March 22, 2012
GM (Genetically Modified) Eucalyptus is one step closer
This is not a new story, but merely another step in the historical process of moving agriculture towards the use of GM in aromatic plants (Although this Eucalyptus is being developed for timber and not for making essential oil.)
The Institute of Science in Society reports on their website on the latest news in the saga of GM Eucalyptus approval for field testing. In an article ‘Confined’ field releases of Eucalyptus neither confined nor safe scientists at ISIS have criticized the Environmental Analysis process on grounds “uninformed prejudice and hiding crucial details”. The two Eucalyptus species (E. Grandis) and (E. urophylla) that have been hybridized and then cloned are not generally considered to be of aromatic use, but are used for timber. An American Corporation ArborGen has applied for permission to release the clone into the environment in the southeastern US to test how well their genetic modifications work. ISIS does not believe that the Environmental Assessment has adequately addressed a number of important issues. They have asked for wide circulation of their information and granted blanket permission for reproduction, so the aromaconnection is reposting the entire post here so that our readers can see for themselves some of the issues that will arise if genetically modified plants are used. A major part of the concern is the lack of transparency as well as potential safety issues.
ISIS Report 21/03/12
Please circulate widely and repost, but you must give the URL of the original and preserve all the links back to articles on our website
‘Confidential Business Information’ makes a mockery of risk assessment
An application from ArborGen has taken a sinister turn in declaring most, if not all of the genetically modified (GM) constructs in a Eucalyptus hybrid clone to be tested in environmental release ‘Confidential Business information’, thereby precluding any meaningful independent safety and environmental assessment of the GM trees, or appropriate remedial action and identification in case of harm caused to the environment and innocent bystanders. The USDA/ APHIS (United States Department of Agriculture/Animal and Plant Health Inspection Service) has yet again made a highly flawed Environmental Assessment (EA) on the proposed release, dismissing every issue on safety largely on a priori assumptions and in the absence of real data .
ArborGen, LLC, based in Summerville, South Carolina, has applied for the ‘confined’ environmental release of the clone EH1 of a Eucalyptus grandis × Eucalyptus urophylla hybrid genetically modified with various constructs at six locations encompassing a total of 14.7 acres in the States of Alabama, Florida, Mississippi, and South Carolina . (As of September 2011, ArborGen is growing a total of approximately 67 acres of GM trees on 18 of the 32 permitted locations.) Five of the locations for the current release already have active APHIS permits for GM trees granted previously. The sixth site in South Carolina has been listed as a holding site for GM trees in previous APHIS permits and notifications, and is a new location for the release of GM Eucalyptus. ArborGen is requesting that trees be allowed to flower at four locations in Alabama, Florida and Mississippi. At two locations in South Carolina, ArborGen has requested to release trees in containers and have indicated they will not allow the trees to flower.
The stated purpose of the field release is to assess the effectiveness of different gene constructs intended to confer cold tolerance, to alter lignin biosynthesis, to alter growth rate, along with testing the efficacy of the barnase gene designed to alter fertility. In addition, the trees have been engineered with a selectable marker that confers resistance to the antibiotic kanamycin. With the exception of the C-Repeat Binding Factor (CBF) gene (see later), the barnase gene, and nptII gene, all genes are claimed as Confidential Business Information (CBI), even though they are different constructs from those in trees previously permitted for environmental releases by APHIS.
The designation of the majority of transgenic modifications CBI certainly prevents any rational, independent evaluation of the impact of those genes and the GM Eucalyptus on the environment, and on human and animal health. Unfortunately, USDA does not appear to have a mechanism for identifying and discarding frivolous CBI designations. The avalanche of CBI designations of transgenic crop and tree modifications suggests that the designation is being used to avoid doing proper risk assessment and also making it impossible for independent risk assessments that could otherwise be done; and in addition, prevent the detection of adverse side effects due to the modifications, which would also make it impossible to take appropriate remedial action. This is clearly unacceptable for protection of public health and the environment. The USDA should open the CBI designations to independent adjudication.
A number of risks were assessed in a perfunctory fashion and dismissed based to varying degrees on a priori assumptions in the absence of real data from dedicated investigations.
Alteration in susceptibility to diseases or insects
This was dismissed largely on basis of the statement in ArborGen’s application that “none of the genes being engineered into the Eucalyptus plants are expected to alter the susceptibility of the transgenic Eucalyptus plants to disease of insect damage.”
We have previously pointed out that reducing lignin in trees would make them more susceptible to attack by insects and pathogens (see  Low Lignin GM Trees and Forage Crops, SiS 23).
Risks from transgenes
Kanamycin resistance Risks from the kanamycin resistance gene is dismissed even though we have pointed out that kanamycin is still in clinical use and also kanamycin resistance cross-reacts with new antibiotics  (Kanamycin Still Used and Cross-Reacts with New Antibiotics, ISIS Report).
Cold tolerance C-Repeat Binding Factor (CBF) genes are transcription factors belonging to the AP2/EREBP family of DNA binding proteins, which recognize a cold- and drought-responsive DNA regulatory sequence designated the C-repeat (CRT)/dehydration-responsive element (DRE), found in the promoter regions of many cold-inducible genes. When CBF genes are overpressed constitutively, as when placed under the control of the CaMV 35S promoter, it was associated with stunting, reduced flowering and lack of tuber production in potatoes. However, when the CBF gene was placed under the control of a cold-induced promoter, rd29A, it increased tolerance to freezing while restoring growth and tuber production to wild-type levels. The GM Eucalyptus trees tested have the CBF gene under the control of a cold inducible promoter, which causes the gene to be expressed only when cold, and hence “not expected to produce any toxic substance and is not expected to alter the characteristics of the engineered plants”.
This large assumption is far from justified as the Eucalyptus version, EguCBF1, when over expressed, not only results in cold tolerance, but also increased water retention, higher oil gland density and wax deposition, and over expression of anthocyanin pigments . The gene network influenced by CBF gene modification produces highly pleiotropic effects. But there does not appear to have been any investigation on the production of unintended metabolites, proteins, or nuclei acids in the modified trees, all of which could have health and environmental impacts.
Gene for altered fertility We have commented on the dangers of the barnase gene on numerous previous occasions, most recently in 2008  USDA FONSI for Transgenic Poplars Absurd & Dangerous, SiS 38). It is a well-known cytotoxic protein that breaks down RNA. Because they are from a soil bacterium, and unrelated to any mammalian RNAses, they are not susceptible to eukaryotic RNAse inhibitors. Consequently, they are highly toxic, and are actually being engineered currently as a means of killing cancer cells . But USDA has dismissed the dangers of this gene in the current EA as in previous EAs. This is unconscionable. Although the barnase is being used to prevent pollen formation, this is not 100 effective, and many beneficial insects and other wild-life could well be affected.
Apart from the above genes, the genes for altered lignin (3 of them), genes for altered growth (4), non-coding sequences (undisclosed number derived from plants and plant pathogens), were all not mentioned or explicitly not disclosed under CBI, and consequently, not risk assessed at all before stating that they are not expected to pose any risks.
Mode of transformation and hazards of horizontal gene transfer
One aspect that needs to be highlighted is the mode of transformation of the GM Eucalyptus involved Agrobacterium. This is a serious unresolved hazard in genetic modification that we have drawn attention to for years, most recently in 2011  Scientists Discover New Route forGM-gene 'Escape' (SiS 50). Research commissioned by the UK Department of the Environment, Food and Rural Affairs (DEFRA) in the 1990s had already revealed that it is very difficult, if not impossible to get rid of the Agrobacterium vector used in creating the transgenic plant. The bacterium is likely to remain dormant even after the transgenic plants are transplanted into the soil. Hence, it is expected to facilitate horizontal gene transfer, in the first instance, to wild-type Agrobacterium in the soil, and further afield, to other bacteria and fungi in the soil. It now transpires that Agrobacterium can enlarge their host range to infect other species and exchange genes with them through hormones produced at the site of plant wounds ( Scientists Discover New Route for GM-gene 'Escape', SiS 50).
The applicant has indicated that they are not aware of any commercial plantings of sexually compatible Eucalyptus species within 1 000 meters of the proposed test plot location at any of these sites. Therefore, based upon the limited distance that viable pollen is likely to occur outside a tree stand, it is deemed highly unlikely that gene flow would occur outside of the confined field test sites at these locations. An Australian study, however, found that remnant populations of Eucalyptus were connected by pollen dispersal to pollen sources up to 1.94 kilometers away .
It is by now obvious that transgenes can also spread horizontally to all species interacting with the trees and pollen, in the air, in the soil and in the water, as we have repeatedly pointed out to regulators . Needless to say, horizontal gene transfer was dismissed.
