June 01, 2008
Is This The End of The Indie Beauty Products Boom as We Know It?
The past decade has seen an explosion of small, independent aromatics products companies emerge from the kitchens and basements of America. From aromatherapy wellness products creators, indie natural perfumers, sultry incense formulators, handmade soap makers and makers of bath products galore - creative entrepreneurs have conjured up myriad offerings from bath fizzies to sugar scrubs to pampering spa products.
Then, along came the Food and Drug Administration Globalization Act of 2008, announced last month, proposing to give the FDA authority to affect new regulations that could stop the growth of this creative movement dead in its tracks. For some, it could be the end. Under the new rules proposed, The FDA could mandate an annual registration fee of no less than $2,000 (possibly more) per manufacturing facility. This could put some out of business.
The Personal Care Products Council (formerly the Cosmetic, Toiletry and Fragrance Association), has already testified before the House Committee on Energy and Commerce, outlining the self-regulatory efforts of the major cosmetic industry over the past several decades. From the written testimony of Pamela G. Bailey, CFO and President of the PCPC, "The result of manufacturer safety practices and voluntary initiatives under a existing framework of Federal law has been an outstanding safety record that has been commended by previous FDA Commissioners. Cosmetics and personal care products are the safest category of products regulated by the FDA." Stephen F. Sundlof, D.V.M., Ph.D., Center for Food Safety and Applied Nutrition, also submitted testimony which included the following: "We believe the proposed legislation should be more closely targeted and prioritized according to risk. Several of the legislative sections appear not to be sufficiently focused on high-risk products. Some of these requirements would divert resources, which could detract from important product safety and security priorities." While these larger entities are not arguing for or against the proposed legislation, these seem to be cautionary statements that would lead us to believe the larger industry has faith in existing industry efforts to self-regulate cosmetic safety via the CIR (Cosmetic Ingredient Review) established by CFTA in 1976 and funded entirely by the industry, evaluating more than 1,300 ingredients and publishing peer-reviewed scientific literature, available to the public.
We are fortunate to have Donnamaria Coles Johnson who because of her passion for cosmetics and beauty products has tirelessly championed for small beauty products companies. If you are a small cosmetic manufacturer and are not a member of the Indie Beauty Network, you are missing a plethora of ideas, education and networking to assist your business development. Donnamaria has put up a public page to address this latest FDA issue, open to the public for comments and suggestions. She will be preparing a position paper, using members' comments that will carry our voice to be heard by the Committees in charge of vetting public comments. You can find Donnamaria's message and governmental links here: http://www.indiebusinessforum.com/forumdisplay.php?f=41
We urge all small natural cosmetic manufacturers to keep abreast of this issue and join efforts as needed to make sure that indie business doesn't get left behind.
Posted by Marcia on June 1, 2008 in Certification, Organizations, Politics, Regulatory Issues, Research, Safety/Toxicity, Trade Issues | Permalink | Comments (1) | TrackBack
May 12, 2008
Organic/Natural Standards to be Discussed at Upcoming Meeting
The big players in the Beauty Products World are gathering together in New York later this week at "The Natural Beauty Summit" to "create a forum to learn and discuss the key challenges the cosmetics industry faces in the areas of natural and organic products as well as sustainability" . . . or so says the program for the conference, to be held at the Hilton Hotel in New York City May 15-17. This is a followon to a similar summit in Paris last November, to be followed by a sequel, again in Paris, in October 2008.
Sponsored by Organic Monitor and Beyond Beauty Paris, the main focus of this conference will be Natural Cosmetics with a major session on Standard & Regulatory Issues followed by a panel discussion, and the next day a Natural Cosmetics Workshop focusing on "an assessment of the growing number of standards and certifications for natural and organic cosmetics . . . [with] a critical review of the major standards, comparing and contrasting the similarities and differences between them."
