC. "It's time to get the facts straight and put an end to the sensational claims that are being made by advocates of scent bans." "We respect the fact that some individuals appear to react excessively to many common everyday substances, including scented products," continued Carter. "At the same time, we also know that scented products are as safe as the foods we eat, and the many other products we use in everyday life." "Responsible public policy-making should be based on accurate information and the best available accepted science," said Carter. "That is why SPEIAC is making an effort to correct the misinformation that is being circulated." The Association today sponsored an education forum with delegates invited from Health Canada and the scientific community, together with Halifax area public policy-makers and individuals representing the anti-scent movement. A presentation by Bill Troy, Chair of the Scientific Advisory Committee of the Fragrance Materials Association (FMA) explained the steps taken to ensure the safety of fragrance materials and the type of testing that is done. "Fragrance industry associations around the world work closely with the Research Institute for Fragrance Materials, an international, independent organization devoted to evaluating the safety of fragrance ingredients," said Troy. "This is a responsible industry that takes safety seriously." In addition to the forum, SPEIAC will be sponsoring public education advertising in the two major Halifax newspapers over the coming month. "The advertising campaign is designed to get the facts out about scented products and safety," said Carter. Fragrances are primarily composed of water and grain alcohol - of the same type and purity we drink in beverages - together with essential fragrance oils. This basic composition has remained unchanged for hundreds of years.** "People need to know that the ingredients in scented products are tested for safety and that fragrance formulations do not contain the dangerous substances that some people are claiming," continued Carter. "They also need to know that just because a material is synthetic doesn't mean it is harmful. The safety of a substance is not determined by whether it is of synthetic or natural origin. In fact, synthetic materials are often purer and help us preserve natural resources. "These are just a couple of examples of the erroneous beliefs that are the basis of informal, but widespread, public policies in the region," said Carter. "But public policy should be based on accurate information - not beliefs. This is vital to the protection of individual rights and freedoms." SPEIAC continues to advocate responsible use of scented products and advises that everyone has a personal scent circle about arm's length from the body. The Association recommends exercising restraint when using scented products so that it is not noticeable outside your scent circle. -30-
For more information, visit the SPEIAC Web site at SPEIAC Ad
The first of the fragrance industry's ads. (Linked to 6/24/00 **)
"The answers to these questions should be based on facts - not beliefs. That's the only way to create responsible practices that respect individual rights and freedoms."
"Fragrance formulations do not contain toxic ingredients such as carcinogens or neurotoxins. And, I'm afraid the information in the industry's ad about the formulation of modern synthetic fragrances simply doesn't square with information available through the petition that is currently before the US Food and Drug Administration. Specifically, see Analyses at http://www.ehnca.org/www/FDApetition/bkgrinfo.htm#Analyses For the entire petition, please visit http://www.ehnca.org/www/FDApetition/bkgrinfo.htm
Nor does SPEIAC's statements square with the information available through PerfumersWorld http://www.perfumersworld.com/index.html Also, do check out their FAQs, Question & Answer Guide http://www.fragrance.org/feature_faqtext.html Let me assure you, people do apply and reapply throughout the day, just as they are told to do by the industry. Is there any wonder there is SBS (Sick Building Syndrome)? These products are volatile organic compounds, and are recognized air pollutants. See NIEHS's Common Indoor Air Pollutants http://www.niehs.nih.gov/external/faq/indoor.htm
-- barb
http://www.perfumersworld.com/chems/material.htm
A closer look at chemicals in fragrances, which the industry in Halifax and in their ad, claimed aren't in fragrances
Cosmetics Prohibited sales of cosmetics 16. No person shall sell any cosmetic that (a) has in or on it any substance that may cause injury to the health of the user when the cosmetic is used,
(ii) for such purposes and by such methods of use as are customary or usual therefor; (b) consists in whole or in part of any filthy or decomposed substance or of any foreign matter; or (c) was manufactured, prepared, preserved, packaged or stored under unsanitary conditions.
Where standard prescribed for cosmetic 17. Where a standard has been prescribed for a cosmetic, no person shall label, package, sell or advertise any article in such a manner that it is likely to be mistaken for that cosmetic, unless the article complies with the prescribed standard. http://canada2.justice.gc.ca/ftp/en/Laws/Chap/F/F-27.txt
US Food and Drug Administration - Cosmetics To get to US Codes: From http://uscode.house.gov/usc.htm enter "21" in "Title" box and "361" in 'Section" box, click Search. Click on the document that appears in their next screen. When finished with the US Codes, just click the close box to return to this page. -- barb [Title 21] Sec. 361. Adulterated cosmetics -STATUTE- A cosmetic shall be deemed to be adulterated - (a) If it bears or contains any poisonous or deleterious! substance which may render it injurious to users under the conditions of use prescribed in the labeling thereof, or under such conditions of use as are customary or usual, except that this
provision shall not apply to coal-tar hair dye, ... -----
!Query from barb: Folks, just what is it I'm missing here? [Title 21] Sec. 362. Misbranded cosmetics -STATUTE- A cosmetic shall be deemed to be misbranded - (a) If its labeling is false or misleading in any particular. (b) If in package form unless it bears a label containing (1) the name and place of business of the manufacturer, packer, or distributor; and (2) an accurate statement of the quantity of the contents in terms of weight, measure, or numerical count: Provided, That under clause (2) of this paragraph reasonable variations shall be permitted, and exemptions as to small packages shall be established, by regulations prescribed by the Secretary. (c) If any word, statement, or other information required by or under authority of this chapter to appear on the label or labeling is not prominently placed thereon with such conspicuousness (as compared with other words, statements, designs, or devices, in the labeling) and in such terms as to render it likely to be read and understood by the ordinary individual under customary conditions of purchase and use. ...
21 CFR 740.10 COSMETIC PRODUCT WARNING STATEMENTS Note: This link will open a new page; when finished reading, just click the close box to return to this page. Also, once into the FDA page, scroll to "740.10 " or use your find command. -- barb
Subpart B--Warning Statements (a) Each ingredient used in a cosmetic product and each finished cosmetic product shall be adequately substantiated for safety prior to marketing. Any such ingredient or product whose safety is not adequately substantiated prior to marketing is misbranded unless it contains the following conspicuous statement on the principal display panel:
Additional information about EI/MCS, Indoor Air Quality, Scents, ... is avaiable through -- There's a lot of valuable information available through this site! -- barb http://www.environmentalhealth.ca/
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perfume, fragrances -- The Environmental Health Network (EHN) [of California] is a 501 (c) (3) non profit agency and offers support and information for the chemically injured. Learn about the toxicity of fragrances from the work of Julia Kendall and Betty Bridges, RN, get The BEST of the Reactor, join EHN and receive The New Reactor. See what influence the Chemical Manufacturers have had against those of us with EI. The URL for this page is http://www.ehnca.org