Deadly yeast in Eucalyptus
Cryptococcus neoformans gattii is a yeast pathogen hosted by a variety of Eucalyptus species as well as other tree species. It causes systemic fungal infections in humans, leading to fungal meningitis and death. C. neoformans gattii has been found on a number of Eucalyptus hosts, some being grown in commercial plantations and imported and exported for ornamental use. People have contracted and died from cryptococcosis in India, Africa, Taiwan, South America and California. C. neoformans gattii infections are found particularly in AIDS patients due to their weakened immune systems. Infections with this fungus are rare in those with fully functioning immune systems. For this reason, C. neoformans gattii is sometimes referred to as an opportunistic fungus. There was an outbreak of cryptococcal disease on the eastern part of Vancouver Island, British Columbia in 1999. The disease was previously only known to occur in tropical or semi-tropical climates. The risk that these field trials will result in a higher incidence of the fungus in the US and thereby pose a risk to human health is considered negligible for the following reasons. First, there is not a clear association between E. grandis or E. urophylla and C. gattii. Second, there is no reason to believe that the genetic modification of the hybrids will alter the association of the trees with C. gattii. Third, the scale of the field tests is miniscule compared to the vast expanses of native trees that could potentially harbour the pathogen .
But there is already evidence among forest or urban trees that Eucalyptus species are homes for the deadly yeast. Furthermore, there is no vast expanse of native species in the US that are homes for the toxic yeast, according to the peer reviewed scientific publications [11-13]. The deadly yeast should have been studied in the transgenic trees rather than being groundlessly and a priori dismissed by USDA.
Issues raised in previous submissions on transgenic Eucalyptus still unresolved
The Institute of Science in Society previously submitted several briefs objecting to environmental releases of GM Eucalyptus, and dealing with other issues in more detail, such as the alteration in susceptibility to disease or insects , the potential of the Eucalyptus to harbour plant pests, the kanamycin resistance selectable marker gene, the barnase gene, genes for altered lignin, and the deadly yeast C. gattii [14-15] Field Testing Genetically Engineered Eucalyptus: Environment Assessment Still Inadequate, SiS 46, GM Eucalyptus Environmental Assessment Irregular, SiS 35]. None of the issues we raised have been properly addressed, let alone resolved.
We can only repeat our call  for a Moratorium on all GM Trees and Ban on GM Forest Trees (SiS 35).
- DEPARTMENT OF AGRICULTURE Animal and Plant Health Inspection Service [Docket No. APHIS–2011–0130] ArborGen, LLC; Availability of an Environmental Assessment for Controlled Release of a Genetically Engineered Eucalyptus Hybrid Federal Register Vol. 77, No. 28 Friday, February 10, 2012 Notices 7123.
- Eck C. Permit application 11-052-101rm received from ArborGen Field testing of genetically engineered Eucalyptus grandis X Eucalyptus urophylla Draft Environmental Assessment December 6, 2011 http://www.aphis.usda.gov/brs/aphisdocs/11_052101rm_pea.pdf
- Cummins J. Low lignin GM trees and forage crops. Science in Society 23, 38-39, 2004.
- Cummins J. Kanamycin still used and cross-reacts with new antibiotics. ISIS report, 27 May 2001, http://www.i-sis.org.uk/kanomycin.php
- Navarro M, Ayax C, Martinez Y, Laur J, El Kayal W, Marque C, Teulières C. Two EguCBF1 genes overexpressed in Eucalyptus display a different impact on stress tolerance and plant development. Plant Biotechnol J 2011, 9(1), 50-63.
- Cummins J and Ho MW. USDA FONSI for transgenic poplars absurd & dangerous. Science in Society 38, 40-41, 2008.
- Ulyanova V, Vershinina V and Ilinskaya O. Barnase and binase: twins with distinct fates. The FEBS Journal 2011, 3633-43.
- Ho MW. Scientists discover new route for GM-gene ‘escape’. Science in Society 50, 14-16, 2011.
- Knight CJ, Bailey AM, Foster GD. Investigating Agrobacterium-mediated transformation of Verticillium albo-atrum on plant surfaces. PLOS ONE 2010, 5(10): e13684. Doi:10.1371/journal.pone.0013684
- Sampson JF, Byrne M. Outcrossing between an agroforestry plantation and remnant native populations of Eucalyptus loxophleba. Mol Ecol 2008, 17(11), 2769-81.
- Chen M, Liao WQ, Wu SX, Yao ZR, Pan WH, Liao Y. Taxonomic analysis of cryptococcus species complex strain S8012 revealed Cryptococcus gattii with high heterogeneity on the genetics. Chin Med J (Engl). 2011, 124(13), 2051-6.
- Chowdhary A, Randhawa HS, Boekhout T, Hagen F, Klaassen CH, Meis JF. Temperate climate niche for Cryptococcus gattii in Northern Europe. Emerg Infect Dis. 2012, 18(1), 172-4. doi: 10.3201/eid1801.111190
- Crous PW, Groenewald JZ, Shivas RG, Edwards J, Seifert KA, Alfenas AC, Alfenas RF, Burgess TI, Carnegie AJ, Hardy GE, Hiscock N, Hüberli D, Jung T, Louis-Seize G, Okada G, Pereira OL, Stukely MJ, Wang W, White GP, Young AJ, McTaggart AR, Pascoe IG, Porter IJ, Quaedvlieg W. Persoonia 2011, 26, 108-56.
- Cummins J. Field testing genetically Engineered Eucalyptus: rnvironment assessment still inadequate. Science in Society 46, 36, 2010.
- Cummins J and Ho MW. GM eucalyptus environmental assessment irregular. Science in Society 35, 50, 2007.
- Cummins J and Ho MW. Moratorium on all GM trees and ban on forest trees. Science in Society 35, 32-34, 2007.
April 19, 2011
The Cacao Story Continues
In February 2008, I was moved by the investigative journalism of Christian Parenti, of The Nation surrounding child labor in Cote d'Ivoire. I did this blogpost at the time after further research into this disturbing issue.
As the Ivory Coast and other African and Arab nations now fall into civil war and political/cultural disruption, this issue has not yet been addressed and conditions for the children have not changed, now worsened by child trafficking from other African nations into Cote d'Ivoire specifically as slaves to harvest the cacao.
This documentary video produced by Helle Faber of Denmark from last year is evidence that the conditions for children in the region are worsening.
April 16, 2010
“Safe Chemicals Act of 2010”
Joined by Congressmen Henry Waxman and Bobby Rush, New Jersey Senator Frank Lautenberg introduced new legislation that would overhaul 1976 polyester era Toxic Substances Control Act.
"This is a complex issue, and we compliment Senator Lautenberg and Congressmen [Henry] Waxman and [Bobby] Rush for bringing focus to the need for modernization of the TSCA," said Cal Cooley, president of the American Chemistry Council, in a statement.
“Green groups would say that's an understatement. The TSCA grandfathered in more than 60,000 industrial chemicals that were already in use in 1976, with no safety testing, including chemicals like bisphenol-A, the endocrine disruptor that more recent studies have shown could have a serious impact on developmental health. New chemicals went straight to the marketplace with little government oversight — in the 34 years since the TSCA was enacted, the EPA has required testing for only 200 chemicals out of the more than 80,000 available for use in the U.S., and has regulated only five”, reports Time Read more.
Press Release of Senator Lautenberg
Lautenberg Introduces "Safe Chemicals Act" to Protect Americans from Toxic Chemicals
Measure Will Require Safety Testing for Chemicals
Contact: Lautenberg Press Office (202) 224-3224
Thursday, April 15, 2010
WASHINGTON, DC - U.S. Senator Frank R. Lautenberg (D-NJ) today announced legislation to overhaul the “Toxic Substances Control Act of 1976” (TSCA), an antiquated law that in its current state, leaves Americans at risk of exposure to toxic chemicals. Lautenberg, who chairs the Senate Subcommittee on Superfund, Toxics and Environmental Health, introduced the “Safe Chemicals Act of 2010” to protect the health of families and the environment.
“America’s system for regulating industrial chemicals is broken,” said Senator Lautenberg. “Parents are afraid because hundreds of untested chemicals are found in their children’s bodies. EPA does not have the tools to act on dangerous chemicals and the chemical industry has asked for stronger laws so that their customers are assured their products are safe. My 'Safe Chemicals Act' will breathe new life into a long-dead statute by empowering EPA to get tough on toxic chemicals. Chemical safety reform is not a Democratic or Republican issue, it is a common-sense issue and I look forward to building bipartisan support for this measure.”
The “Safe Chemicals Act of 2010” requires safety testing of all industrial chemicals, and puts the burden on industry to prove that chemicals are safe in order stay on the market. Under current policy, the EPA can only call for safety testing after evidence surfaces demonstrating a chemical is dangerous. As a result, EPA has been able to require testing for just 200 of the more than 80,000 chemicals currently registered in the United States and has been able to ban only five dangerous substances. The new legislation will give EPA more power to regulate the use of dangerous chemicals and require manufacturers to submit information proving the safety of every chemical in production and any new chemical seeking to enter the market.