The list of standards and proposed standards that will be covered at the session is:
- A Retail products standard proposed by Whole Foods
- the USDA National Organic Program Standard applied to Cosmetics
- the American NSF Standard
- the OASIS Standard
- A review of European natural and organic standards harmonization
- ECOCERT and BDIH
The aromaconnection blog will be following these issues closely as they develop. Notably missing from the above list is the NPA (Natural Products Association) standard we blogged about yesterday and last month. We are working on a table showing details of the standards and comparing their features. In fact, we are probably duplicating what may show up in the proceedings of the NBS (if there are any), but we hope to get it into print sooner.
Organic Monitor, one of the co-sponsors of the NBS, predicts that 2008 will be the beginning of "an industry shake-up" as various standards are unveiled in Europe and North America. In this linked article, they reference several standards that are not included on the list above. They also express concern about fragmentation that could lead to a reduction of trade, but express also the "more optimistic view" that Cosmetics might follow the lead of the textile industry and develop a harmonized global standard.
In the meantime the infighting has already begun. OCA and Dr. Bronner's have challenged what they call "weak" ECOCERT and OASIS standards, according to this OCA Press Release widely reported in the media mid-March. And as we reported yesterday, the C.A.M. Report is somewhat skeptical of the whole idea.
We can probably look forward to an exciting year!
Posted by Rob on May 12, 2008 in Marketing, Organizations, Politics, Regulatory Issues, Standards, Weblogs | Permalink | Comments (0) | TrackBack
May 04, 2008
Perfume Politics: The Oppressive Perfumer's Guild
Guilds are perhaps the precursors of modern trade unions, and also, paradoxically, of some aspects of the modern corporation. Guilds are actually small business associations and have little in common with trade unions. They are more like cartels in that they assume exclusive privilege to produce certain goods or services or dictate standards of a profession. Guilds can establish restrictive guidelines or a rigid system and can exclude those who do not abide. Guilds emerged with a similar spirit and character to the original patent systems and are not generally conducive to a democratic free flow of development and interaction.
In the modern democracy, we have created nonprofit organizations or NGO's intended to benefit a group by collective efforts and by providing public education or services that benefit society. Legal nonprofit corporations receive tax relief, but are required to provide public reporting and transparency. Such nonprofit endeavors are usually governed democratically and operated by officials periodically elected from within the membership. This creates a structure that will evolve the endeavor into the future separate from and not dependent on or owned by any one member.
The French Perfumer's Guild of antiquity was perhaps the worst example of the power a Guild over its members. Established by an edict of King Philippe-Auguste in 1190 (reconfirmed by patent letters by King Jean in 1357, again by King Henri III in 1582, and again by Louis XIV in 1658, the "confrerie des Maitres Gantiers et Parfumeurs") that primarily gave glovemakers of the extended medieval period the exclusive right (i.e., monopoly) to manufacture and sell cosmetics of all types. Why glovemakers, you ask? Gloves were made from leather tanned using urine and other toxic and putrid substances and needed to be scented before they could be respectably worn. The glovemakers were wealthy manufacturing businesses and they were quite adept at organized efforts to lobby each respective monarchy, reminding of the importance of their role in medieval society and thereby acquiring the sanction necessary to maintain their monopoly. And, one can also suspect that favors were extended. Today, we might call them bribes. As you can see, this monopoly continued for a long time and was grounded in the necessity for perfuming what would otherwise be unusable products - leather gloves. The corporation or guild, headed up primarily by master glovemakers, established the sole credentials of those who could sell gloves as well as perfumed goods and dictated the kinds of products they could manufacture . . . a long list including sachets with perfumed powders, compositions used in burners for environmental scent, pomades for the hair, soap, cosmetic creams, scented gloves and even tobacco. A quaint novelty to us today, but in common use then, was the "oyselets de Chypre." These were cloth birds in bright colors, decorated with feathers and stuffed with aromatic powders, then placed in ornate cages and hung from ceilings or walls to add fragrance to a room.