Over the last several months, Sen. Lautenberg has chaired a series of hearings to help craft the “Safe Chemicals Act” with dozens of witnesses including business leaders, public officials, scientists, doctors, academics, and non-profit organizations. Through the hearings, public health groups, environmentalists, industry representatives and the EPA have expressed support for reforms to our nation’s toxic substance laws. The “Safe Chemicals Act of 2010” comports with the reform principles laid out by the Obama Administration, the American Chemistry Council and the Safer Chemicals Healthy Families Coalition.
The text of the "Safe Chemicals Act of 2010" can be found here and a full summary of the bill can be found here.
Highlights of the “Safe Chemicals Act of 2010”
Provides EPA with sufficient information to judge a chemical’s safety. Requires manufacturers to develop and submit a minimum data set for each chemical they produce, while also preventing duplicative or unnecessary testing. EPA will have full authority to request additional information needed to determine the safety of a chemical.
Prioritizes chemicals based on risk. Calls on the EPA to categorize chemicals based on risk, and focus resources on evaluating those most likely to cause harm.
Ensures safety threshold is met for all chemicals on the market. Places the burden of proof on chemical manufacturers to prove the safety of their chemicals. All uses must be identified and determined safe for the chemical to enter the market or continue to be used.
Takes fast action to address highest risk chemicals. Requires EPA to take fast action to reduce risk from chemicals that have already been proven dangerous. In addition, the EPA Administrator is given authority to act quickly if any chemical poses an imminent hazard.
Creates open access to reliable chemical information. Establishes a public database to catalog the information submitted by chemical manufacturers and the EPA’s safety determinations. The EPA will impose requirements to ensure the information collected is reliable.
Promotes innovation and development of green chemistry. Establishes grant programs and research centers to foster the development of safe chemical alternatives, and brings some new chemicals onto the market using an expedited review process.
# # #
March 29, 2010
Rosewood & Guaiacwood oils Controlled Under CITES Appendix II.
by Tony Burfield. March 2010.
The Environment News Service reported on 19th March 2010, that two South American trees, over-exploited by essential oil traders for the perfumery & cosmetics market, will be listed under Appendix II, the Convention in International Trade (CITES) in Doha, Quatar has decided. Trade controls (international commercial trading strictly by permit only) will apply within 90 days for Aniba rosaedora (Brazilian rosewood), proposed for listing by Brazil, and for Bulnesia sarmientoi (holywood) from the Gran Chaco region of Central America (from which guaiacwood oil, acetylated guaiacwood oil and guaiyl acetate is produced), proposed for listing by Argentina.
Cropwatch has long drawn attention to the decline in the ecological status of rosewood trees (see rosewood monographs in the Cropwatch Files section of website), and many essential oil users have subsequently volunteered to stop purchasing the essential oil. Unfortunately there is always the unethical element of the trade which will carry on using unsustainable species up until the point at which it is actually illegal to do so Cropwatch has previously named and shamed these concerns, but they seem too set in their ways to take any notice of environmental arguments. The status of holywood (guaiacwood) trees in the Gran Chaco National Park which stretches across W. Paraguay, N. & N.E. Argentina & S.E. Bolivia was recently updated by Cropwatch in its Updated List of Threatened Aromatic Plants Used in the Aroma & Cosmetic Industries v1.19 (see Cropwatch Files). Guaiacwood essential oil is actually a brownish paste melting at 45ºC and acetylated derivatives have occupied an important place in the perfumer’s palette.
But will the listing really make any difference? A CITES Appendix I listing would have been more effective, especially in the case of the rosewood tree, who’s survival is more in the hands of the lawless loggers. Rosewood oil from unlicensed stills deep in the forest continues to find its way into the essential oils market, although some batches show unusual compositions, prompting queries about the species it was sourced from (see Cropwatch’s Rosewood biblio in the Cropwatch Files). Will guaiacwood oil from Paraguay continue to be legally available, or is it just Argentinean origins which will be unavailable? Time will tell, but these CITES listings are, at least, a step in the right direction.
March 18, 2010
Powerpoint Text: Is excessive regulation destroying the perfumery art?
Presentation linked from previous post converted to a blog post by Rob.
by Tony Burfield Cropwatch www.cropwatch.org
Who are Cropwatch?
Logo: Juniperus procera Hochst. ex Endl. (Kenyan Cedarwood): Over-Exploited to Near Extinction by the E.O. Trade.
- A loosely based, non-financed, independent watch-dog to the aroma & natural products trade. In existence approx 6-7 years.
- Best known for its pro-active campaigning activities on natural aromatics, data-bases on threatened aromatic species & bio-piracy, long-term opposition to the 26 allergens legislation, & to the QRA (which the SCCP has also criticised in SCCP/1153/08).
- No formal membership; produces an occasional Cropwatch Newsletter which reaches some 40,000 people.
- Provides free information on natural aromatics on its website www.cropwatch.org and free advice to enquirers.
Part I – Perceived Problems with Fragrance Safety Legislation & Safety ‘Experts’.
Safety Issues in the Aroma Business.
- Fragrance customers usually insist on adherence to all existing H&S guidelines (both official & voluntary) because of the prevailing fear-culture, and possible media exposure regarding potential adverse effects to end-users from single ‘hazardous’ fragrance ingredients.
- EU Regulators have no capability of gauging the socio-economic effects of their policies. Banning or restricting natural aromatic materials often has severe economic consequences for natural aromatic producers and dependent communities in developing countries. Disastrous EU legislation is (sometimes) followed by an impact assessment and (then possibly) corrective action – but by then its often too late to save any affected SME’s (e.g. the effect of the BPD on Europe’s natural biocidal product manufacturers).
- Knowledgeable whistle-blowers revealing questionable trade practices are shunned by the trade (for example, as detailed in the letters of the late Stephan Arctander).
- So many SME’s (candle-makers / soap-makers/ incense traders / pot pourri makers / hand-made cosmetics makers / general cleaning product makers / natural perfumers / aromatherapists etc.) cannot afford IFRA / RIFM’s annual fees, & so are locked out of access to a lot of detailed safety data.
- Perfume manufacturing orgs. require the implicit adherence of their members to IFRA Standards & CoP [note: these are not legal requirements, with the exception of Eco-label fragrances]. However many traditional perfumes types, as well as natural, organic & functional perfumes are almost impossible to construct under existing IFRA regulations.
- Safety data is often generated by the major aroma corporates in an atmosphere of secrecy & may have private ownership issues attached; data can be difficult to locate, & expensive or virtually impossible for the general public to obtain. There is also a lack of transparency by regulatory professionals.
The ‘Zero Risk Mindset’.
- EU Regulators apply - (or appear to have been pressurised into, by ‘invisible’ lobbyists) a disproportionate & excessive degree of regulation wrt aromatic ingredients, which appears to be an attempt to construct a clean, risk-free and largely synthetic-based world of their own. That is not the world that most of us wish to inhabit, and Cropwatch believes that many will ignore any restrictions which deny us the use of those familiar natural materials which we associate with our lives, our heritage & our traditions.
“..a society that does not try to shape its future ends up being dictated to by its own anxieties.” - Hunt (2004)
So How Dangerous is it to go Outside…?
- The green leaves of trees & plants continuously emit a- & b-pinenes, limonene etc. Shenck (1979) estimated that 438 million tons of monoterpenes* evaporate into the air continually from biological materials [*natural monoterpenes that are designated ‘dangerous for the environment’]. It has been calculated that one European forest puts more chemicals into the environment that the whole EU chemical industry.
- Emitted leaf volatiles also react with ozone to form irritating / sensitising terpene epoxides. Some US fragranced home-care products containing limonene are labelled (paraphrasing): do not use if smog outside !
- Tree leaf volatiles also react with nitrogen oxides from combustion engine emissions causing chemical smogs. Academics at Lancaster University (2002) recommended that UK councils modify the planting of certain VOC emitting trees (maple trees: good; oaks & poplars: bad!) (not, you will notice, take any steps to stop cars emitting nitrogen oxides).
Nature: Presents More Hazards than Using Fragranced Products?
- Inhalation of fern spores poses a cancer risk to countryside visitors / dwellers, & the spores are also a risk to the safety of potable water supplies (Calif. Prop 65).
- Unregulated nuisance farm crops such as mustard seed-rape (flowers & roots) emit allyl isocyanate, benzyl cyanide etc. into the air & soil. Aerial dispersion causes respiratory distress / allergy to many in vicinity (see Rapeseed report: Cropwatch Files).
- This is not to mention the unregulated intake of natural carcinogens, mutagens, toxins etc. consumed in food & spices, & beverages (e.g. methyl eugenol from pesto, safrole from nutmeg, and the CMR1 substance ethanol).
Unregulated Plateful of Suspected Rodent Carcinogen posing as Foodstuff [A plateful of methyl eugenol containing Pesto!].
- Industry is seen as a cash-cow by the EU H&S Commission. REACH registration costs will potentially ruin all but the largest aroma concerns, in spite of concessions for SME’s. The aroma industry magnates therefore divisively support the REACH regulations as a means of eliminating competition.
- The ECHA has created an unmonitored situation under REACH (e.g. for lead registrants & for SIEFS etc.) where bullying and mafia-like activity by large aroma industry corporates has gone unrestricted.
- REACH will severely reduce the available portfolio of fragrance ingredients – Western companies will only be able to make ‘Mickey Mouse’ perfumes.
- REACH has already driven the focus of activity of leading trans-international aroma companies out of Europe.
- Leading toxicologists are opposed to REACH (see next slide)
The Basis of REACH challenged
- The idea that the toxic effects of a chemical show a dose-dependent linear relationship ending at a threshold level is now challenged: at low levels adaptive, non-adverse or even beneficial effects occur (hormesis), and have been shown for >6,000 chemicals (Calabrese 2004).
- This raises a ‘serious misreading of the term toxic’ charge for the EPA, and for the ECHA over the REACH legislation, and suggests that the 50-100 million Euros spent on the exercise is wasted, and will not save a single life.
- The above reference to the EPA needs to be seen as what appears to be a gagging order, mentioned a document prepared by the EPA in 2004, which states that the purpose of a risk assessment is to identify risk (harm, adverse effect etc.), effects that appear to be adaptive, non-adverse or beneficial may not be mentioned. - through Calabrese (2007) ”Belle Newsletter: Introduction. “ Human & Experimental Toxicology 26, 845.
The importance of natural aromatic ingredients.
- Naturals breathe life into an otherwise simple blend of chemicals, adding depth and sophistication - whether floral absolutes, woody materials or citrus oils are employed (many of these ingredients will disappear under REACH).
- Whole fragrance styles / families would not exist without naturals – for example, Eau de Colognes, Eau Fraiches.
- Many landmark fragrances & fragrance styles owe their conception to key natural materials e.g. the chypre style of Mitsouko & Miss Dior, which were based on accords of oakmoss, patchouli oil and labdanum together with bergamot oil.
- Many essential oils lend an incomparable radiant freshness to fragrances e.g. lime, lavender & petitgrain. It is hard to imagine an impressive masculine fine fragrance which merely relies on synthetic materials for its freshness.
A Timid Industry.
- Cosmetic / biocidal / detergent & cleaning ingredient restrictions & regulation proceed with little effective trade questioning or objection in the EU, leading to questions about why industry is so timid (see Durodie 2004).
- But ‘the worm is turning’. In the US, cosmetics-based SME’s are grouping together to prevent financially discriminating legislation acting against them – for example over the crippling fees & costs involved with compliance to the FDA Globalisation Act HR-759, 2009). The Colorado Safe Personal Products Act HB-1248 which proposed zero tolerance for many ‘hazardous’ single cosmetic ingredients (& so was potentially even more extreme than existing European legislation) failed in committee (01.03.2010) due to pressure from SME’s. In S.E. Asia, producers of natural aromatic materials & cosmetics are just starting (Feb 2010) to form anti-regulation groups to protect their livelihoods.
Shortcomings of the EU Cosmetic Commission’s H&S Policies.
- The EU Cosmetics Commissions’ CoP refuses to define ‘safety’, there is no individual ingredient risk quantification, it does not consider ingredient risk / benefit considerations (except for preservatives), it does not allow in-use considerations, & it does not allow for end-consumer adverse reaction statistics to affect safety policy - as apparently this is not ‘bona fide’ evidence (Daskaleros 2007).
- This ‘risk-only’ chemophobic scenario leads to a state of toxicological imperialism, where over-precaution & scare-mongering are de rigueur, and where pharmaceutical & chemical company lobbying disadvantages competitive natural products. Worrying situations of vested interest (e.g. in the SCC(S)(P)) remain unaddressed. Europe has become a hostile environment for perfumery; many concerns have relocated outside the EU.
A Lack of Cross-Disciplinary Expertise..
- EU Cosmetic Comm. staff admitted to Cropwatch (Brussels 2007) they were unable to find the services of a botanical expert, and the SCCP had no literature search ability until 2007 (& so previously could not properly independently review the evidence presented to them). Now a pool of 160 ’experts’ is supposedly to be made available to Brussels staff (but no word on any botanists!).
- The previous safety assessments of many / most natural fragrance ingredients by RIFM have proceeded via industrially donated materials which have not been botanically identified at source by an expert, were not batch-tracked and not proven as 100% derived from the named botanical. The lack of forensic and taxonomic application has led Cropwatch to describe a number of IFRA Standards as non-robust, where botanical identifications (as published) are either incorrect, incomplete or based on false assumptions of ingredient purity e.g. for opoponax (see Cropwatch Files - Opoponax).
..and a Lack of Ecological Awareness..
- The industrial over-exploitation of many natural aromatic species by the Cosmetics & Pharmaceutical industries remains virtually unchecked – by the time a CITES listing or an IUCN Red Listing is in place, it is often too late to save the species under threat, or the full compliment of its’ genetic diversity.
- For example while IFRA pondered a new Standard for styrax qualities, less than 15 hectares of Asian styrax trees remained unlogged in Turkey.
- Commodities from rare or threatened species include: agarwood oil, sandalwood oil East Indian, sandalwood oil East African, rosewood oil, Cedrela odorata oil, guaiacwood oil, copaiba balsam, gurjun balsam, candeia plant spp., costus qualities, Parmelia (fragrant lichen) qualities, some frankincense yielding spp. e.g. Boswellia papyrifera, chaulmoogra oil and many others (see Cropwatch data-base on Threatened Aromatic Species).
Media Bad Science on Naturals – an Example.
- Gynecomastia in 3 pre-pubertal boys, allegedly caused by using lavender/TTO-containing cosmetics / personal care products (Henley et al. 2007), received much newspaper coverage in 2007-8. The New England Journal of Medicine which ran the article, had previously announced a policy change, as it could not find independent experts for peer reviewing, who had not been paid off in some way by industry (Newman 2002). A pity, since refutation of the robustness of science behind the alleged gynecomastia-lavender/TTO link followed [e.g. by Nielson (2008) & Lawrence (2007) amongst others], but of course, received no attention from the popular media.
Bad Science on Naturals in Peer-Reviewed Journals – An Example.
According to Frosch, White et al. (2002):
- patchouli oil contains cinnamic aldehyde, benzaldehyde & eugenol!
- Atlas cedarwood oil contains alpha-ionone!
- sandalwood oil contains geraniol & citronellol!
- the main components of spearmint oil are limonene, 3-octanol, menthone and dihydrocarvone (but no mention of the major constituent: carvone!)
Ref: Frosch P.J., Johansen J.D., Menné T., Pirker C., Rastogi S.C., Andersen K.E., Bruze M., Goosens A., Lepitoittevin J.P. & White I.R. (2002) “Further important sensitisers in patients sensitive to fragrances II - Reactivity to essential oils.” Contact Dermatitis 47, 279-287.
Part 2. The Mis-regulation of Natural Ingredients – some Examples
Destroying the very foundations of perfumery.
- The restriction/banning of key fragrance ingredients on dubious / over-precautionary safety grounds, can easily compromise the founding elements of the traditional perfumery art. For instance, the crucially important fougère perfumery accord consists of a combination of bergamot, coumarin & oakmoss.
- Bergamot oil usage is under threat from potential EU legislation because of its allegedly photo-toxic furocoumarin (FC) content (see flawed SCCP Opinion 0942/05, then compare with the Cropwatch FC data-base).
- Oakmoss was originally proposed to be restricted as a sensitiser under SCCP/1131/07, limiting the potent sensitisers atranol & chloroatranol to 2ppm in product. Cropwatch (2009) described this Opinion as unsafe from a failure to consider all the published evidence (which it has subsequently made publicly available). EU policy on oakmoss / treemoss has since been modified.
Public Objections to ‘Safe’ Reformulations of Classic Perfumes.
- Reformulations of classic perfumes, carried out in order to conform to modern regulatory requirements, have led to disappointment and bitterness amongst their long-term devotees, whose historical memories and emotional attachments are evoked by the odour profiles of particular fragrances, as part of their rightful cultural inheritance. Many fragrance houses seem in-denial about the whole subject, but Turin (2007) has remarked on customer anger generated during the Guerlain Mitsouko reformulation debacle. Internet discussions on a wider range of classic perfumes whose character has been allegedly mutilated by reformulation are available (for example see Perfume of Life Forum Jan 2007)…
Natural Ingredient Usage Declines.
- The usage of naturals has declined in perfumery from downward pressure on ingredient costs (synthetics are comparatively cheaper), erratic supply (climatic & geophysical events; political events; demand pressures) & from stability & compositional issues.