By 1750, there were 250 master perfumers, members of the corporation who had served 4 years as an apprentice and an additional 3 years as "compagnons" before reaching the status of master. For all intents and purposes, they were slaves, not free (until the Revolution that is) to work outside the confines of the guild or to develop their own trade and commerce. Only rarely were there exceptions, a notable one being René Le Florentin, Catherine de Medicis's personal and favorite perfumer. Le Florentin had a reputation for talent in creating scents and fabricating poisons! And, obviously Catherine was well positioned to demand for him premature status.
Everything changes. Along came the French Revolution, rendering perfume and other objects considered frivolous luxury symbols of excesses of the aristocracy out of favor. With the exception of popular scents like, "parfum á la Guillotine". Under the Terror, choice of scent indicated political affiliation, a kind of odorous password. Politically correct scents could literally save one from execution. Napoleon's return from conquering (so he claimed) Egypt, along with his renowned heroic status gave him the power to re-establish the importance of French manufacturing to the glory of the nation. His fondness for cologne bode well for the lagging perfume industry, establishing imperial commissions as well as scientific and technological research in organic chemistry . . . a science that would revolutionize the perfume industry in the latter half of the 1700's. Thus, the adjective "French" is aligned with the noun "civilization" and under a new empire, cosmetic luxury products had a more general and populist allure.
One would hope that we are beyond the oppressive restrictions imposed on the medieval creative perfume artists of the day and that individuality and inventiveness are the modern dictates for his or her endeavors and acceptance. And, that perfume guilds are fashioned after the democratic principles of modern non-profits and NGO's.
References
Stamelman, Richard, "Perfume: A Cultural History of Fragrance from 1750 to the Present", 2006, Rizzoli International Publications, Inc.
Classen, Constance, Howes, David, Synnott, Anthony, "Aroma: The Cultural History of Smell", 1994, Routledge Press
Newman, Cathy, "Perfume: The Art and Science of Scent", 1998 National Geographic Press
Posted by Marcia on May 4, 2008 in Certification, Education, History, Organizations, Perfumery, Politics, Regulatory Issues | Permalink | Comments (1) | TrackBack
April 30, 2008
Cropwatch at the Cross-Roads
Cropwatch Statement
After 4 or 5 years of continuous activity, Cropwatch has some choices to make. Do we go on the way that we have been, snapping at the ankles of those who run & regulate the aroma industry so badly, or should we 'old dogs' learn some new tricks? Cropwatch supporters, and organisations sympathetic to our aims, regularly offer us donations and advise us of potential sources of grants, to which we have always said 'no thanks, we're non-financed'. Our current thinking is that this might be a mistake, since we are limiting our potential effectiveness. .
We are certainly not asking everyone for money, but we are asking you to help us with some feedback on how a financial input could potentially help the aroma world to become a better & fairer place, so please mail us if you have any thoughts or ideas.
Our initial list of ideas to use donated funding would be:
1. To finance risk/benefit studies on natural aromatic products. This research is needed because the existing major players such as IFRA/RIFM, are set up only to investigate the risks/hazards of fragrance ingredients (but not the benefits), & EFFA can only present the safety risks of essential oils, absolutes, resinoids etc in terms of the imagined hazards of the individual contained chemicals, rather than adopting a holistic approach for the aromatic ingredient as a whole. Therefore both organisations are badly positioned to defend natural aromatic ingredients against the current avalanche of restrictive legislation. The EU Commissioners have previously declined to accept safety-data based on risk/benefit considerations, although we believe this policy to be untenable in the long-term - it is the norm in virtually every other regulatory area (biocides, agricultural chemicals, pharmaceuticals etc).
[Neither is this just a European problem. The U.S. House Committee on Energy and Commerce have just announced draft legislation (Global Harmonisation Act 2008) intended to stimulate discussion on how to provide adequate funding and authority for the FDA to ensure the safety of the nation's food, drug, medical device and cosmetic supply in an increasingly globalised marketplace. The draft legislation already highlights several areas which will affect the fragrance industry].