- Under existing EU H&S policy, natural complex substances are treated as a collection of individual composite chemicals. The vast majority of essential oils, absolutes & resinoids contain several of the 26 named allergens, which have to be labelled under EU Directive 2003/15/EC (now under review). The desire by cosmetic manufacturers to avoid excessive product labelling has previously lead to some decline in the overall usage of essential oils.
- Under CHIP / EU DPD & DSD (now under the CLP 1272/2008/EC), R50/53 environmental labelling (dead fish / dead tree symbols) and R65 labelling have had a serious impact on usage of citrus oils & their terpenes. Citrus oils have been traditionally employed in many types of perfumes for household & air care products due to their diffusion, lift & fresh character, but perfumers now find it difficult to use them for the reasons above. Ditto for pine needle oils.
- Cinnamon leaf & clove oils were used in pot pourris & candles, but R43 issues with cinnamic aldehyde & eugenol contents etc. mean that their use is restricted.
- Minor oils that IFRA has banned / restricted on predictive toxicological grounds, but has no funds to practically investigate – melissa, santolina, boldo etc. NB Cropwatch recently published the Robertet toxicological evidence on melissa oil showing the original IFRA ban was unjustified
- Natural products needing expert botanical identification & chemical analysis for QRA studies, are/were not supported (read: can’t afford to support) by IFRA– opoponax, styrax..
The ‘Weak Animal Carcinogens’ Issue.
- The EU classification of methyl eugenol as a suspected rodent carcinogen & mutagen, and safrole as a hepatocarcinogen, together with corresponding IFRA restrictions, has led to a great reduction in the use of those natural materials which contain them, such as the methyl eugenol-containing spice oils: clove bud, pimento leaf & pimento berry. The use of rose oil has been similarly affected - it is now virtually impossible to create a 100% natural rose fragrance which complies to IFRA guidelines, formulated with >1% rose oil. Use of cinnamon leaf & nutmeg oils too, has also been curtailed by the safrole classification, as has the use of basil & tarragon oils containing estragole (weak carcinogen, weak mutagen).
- Such limitations have had significant effects on fragrance styles entering the market place: traditional aromatic masculine fougères and rich spicy notes are very difficult to achieve at so-called ‘safe’ levels.
Some Inconvenient Classifications.
- Safrole: carcinogen cat. 3 mutagen cat. 2 (EFFA CoP 2009). Occurs in sassafras, nutmeg, mace, star anise & cinnamon leaf oils.
- Methyl chavicol: Possible weak genotoxic hepatocarcinogen (SCF 2001). Occurs in star anise, exotic basil, fennel, tarragon oils.
- Methyl eugenol: Possible carcinogen (US). Calif. Prop. 65 carcinogen. Occurs in rose, basil, bay WI, cananga, citronella Sri Lanka, pimento, lovage & betel oils etc. Human exposure levels normally several magnitudes below bioassay levels for rats, mice; relevance of rodent data questioned (Robison & Barr 2006).
- Ethanol: CMR cat 1. Cosmetic manufacturers are currently withdrawing ethanol from mouthwash formulations. Indispensable ingredient to cosmetics trade.
- Cropwatch has a large A-Z data-base of articles on the various furocoumarin (FC) contents of natural products following FC phototoxicity issues (under SCCP/0942/05 etc.). Companies like Treatt, Capua etc. now market a range of FC-free citrus oils, but small traditional producers of citrus oils are potentially disadvantaged without huge technology investments. And for what reason? The safety case for reducing FC’ s to the minute levels the EU proposed in cosmetic products is not robust, and other commonly used cosmetic ingredients also show photo-toxic effects.
- To date, safrole-free nutmeg qualities, methyl eugenol-free rose oil, IFRA compliant oakmoss qualities, furanocoumarin-free bergamot oil etc. etc. have all proven to be more-easy-to-adulterate, pale olfactory shadows of traditionally produced natural products. This reduction in ingredient quality compromises the art of the possible in perfumery practice.
‘Allergic’ Fragrance Ingredients.
- SCCNFP in Opinion SCCNFP/0017/98 & 0329/00 identified a number of fragrance chemicals (16 of which occur in natural products) associated with a labelling obligation for allergens where conc. in the final product is <0.01% in products rinsed off the skin products or <0.001% in leave-on products. This was incorporated into Council Directive 2003/15/EC. The basis for the inclusion of these chemicals as allergens has never been explained by the SCCP (Storrs 2007). The chairman of the SCCP (Ian White) has co-authored a number of research papers on alleged allergens, & cannot be said to be a disinterested party.
- Independent papers / peer-reviews (e.g. those by Schnuch, Flocfh, Vocanson, several by Hostynek & Maibach) have indicated that there is no robust clinical or experimental evidence to support many of these 26 ingredients as allergens. Schnuch (2008) asked the EU to rethink their policy.
- Hostynek & Maibachfs (2008) detailed article on gAllergic Contact Dermatitis to Linalool: Allergen Status Disqualifiedh has appeared in a third consecutive journal/trade magazine.
- A request for an updated scientific opinion on the labelling of 26 fragrance substances which were introduced into Annex III of the Cosmetics Directive by 2003/15/EC was made by the EU Commission of the SCCP, politically passed off as ‘a spin-off from the public consultation (Nov 2006) on the Commission proposal of regulation of some fragrance substances’.
- "Scientific information of general and specific nature has been submitted to DG-ENTR. in order to ask the SCCP for a revision of the 26 fragrances with respect to further restrictions and possible even delisting.”
- “At that time there were not sufficient scientific data to allow for determination of dose response relationships and/or thresholds for these allergens”.
- Cropwatch comments: if this is manifestly correct, why did they go ahead with the legislation?
- The older Opinion SCCNFP/0017/98, divided allergens as most frequently listed (list A) and infrequently listed (list B), but the recent Brussels request to the SCCP (see previous slide) makes no reference to the work of Schnuch et al. (2007), who called for a slightly different list of substances to be reviewed as allergens, on the basis of his published work indicating there were no safety concerns to consumers for a number of these SCCP allergens.
The Tea Tree Oil (TTO) Debacle
- TTO is in a Catch-22 situation. It is universally acknowledged by microbiologists as a useful biocide except by the EU Biocides Commission. Therefore, apparently, TTO in EU cosmetic products ‘does not have a cosmetic purpose’ (SCCP/1155/08).
- Also according to SCCP/1155/08, diluted TTO might be unstable in cosmetic formulations, skin & eye irritation not assessed by adequate methods. The SCCP identified data-gaps relating to subchronic toxicity, percutaneous absorption, genotoxicity / carcinogenicity & reproductive toxicity.
- The ATTIA (& RIRDC) made the big mistake of submitting a safety dossier to the SCCP on these shortcomings, at a cost of £200,000 Australian, thus creating a precedent for the whole essential oils industry. The SCCP took nearly 2 years to evaluate their data, and still were not satisfied.
- Adverse end-user reactions from sales of tens of millions of small bottles of TTO by major distributors runs at < 0.0015% (Cropwatch, unpublished data).
- Under IFRA’s 44th Amendment, vanillin was at first restricted on alleged QRA sensitisation grounds, but this restriction is currently suspended (this dithering costing industry hundreds of thousands of Euros in reformulation, ingredient stock adjustment, costs of buying in substitution stock and re-labelling). Current vanillin consumption is about 6,000t/y.
- Vanillin has been the foundation of the oriental fragrance family formed from accords of vanillin, balsams, spices, patchouli, woods, salicylates and citrus oils. Jicky, created in 1889 by Guerlain was the first major oriental fragrance founded on this accord.
- In the early to mid 1990s a major vanillic trend was founded on an overdose of vanillin and vanilla. Beginning with Vanilla Fields (Coty 1993), a host of sweet vanillic floral and vanillic floriental fragrances were launched e.g. Tocade (Rochas 1994), Loulou Blue (Cacherel 1995), Le Male (J. P. Gautier 1995), Allure (Chanel 1996), Ghost (2000). This trend of the 1990s has lead to a general sweetening of fragrance styles, (and consequently a generally higher use of vanillin), which is apparent today in the myriad of oriental masculine styles (e.g. 212 Sexy for Men 2006) and fruity floral feminine types and fruity florientals (e.g. Delicious Night DKNY 2007).
- Evidence for the alleged very weak sensitising activity of vanillin (according to IFRA) rests on 3 pieces of evidence, 2 of which are hardly new but are unavailable to the general public:
Basketter D.A., Wright Z.M., Warbrick E.V., Dearman R.J., Kimber I., Ryan C.A., Gerberick, G.F., White I.R. (2001). “Human potency predictions for aldehydes using the local lymph node assay.” Contact Dermatitis, 45, 89-94.
RIFM (Research Institute for Fragrance Materials, Inc.), 1970. Maximization study with vanillin. RIFM report number 1760, October 7. (RIFM, Woodcliff Lake, NJ, USA).
RIFM (Research Institute for Fragrance Materials, Inc.), 2009. Human repeated insult patch test. DRAFT REPORT. (RIFM, Woodcliff Lake, NJ, USA).
- Opposing evidence to the sensitising potential of vanillin was listed in Cropwatch Newsletter 15 – for example >99% vanillin ex lignin has been found non-sensitising. But it is likely that this major fragrance ingredient will yet suffer severe usage restrictions on dubious QRA testing grounds.
- Coumarin is regulated by EU Directive 2003/15/EC such that coumarin requires labelling as a sensitiser if present at concentrations of >10ppm in fragranced leave- on products, or >100 ppm in fragranced products washed off the skin.
- SCCP Opinion /0935/05 on 99.9% pure coumarin, shows the expert committee had misunderstood the data, incorrectly concluding that pure coumarin is a sensitiser - Schnuch (2004), Floc’h et al (2002), Vocanson et al (2006 & 2007) and many others have opposing views. Cropwatch’s submission to DG-Ent. on coumarin was never acknowledged.
- Minor impurities in some commercial grades of synthetic coumarin used for allergy testing (dihydrocoumarin; 6-chlorocoumarin etc.) may however be sensitising.
Only 1 well-documented clinically relevant case of allergy to coumarin has ever been reported (Mutterer et al. 1999). Low numbers of clinically relevant cases exist for many other alleged allergens listed under EU Directive 2003/15/EC. The legislation clearly lacks proportionality.
- EFSA (2004) concluded that coumarin is non-genotoxic. Any human carcinogenicity issues may only be relevant to very small sub-section of human population (Lake 1999).
- Federal Institute for Risk Assessment (BfR) had to be publicly corrected in 2007 on alleged risks with coumarin toxicity from cosmetics. The BfR had wrongly maintained that the TDI (0.1mg/d) for coumarin could be exceeded by the normal application of cosmetics. Commentators are on record as saying that Prof. Hensel has, additionally, not understood species differences relevant to coumarin metabolism.
Other Fragrance Ingredients with Questionable Restrictions.
- Benzaldehyde (used for almond & cherry notes); tagetes oils & absolutes; oakmoss & treemoss qualities; FC-containing citrus oils; opoponax & styrax qualities; jasmine absolute; santolina, boldo & melissa oils; oils of the Pinaceae.
- All of these and many others have been discussed by Cropwatch (see website), and many are the subject on on-going investigations to reverse the hasty & over-precautionary limitations imposed.
- Calabrese E.J. (2004) “Hormesis – basic, generalisable, central to toxicology and a method to improve the risk assessment process” J Occup Enviro Health 10(4), 466-7.
- Calabrese E.J. (2007) ”Belle Newsletter: Introduction. “ Human & Experimental Toxicology 26, 845.
- Daskaleros T. (2007) remarks made during Cropwatch meeting with EU Cosmetics Commissioners & DG-Ent staff 2007 Brussels, July 2007.
- Durodie B. (2004) “The timid corporation – why business is terrified of taking risk.” Risk Analysis 24(1), 2004.
- EFSA (2004)
- Floc’h F. (2002) “Coumarin in plants and fruits: implications in perfumery.” Perf. & Flav. 27 (Mar/Apr 2002), 32-36.
- Frosch P.J., Johansen J.D., Menné T., Pirker C., Rastogi S.C., Andersen K.E., Bruze M., Goosens A., Lepitoittevin J.P. & White I.R. (2002) “Further important sensitisers in patients sensitive to fragrances II - Reactivity to essential oils.” Contact Dermatitis 47, 279-287.
- Henley D.V., Lipson N., Korach K.S., Bloch C.A. (2007) “Prepubertal gynecomastia linked to lavender and tea tree oils.” New England Journal of Medicine 356 (5), 479–485.
- Hostynek J. & Maibach H. (2008) “Allergic contact dermatitis to linalool” Perfumer & Flavourist 33, 52-56.
- Hostynek J.J. & Maibach H.I. (2003) "Is there evidence that anisyl alcohol causes allergic dermatitis?" Exog. Dermatol. 2, 230-33.
- Hostynek J.J. & Maibach H.I. (2003) "Is there evidence that amylcinnamic aldehyde causes allergic dermatitis?" Exog. Dermatol. 3, 35-46.
- Hostynek J.J. & Maibach H.I. (2003) "Is there evidence that linalool causes allergic dermatitis?" Exog. Dermatol. 2, 223-229.
- Hostynek J.J., Maibach H.I. (2004) “Is there evidence that geraniol causes allergic contact dermatitis?” Exog. Dermatol. 3(6), 318-331.
- Hostynek J.J., Maibach H.I. (2004) “Sensitisaton potential of citronellol” Exog Dermatol 3(6), 307-312.
- Hostynek J.J., Maibach H.I. (2004) “Is there evidence that alpha-methyl-ionone causes allergic contact dermatitis?” Exog. Dermatol. 3(3), 121-143.
- Hostynek J.J., Maibach H.I. (2006) “Is there evidence that alpha-methyl-ionone causes allergic contact dermatitis?” Cutaneous & Ocular Toxicol. 25(4), 259-271
- Hunt B. (2004) The Timid Corporation – Why Business is Terrified of Taking Risk
- Lake B.G. (1999) “"Coumarin metabolism, toxicity & carcinogenicity: relevance for human risk assessment" Food and Chemical Toxicology 37, 423-453
- Lawrence B.M. (2007) “Estrogenic activity of lavender & tea tree oils Part II.” Perf. & Flav June 2007.
- Mutterer V., Giménez Arnau E., Lepoittevin J.P., Johansen J.D., Frosch P.J., Menné T., Andersen K.E., Bruze M., Rastogi S.C., White I.R. (1999) "Identification of coumarin as the sensitizer in a patient sensitive to her own perfume but negative to the fragrance mix." Contact Dermatitis. 40(4):196-9.
- Nielsen J.B. (2008) “What you see may not always be what you get – Bioavailability and extrapolation from in vitro tests.” Toxicology in Vitro
- Newman N. (2002) "Big Pharma, bad science." The Nation 25 July 2002.
- Robison S.H. & Barr D.B. “Use of biomonitoring data to evaluate methyl eugenol exposure.” Environ Health Perspect. 114(11), 1797-18001.
- Schnuch A. (2004) Öko-Test, No. 7 (July) 2004, 55
- Schnuch A., Uter W., Geier J., Lessmann H., Frosch P.J. (2007) “Sensitization to 26 fragrances to be labelled according to current European regulation. Results of the IVDK and review of the literature.” Contact Dermatitis. 57(1),1-10.
- Shenck G.O. (1979) Perf Kosm 60, 397.
- Storrs F.J. (2007) “Allergen of the year: fragrance.” Dermatitis 18(1),3-7
- Turin L. (2007) “Due Credit” NZZ Folio 04/07.
- Vocanson M. (2006). "The skin allergenic properties of chemicals may depend on contaminants – Evidence from studies on coumarin." Int Arch Allergy Immunol 140, 231–238
- Vocanson M. et al. (2007) “Lack of evidence for allergenic properties of coumarin in a fragrance allergy mouse model.” Contact Dermatitis 57(6), 361-364.
- ATTIA – Australian Tea Tree Industries Association
- BfR - Federal Institute for Risk Assessment
- BPD – Biocidal Products Directive
- DG-ENT - Directorate General (Branch of European Commission responsible for Industry)
- CoP – Code of Practice
- E.O. – Essential Oil
- ECHA - European Flavour & Fragrance Association
- EFSA - European Flavour & Fragrance Association
- FC – FuroCoumarin
- H&S – Health & Safety
- IFRA - International Fragrance Association
- QRA - Quantitative Risk Assessment
- REACH - Registration, Evaluation, Authorisation and Restriction of Chemicals
- RIFM - Research Institute for Fragrance Materials
- RIRDC – Rural Industries Research & Development Corporation (Australian Govt).
- SCCNFP - Scientific Committee on Cosmetic Products and Non-Food Products
- SCCP - Scientific Committee on Consumer Products
- SCF – Scientific Committee on Food
- SME – Small to Medium sized Enterprise
- TDI - Tolerable Daily Intake
- TTO – Tea Tree Oil
- VOC – volatile organic carbons
Editors Note: This was converted from a Power Point document by Rob. The formatting of the references is incomplete, and I did not add links to many previous posts on this blog which deal with many of the materials discussed herein. Those may come later, as will the reference formatting.
Posted by Tony Burfield on March 18, 2010 in Ecological/Cultural Sustainability, Essential Oils/Plant Extractions, Lavender/Tea Tree/Gynecomastia, Perfumery, Regulatory Issues, Safety/Toxicity | Permalink | Comments (1) | TrackBack
December 21, 2009
The Palm Oil Atrocity
Originally posted on La Vida Locadore (cross posted with permission) This is a timely post from outside the aromatic community to introduce Cropwatch’s recently updated List of Endangered and Threatened plants which is now in its 17th upgrade UPDATE: Tony has updated the List of Endangered and Threatened plants to include more information about the Palm Oil Situation. (search for Palm Oil in the pdf file—it’s about the third mention).