2. To develop statistical data on the adverse effects of restricted & prohibited aromatic materials. This data would be a potential bombshell to blow apart the over-precautionary approaches of the cosmetic regulators and career toxicologists, who are in such a powerful position in global regulatory circles. Where this data exists (e.g. the Schnuch data on alleged allergens) it is already causing red faces. The EU Commissioner has previously indicated to Cropwatch (Brussels 2007) that this type of adverse reaction data is inadmissible as safety evidence. But if you are familiar with English history, you might recall that King Canute failed to hold back the waves and so his followers realised he was not all-powerful. So too, the regulators will not be able to ignore the fact that many restrictions on natural products are based on corporate toxicological constructs which don't manifest in the great numbers of negative health effects predicted.
3. To assist with the growing & production of useful commodities from threatened aromatic plants, for cosmetic, aromatherapeutic, flavour & medicinal outlets, in a way that benefits the poor.
4. To set up or help set up a natural aromatics products professional body, with the help of other interested parties. Already we can identify several sub-divided areas which badly need assistance: natural perfumery, the use of naturals within conventional perfumery, natural biocides, herbal drugs & medicines, aromatherapy, natural cosmetics etc.
5. The lobbying of officials & regulators. As we have seen, the more the establishment closes ranks (and its mind) to contrary & dissenting views, the more popular support we have been able to attract. In terms of numbers we are potentially a powerful force. However we have to ask ourselves whether there is any point in continuing the lobbying game. Many of the points we make go unanswered because the officials involved are not sufficiently technically adept or experienced to even understand the arguments put forward. So is it better to plough ahead with a voluntary regulatory system of our own making - at least we might have the experience, familiarity & resources to do a better job. The enormity of the task is detracting, but this is put more into perspective if sufficient funding were to be available.
6. To keep the flame of our traditional perfumery heritage alight. When we read that several major aroma corporations are training fledgling perfumers in pure synthetic perfumery, it makes us wonder if the world has gone quite mad. Once perfumers used to be creative artists with forthright temperaments, views and opinions, passionate about their art. Now, are we all to be reduced to company drones? I was related a story recently concerning a certain essential oils salesman who offered unmarked samples of real good quality Bulgarian lavender oil, and a synthetic lavender construct to a group of young perfumers at a certain megacorporation. The group preferred the artificial lavender construct because "it smelled like linalyl acetate, like its supposed to." Heaven help us! But maybe some of us 'old-timers' should organise courses & lectures to pass on the 'ancient knowledge of the art of perfumery' before it is lost forever.
OK, after 5 or so years of trying, we pretty much know what the problems facing us are - what we don't have is a consensus on the best way to solve them. Maybe you can help?