Sun Dec 20, 2009 at 10:41:56 AM PST
I loathe to use a Ballardian catchword in the title but it conveys the sheer insanity and the destructive practices that the palm oil business does to our planet (if you have five minutes to spare please peruse the preceding linked pdf)
Now, thankfully (and quite possibly because of "gentle pressure"), we have the globe's two biggest food firms, Nestlé and Kraft, who have launched internal investigations after a Greenpeace report claimed both purchase palm oil from Indonesian company PT Smart whose parent group Sinar Mas allegedly engages in widespread illegal deforestation and peatland clearance in Indonesia.
In the UK, Marks & Spencer have also made new pledges about their use of sustainable palm oil, ramping up to using only certified oil in products by 2015. But, what is certified oil?
Palm oil is used in a broad range of consumer food and toiletries products, but its production has caused massive deforestation in South Asia, placing livelihoods of humans and habitats of forest animals like orangutans under severe threat.
The growth of Indonesia's palm oil industry is blamed for turning the country into the world's third-largest emitter of CO2 after China and the United States. Additionally Indonesia also has the fastest rate of deforestation, losing an area the size of Wales every year (every year more than 8.5 million hectares of tropical rainforests are being razed worldwide.)
According to Grist deforestation is one of the largest sources of greenhouse gas emissions in developing countries, amounting to roughly 20 percent of overall emissions. 20%! The issue was also one of the key issues debated at the Copenhagen climate change summit.
Under the draft text of the rules, known as Reducing Emissions from Deforestation and Forest Degradation (REDD), oil palm plantations created by clearing rainforests would qualify for payments from a new scheme in which rich countries would pay developing countries for storing carbon in trees.
The Jakarta Times reported that Unilever has also decided to suspend the annual contract worth US$32.5 million after it obtained photographic evidence of Sinar Mas clearing protected rainforests, including reserves for Indonesia's endangered orangutan population.
"We have received very serious allegations against Sinar Mas and we had no choice but to suspend future purchases from them," Unilever's vice-president for communications, Gavin Neath, told The Times. Sinar Mas's actions break Indonesian law and highlight how membership of the RSPO alone is not sufficient proof of a company's environmental credentials, alleges Greenpeace. A Unilever spokesperson told FoodNavigator.com: "The Greenpeace claims about (PT SMART) breaking RSPO guidelines are too serious for us to ignore."
What's the benefit of Palm oil? It is a form of vegetable oil derived from the oil palm tree (Elais guineensis) mostly produced on plantations in the tropics, notably in South East Asia. In every supermarket shelves you will find that at least 10% of all products are made from palm oil: frying oil, biscuits, chips, chocolate, instant noodles, ice cream, cakes, mayonnaise and so much more, the list is very long.
It does not stop there. Broken down to form derivative products, it is also used in soaps, shampoo, cosmetics and detergents and in the metal and leather industries. Palm kernel meal, which is extracted from the same plant, is used as livestock feed.
Here are a few examples of the questions you might ask yourself: what links breakfast margarine with the repression of indigenous people in Indonesia? Were your leather shoes made at the expense of the rainforests? What do crisps and biscuits have to do with the enforced displacement of rural populations?
"Around three-quarters of the world's oil palm is grown in Indonesia and Malaysia where much of the recent expansion of the industry has been onto peatland and into tropical rainforest," according to Unilever's website. "The clearance and burning of South-East Asia's peat forests release 2bn tonnes of greenhouse gases every year. According to some estimates, deforestation in Indonesia alone accounts for 4 per cent of global greenhouse gas emissions - making it the third-highest emitter behind the US and China."
However the company believes the link between the cultivation of oil palm and climate change can be broken by creating a market that is sustainable and certified. Read my lips: sustainable palm oil is simply snake oil in a clever disguise.
Many manufacturers and retailers are using palm oil in great quantities to stimulate supply and demand regardless of its huge environmental impact in South Asia, where forests have been cleared to make way for more plantations. The devastation has displaced both humans and animals that live in forest regions, and makes a big contribution to carbon emissions.
The WWF has now graded 25 major users of palm oil in Europe (world's largest consumer), to see how much of the available "sustainable" palm oil they are using.
"The top scoring companies have shown what's possible, with some buying fairly substantial quantities but now it's a question of whether the majority will follow," Adam Harrison, WWF's senior policy officer for food and agriculture. "If they do, it will transform the market, giving producers the confidence to grow more sustainable palm oil. If they don't, there will be grave consequences for the environment."
Low-scoring retailers included Aldi, Waitrose, Boots, Morrisons, Co-op and Tesco. While no company achieved the maximum 29 points, amongst the highest scorers were Sainsbury's, Marks and Spencer, Cadbury and Nestle.
The publication of the scorecard follows an announcement from Nestle this week that it will use only sustainable palm oil by 2015. But as I said above: sustainable palm oil may not be sustainable after all. You might like to read what Friends of the Earth have to say on the matter:
After a complain from Friends of the Earth International the UK advertising watchdog has ruled that claiming palm oil is "sustainably produced" is false advertising.The link is posted above.
Palm Oil names, what to look out for on the labels:
Sodium Laureth Sulphate (Can also be from coconut)
Sodium Lauryl Sulphates (can also be from ricinus oil)
Sodium dodecyl Sulphate (SDS or NaDS)
Palm Oil Kernel
Stearic Acid (may also come from other sources, but not likely in today’s environment – Rob)
Chemicals which contain palm oil:
Sodium Lauryl Sulphate
Sodium lauryl sulfoacetate (coconut and/or palm)
Hydrated palm glycerides
Sodium isostearoyl lactylaye (derived from vegetable stearic acid)
Cetyl palmitate and octyl palmitate (and anything with palmitate at the end)
November 05, 2009
Notes & News
A new lemongrass variety “suwarna” has been developed by the Central Institute of Medicinal and Aromatic Plants to address drought conditions with a limited amount of planting material released in Uttar Pradesh. This new variety will produce about 200 kg of oil per hectare as compared to normal varieties that produce about 100-124 kg per hectare. This is an attempt to diversify the income of farmers, particularly those in drought-affected areas.
The International Aloe Science Council presents a scientific primer on aloe. IASC has assembled a comprehensive document exploring the different varieties of aloe, their health properties, cultivation techniques and more. Download this e-book to learn about:
- commonly traded aloe species primarily used in the nutrition industry, and key components;
- cultivation considerations;
- aloe vera as a market commodity, including pricing information;
- a detailed appendix on aloe species; and
- details on requirements for organic certification.
The International Fragrance Association (IFRA) has appointed Aurore Boudet scientific and regulatory affairs manager. She will focus on the management and implementation of the IFRA code of practice, IFRA standards, and the compliance program.
The Research Institute for Fragrance Materials (RIFM) has formed an environmental adjunct group to support the expert panel’s efforts in environmental assessment of fragrance materials and development of IFRA Environmental Standard. The group includes Michael McLachlan, professor of analytical environmental chemistry, Stockholm University, Sweden, and Beate Escher, deputy director of the national research centre for environmental toxicology, University of Queensland, Australia. These appointments bring expertise in advising RIFM, especially in the areas of environmental fate and bioaccumulation.
We at aromaconnection want to remind our community to support an outstanding nonprofit effort: United Aromatherapy Effort (UAE), headed up by Sylla Sheppard-Hanger, was founded in 2001 to support emergency and disaster relief workers by providing rejuvenating aromatherapy and massage services during long and arduous rescue efforts after 9-11. The group continues to solicit aromatherapy supplies and monetary donations to provide support to U.S. troops in Afghanistan. We urge you to visit the UAE website to learn how you can contribute.
Posted by Blogmistress on November 5, 2009 in Ecological/Cultural Sustainability, Essential Oils/Plant Extractions, Oil Crops, Organizations, Regulatory Issues, Research, Science, Trade Issues | Permalink | Comments (1) | TrackBack
August 17, 2009
Notes and News
A distillation of Kashmiri rose oil was contaminated by geranium oil after the still was found to have not been thoroughly cleaned before the rose distillation began earlier this spring, reports R.P. Adams, Baylor University, and A.S. Shawl Regional Research Laboratory (CSIR) in August P&F.
Earthoil has been awarded IMO (Institute for Marketology) Fair for Life for its Indian mint-growing operation in Uttar Pradesh. Earthoil purchases from a 600+ farmer cooperative.
This article shows that bird brains aren’t so small after all.
Healthy Herbs and Spices
It’s that time of year; take a break and visit a lavender farm. This article features escapes to Sonoma Valley where lavender grows among the wine grapes, CA.
March 25, 2009
Call for Support for Firefighters/Victims in Australia
United Aromatherapy Effort is helping to mobilize efforts and donations to help wildfire relief efforts throughout Australia. Any supplies or monetary donations would be welcome.
March 21, 2009 NEWS: CALL TO ACTION
Once again the amazing power of the internet, and all our interconnections have enabled us to network this call to Action (feel free to forward).
We are mobilizing to help out with the teams already working for the Wildfire Relief Effort. The Australian Practitioners Emergency Response Network (APERN) exists to help frontline emergency workers fulfill their duties in an emergency/critical incident and to support volunteers and victims in a caring and compassionate way. The blog: http://therapistsunite.blogspot.com/2009/03/apern-bulletin-tuesday-10th-march-2009.html. It emerged from the events of Black Saturday, the 8th February, 2009 when extensive bush fires in resulted in over 200 deaths. APERN is still in its formation stages and they are all volunteers. In addition Hands on Health Australia or HOHA http://www.handsonhealth.com.au/ aims to assist communities to improve the delivery of health and other services to marginalized people, utilizing the resource of community volunteers. They are looking at setting up 7 community clinics. At present some clinics are running and others are still in progress. Some communities around Whittlesea are only just returning to their homes to begin the rebuilding stage. There are 7000 people still homeless and living in tents, having survived one of the worst tragedies. (News links on the UAE site if you need a reminder.)
Supplies (respiratory blends, relaxation, clinic supplies like towels/base oils, etc) can be sent to Tuesday Browell (email@example.com) 424 High Street, Echuca, Victoria Australia. 3564 mobile ph is.0428342957.
In addition Ron Guba/Essential Therapeutics in Melbourne is collection donations for oil supplies if you want to purchase local supplies toward the Relief effort: visit http://www.essentialtherapeutics.com.au he will see your purchase is mixed into respiratory blends, or other useful products and delivered via the above organizations. Ultrasonic diffusers would be great for the seven clinics if someone wants to contribute those, contact Sheriar Irani in Sydney www.subtleenergies.com.au
This is a great quick way we can help rather than sending our own supplies.
Thank you in advance for any support as we mobilize globally to help out when we can. Please feel free to forward this to any other lists or organizations, and other caring aromatic friends.
March 07, 2009
Sassafras oil distillers help destroy Cambodian forest
Copyright © Tony Burfield March 2009.
Illicit manufacturers of MDA, MDEA & MDMA (ecstasy) can utilise safrole from safrole-rich essential oils such as sassafras oil and “brown” camphor oil as starter materials (precursors). Therefore safrole & sassafras oils are designated as controlled substances in many countries, and safrole is listed as a Table 1 precursor under the United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances. Since sassafras trees (Sassafras albidum (Nutt.) Nees) grow wild in the Eastern parts of the US, the Drugs Enforcement Agency has made safrole a List 1 substance under the under the Chemical Diversion and Trafficking Act, and it is unlawful to trade safrole & safrole-rich substances for illicit drug-manufacturing purposes. There are legitimate uses for safrole however - these include the manufacture of the aroma chemical heliotropin (‘cherry pie’) and the knock-down insecticide piperonyl butoxide. Interestingly, there is a tradition of drinking sassafras tea, of using sassafras as in ingredient in sarsaparilla drinks, and making root beer from the inner bark of young sassafras tree roots. Dried ground sassafras leaves, in the form of aromatic filè powder, is also used in cooking, being stirred into traditional Southern dishes just before serving. The FDA made sassafras a prohibited ingredient for food & beverages in 1976, since it is a weak experimental animal carcinogen (rats, mice) - Daimon et al. (1998). It has to be said that there is some resistance amongst many US citizens in accepting that safrole is actually the heptacarcinogen it is made out to be. The latest EFFA Code of Practice for example lists safrole both as carcinogen category 2, and as a mutagen category 3m. It is fair to day that the amount of evidence for safrole’s role in human carcinogenicity is scanty, even at this point in time, although there is very limited evidence of oral cancers from long-term safrole exposure from betel-leaf and areca-nut chewing practices (Chen et al. 1999). So the traditions of sassafras tea drinking (often made from the sassafras tree’s twigs & leaves) still persists in places, such as is still found within N. American Indian communities in Eastern parts of Canada. In the Eastern US, many citizens regard the right to use sassafras as part of their cultural inheritance, although any commercial root beer listing sassafras as an ingredient is now made with safrole-free sassafras extract.
N. American sassafras essential oil has a sweet-spicy peppery odour, with an underlying woodiness; the dry-out on a perfumers strip being invariably spicy and woody. Safrole has a cleaner, candy-like odour and its previous uses in perfumery included deployment in re-odourant formulae & soaps. In flavourings safrole was used as an ingredient to flavour medicinal products and confectionery. IFRA prohibits the addition of safrole to fragrances as such, and limits the safrole content of perfumes formulated with safrole-containing essential oils (basil, nutmeg, sassafras, cinnamon leaf etc.) to 0.01% for both skin contact & non-skin contact fragrances. This causes a potential problem for utilization of many safrole-containing fragrance ingredients, such as nutmeg butter; safrole-free versions of various aromatic nutmeg ingredients are commercially available, but often lack the spicy-sweetness and body of the authentic versions.
In South America, the safrole-rich chemotype of Brazilian sassafras tree Ocotea pretiosa (Nees) Mez. has been over-exploited as a safrole-source (there is also a methyl eugenol chemotype). As early as 1966 Mors and Rizzini (Mors & Rizzine 1966) noted that O. pretosia was becoming scarce in Santa Catarina due to uncontrolled exploitation and the natural slow growth of the tree. So Brazil went from being a major supplier of sassafras oil in the ‘sixties, to being a minor supplier in the nineties. Vietnam took over the role of being the major supplier, felling the tree Cinnamomum parthenoxylon (Jack) Meisn. to distill the roots to produce hundreds of tons of sassafras oil Vietnamese annually. Cropwatch (2007) declared the tree as now being critically endangered in Northern & Central Vietnam. Other geographic sources of safrole include Yunnan, China, where C. parthenoxylon, Sassafras tzumu & fractions of C. camphora are utilized for domestic piperonyl butoxide & heliotropin manufacture.
In S.W. Cambodia, sassafras trees (‘Mreah Prew Phnom’) Cinnamomum parthenoxylon are especially found amongst the 2 million ha. of forest within the Cardamom mountains. On-going investigations of illegal oil-producing activity were started in 2004 by the Flora & Fauna International Group. In a recent move, made together with help from the Ministry of the Environment, illegal distilleries were discovered within the Phnom Samkos Wildlife Sanctuary, run by Vietnamese syndicates, producing sassafras oil from the shredded roots & trunk of the Mreah Prew Phnom trees
Rangers from the Phnom Sankos Wildlife Sanctuary prepare to dismantle illicit sassafras oil still. Credit D. Bradfield – FFI. (used with permission.)
Subsequent action by the Royal Cambodian Armed forces dismantled 2 factories and led to 2 arrests. Tim Wood, FFI Field Co-ordinator at the Phnom Samkos Sanctuary is quoted as expressing grave concern that the harvesting of these trees is destroying the fragile eco-system habitats within the sanctuary. The FFI press release describes the pollution of streams used for cooling water for the distillation, and mentions the abstraction of fuel wood to drive the distillation process. Local peoples fear that this rate of abstraction could push the forest & Mreah Prew Phnom trees to the brink of extinction within 5 years. As a mark of their success, the 25th Feb 2009 FFI press release also mentions the fact that in June 2008, 33 tons of illicitly produced sassafras oil were destroyed, and the 2009 FFI raids reported above have to be put in context – since previously in 2006 there were some 75 operating stills in the Western Cardamom Mountains. Now however, the FFI are apparently facing funding problems and need economic help to continue their work.
Chen C.-L., Chi C.-W., Chang K.-W., & Liu T.-Y. (1999) "Safrole-like DNA adducts in oral tissue from oral cancer patients with a betel quid chewing history." Carcinogenesis 20(12), 2331 - 2334
Daimon H., Sawada S, Asakura S. & Sagami F. (1998) "In vivo genotoxicity and DNA adduct levels in the liver of rats treated with safrole." Carcinogenesis 19, 141-146.
Flora & Fauna International 25th Feb 2009. “‘Ecstasy oil’ distilleries raided in Cambodia’s Cardamom Mountains.” Media Release, Phnom Penh, Cambridge.
IRIN –UN Office for Humanitarian Affairs “Cambodia: Ecstasy tabs are destroying the forest wilderness” – see http://www.irinnews.org/Report.aspx?ReportId=79340
Mors & Rizzini (1966) Useful Plants of Brazil pub. Holden & Day, 1966.
Segelman A.B., et al (1976). "Sassafras and herb tea: potential health hazards." JAMA 236(5),477.