Cropwatch Team
Posted by Tony Burfield on April 30, 2008 in Organizations, Perfumery, Politics, Regulatory Issues, Research, Safety/Toxicity | Permalink | Comments (0) | TrackBack
April 22, 2008
Earth Day 2008
"The President in Washington sends word that he wishes to buy our land. But how can you buy and sell the sky? The land? The idea is strange to us. If we do not own the freshness of the air and the sparkle of the water, how can you buy them? Every part of this earth is sacred to my people. Every shining pine needle, every sandy shore, every mist in the dark woods, every meadow, every humming insect. All are holy in the memory and experience of my people. We know the sap which courses through the trees as we know the blood that courses through our veins. We are part of the earth and it is part of us. The perfumed flowers are our sisters. The bear, the deer, the great eagle, these are our brothers. the rocky crests, the juices in the meadow, the body heat of the pony, and man, all belong to the same family. The shining water that moves in the streams and rivers is not just water, but the blood of our ancestors. If we sell you our land, you must remember that it is sacred. Each ghostly reflection in the clear waters of the lakes tells of events and memories in the life of my people. The waters murmur is the voice of my fathers' father. The rivers are our brothers. They quench our thirst. They carry our canoes and feed our children. So you must give to the rivers the kindness you would give any brother. If we sell you our land, remember that the air is precious to us, that the air shares its spirit with all the life it supports. The wind that gave our grandfather his first breath also receives his last sigh. The wind also gives our children the spirit of life. So, if we sell you our land, you must keep it apart and sacred, as a place where man can go to taste the wind that is sweetened by the meadow flowers. Will you teach your children what we have taught our children? That the earth is our mother? What befalls the earth befalls all the sons of the earth. This we know: the earth does not belong to man, man belongs to the earth. All things are connected like the blood that unites us all. Man did not weave the web of life, his is merely a strand in it. Whatever he does to the web he does to himself. One thing we know: our god is also your god. The earth is precious to him and to harm the earth is to heap contempt on its creator. Your destiny is a mystery to us. What will happen when the buffalo are all slaughtered? The wild horses tamed? What will happen when the secret corners of the forest are heavy with the scent of many men and the view of the ripe hills is blotted by talking wires? Where will the thicket be? Gone? Where will the Eagle be? Gone! And what is it to say goodbye to the swift pony and the hunt? The end of living and the beginning of survival. When the last red man has vanished with his wilderness and his memory is only the shadow of a cloud moving across the prairie, will these shores and forests still be here? Will there be any of the spirit of my people left? We love this earth as a newborn loves its mothers heartbeat. So, if we sell you our land, love it as we have loved it. Care for it as we have cared for it. Hold in your mind the memory of the land as it is when you receive it. Preserve the land for all children and love it, as God loves us all. As we are part of the land, you too are part of the land. This earth is precious to us. It is also precious to you. One thing we know: there is only one God. No man, be he red man or white man, can be apart. We ARE all brothers after all."
-Chief Seattle
The nature Conservancy Earth Day Ideas
Take action for climate crisis solutions at we
Recycle old computers, cell phones and other electronics
Earth Day official events and activities
Professional advice for business sustainability initiative
Earth Day Facts from Rochester, NY plus more links
Make every day Earth Day from Madison, Wisconsin
Adverse effects of palm oil by Dove from Greenpeace
We can do it! from Sierra Club
The Rainforest Initiative
Whitefeather Forest Initiative
The African Conservation Foundaton
Long list of intragovernmental, governmental and private (NGO) environmental orgs
That ought to keep us busy.
Happy Earth Day! from all of us at the aromaconnection group blog.
Posted by Marcia on April 22, 2008 in Conservation, Ecological/Cultural Sustainability, Events, Human Rights, Organizations, Politics, Regulatory Issues, Research | Permalink | Comments (0) | TrackBack
January 03, 2008
Too Much Perfume may indicate Depression
Can’t smell the roses? Maybe you’re depressed. Smell too much like a rose yourself? Maybe you’ve got the same problem. Scientists from Tel Aviv University recently linked depression to a biological mechanism that affects the olfactory glands. It might explain why some women, without realizing it, wear too much perfume.
This according to research at Tel Aviv University reported in Science Daily that suggests that depressed women are also losing their sense of smell, and may use more perfume to overcompensate.
It appears that an autoimmune mechanism may be responsible:
In lupus patients and those with other autoimmune diseases, a particle known as an “autoantibody” attacks the person’s own immune system, appearing in the human body as an aberrant reaction to autoimmune diseases. This particle “is a real novelty,” says Prof. [Yehuda] Shoenfeld. “We have found that, when generated, it weakens a person’s sense of smell and can induce the feeling of depression.”
Unfortunately the original study wasn't cited. By some creative Googling, I was able to trace it back to the original press release (substantially the same as the Science Daily article) and eventually to this study published in the Journal of Autoimmunity, and to another study in Autoimmunity Reviews from 2006 that looks at the relationship between brain illnesses and olfaction. The latter study suggests that deterioration of the sense of smell may be used in the prediction of brain illnesses, and a number of other links from the abstract lead to other olfaction studies.
The Science Daily article and the press release mention the use of aromatherapy in the retail industry to change moods and encourage sales. Professor Schoenfeld suggests that this research may help change attitudes towards aromatherapy.
“I think that science is able to show that aromatherapy might not be just for quacks. After all, some of these remedies have been used since the time of the Egyptians to treat organic diseases.”
Posted by Rob on January 3, 2008 in Aromatherapy, Organizations, Research | Permalink | Comments (0) | TrackBack
November 05, 2007
News from Cropwatch November 2007
Co-founder of Cropwatch, Tony Burfield, has been invited to give an address to the UEAPME (European Association of Craft, Small and Medium-sized Enterprises) Cosmetics Forum in Brussels on 9th November 2007, describing Cropwatch's activities in the aromatic sector, & focusing on the difficulties that SME's (micro-, Small & Medium sized Enterprises) have with the existing European Cosmetics Directive, its seven amendments and its forty or so technical adaptations to progress, with a view to its ultimate simplification. A simplification of the Cosmetics Directive was originally proposed to improve the competitiveness of industry within the EU, the world’s largest cosmetic market. However there are some signs that the EU Commissioners have been looking back over their shoulders and have seen how the Chinese cosmetics market is growing 10% year on year, a rate of expansion unmatched by the European market.
Meanwhile Cropwatch has completed an extensive update of threatened species in the aroma raw materials trade, to be released shortly, and to be followed later by similar comprehensive review for non-aromatic cosmetic raw materials. The aroma materials review features several new areas of ecological concern, including balsams such as gurjun balsam, widely used as a fixative & cheap filler in perfume compounds. In addition we also highlight the pressure on linalol-containing essential oils by including new entries for ho wood oil, now that the market understands that the Chinese authorities are currently preventing linalol chemotypes of Cinnamomum camphora trees from being destructively harvested. This will lead to severe shortages of ho oils (as has happened several times over the last several years) or may terminate their supply completely. As your readership may guess, we can now trace a progression of ecological pressure on linalol-bearing trees, from linaloe oil produced from chipped wood of the now severely threatened Mexican Bursera glabrifolia tree (which was introduced into India). The deterioration in quality of linaloe oil around 1920 or thereabouts led to the market looking to rosewood from French Guiana as a second best choice as a linalol-containing essential oil (in spite of what you may read elsewhere!). The over-exploitation of rosewood trees in French Guiana and eventually from Brazil, lead to scarcity & together with rising oil costs, has since favoured the use of ho oils. Although ho wood oil is neither an odour match/substitute for rosewood oil, the rectified forms of ho oil with negligible camphor content have provided a highly exploitable source of 98-99% natural laevo-linalol, often at a bulk price cheaper than synthetic racemic linalol. Where will the market go now to find natural linalol? The answer perhaps lies with more extensive production coriander seed oil from which attractively-odoured dextro-linalol is easily isolated. Unfortunately coriander seed is currently quite scarce, and therefore the essential oil is relatively expensive.
Cropwatch updates contentious areas such as animal products used in fragrances, and examines the differing interpretations of CITES meeting outcomes over animal by-products such as ambergris, as shown by national governments (e.g. Australia). We also feature a definition of natural products which includes no animal-derived materials and the key phrase "must benefit the poor". As an example of matters working in the opposite situation, we look at the Buchu oil situation in South Africa. In spite of industry trade hype and grandiose statements from SA government agencies talking up the future of SA buchu oil production, the situation on the ground has not been properly explained. Whilst the manner in which wild-gathering of buchu (which included uprooting the plant from the ground, including the roots) undoubtedly further endangered its ultimate survival, it also gave desperately needed income to S. African peoples, some 20% of whom live in total abject poverty. Now legal moves on buchu gathering (permits are required for growing & gathering) give powerful sole rights to rich farmers and prevent “buchu poaching”, ultimately endorsing an industry which has been described as “plagued by Mafia-like hierarchy and overt corruption” (Ashoton 2003). Its' hard to see how these moves can "benefit the poor", rather, as with many other valuable aroma products, the rich seem to get richer, at the direct expense of the poor.
In the update we look more intently at the sandalwood industry and Australian officials’ apparent ambitions to corner the market, & we suggest by inference that government scientists who talk-up the sandalwood oil prospects in the world markets should learn to speak in the widely understood terms which the market uses. We further update Aquilaria (agarwood) entries to CITES Appendix II listings and speculate that a new generation of young aromatic material users will only have the opportunity to experience adulterated or low grade plantation products (for both gaharu & sandalwood qualities), and that the 'old hands' in the trade are rapidly forgetting what the 'real stuff' used to smell like. We substantiate this theory by quoting the amounts of both West African sandalwood oil and logs, and the amount of Australian sandalwood logs delivered to East Indian Sandalwood distilleries. Smell a rat anybody?
In the next Cropwatch Newsletter we also feature a presentation by Professor Jurgen Reichling of the University of Heidelberg given at the 38th ISEO Symposium in Graz in Sept 2007 entitled “External application of essential oils in animals. In addition we feature a presentation by Dr. Hassan Khalid et. al. on “Trade of Sudanese natural medicinals and their role in human & wildlife healthcare.”
Cheers,
Tony.
Posted by Rob on November 5, 2007 in Ecological/Cultural Sustainability, Ecological/Cultural Sustainability, Notes and News, Notes and News, Organizations, Organizations, Regulatory Issues, Regulatory Issues | Permalink | Comments (0) | TrackBack
News from Cropwatch November 2007
Co-founder of Cropwatch, Tony Burfield, has been invited to give an address to the UEAPME (European Association of Craft, Small and Medium-sized Enterprises) Cosmetics Forum in Brussels on 9th November 2007, describing Cropwatch's activities in the aromatic sector, & focusing on the difficulties that SME's (micro-, Small & Medium sized Enterprises) have with the existing European Cosmetics Directive, its seven amendments and its forty or so technical adaptations to progress, with a view to its ultimate simplification. A simplification of the Cosmetics Directive was originally proposed to improve the competitiveness of industry within the EU, the world’s largest cosmetic market. However there are some signs that the EU Commissioners have been looking back over their shoulders and have seen how the Chinese cosmetics market is growing 10% year on year, a rate of expansion unmatched by the European market.
Meanwhile Cropwatch has completed an extensive update of threatened species in the aroma raw materials trade, to be released shortly, and to be followed later by similar comprehensive review for non-aromatic cosmetic raw materials. The aroma materials review features several new areas of ecological concern, including balsams such as gurjun balsam, widely used as a fixative & cheap filler in perfume compounds. In addition we also highlight the pressure on linalol-containing essential oils by including new entries for ho wood oil, now that the market understands that the Chinese authorities are currently preventing linalol chemotypes of Cinnamomum camphora trees from being destructively harvested. This will lead to severe shortages of ho oils (as has happened several times over the last several years) or may terminate their supply completely. As your readership may guess, we can now trace a progression of ecological pressure on linalol-bearing trees, from linaloe oil produced from chipped wood of the now severely threatened Mexican Bursera glabrifolia tree (which was introduced into India). The deterioration in quality of linaloe oil around 1920 or thereabouts led to the market looking to rosewood from French Guiana as a second best choice as a linalol-containing essential oil (in spite of what you may read elsewhere!). The over-exploitation of rosewood trees in French Guiana and eventually from Brazil, lead to scarcity & together with rising oil costs, has since favoured the use of ho oils. Although ho wood oil is neither an odour match/substitute for rosewood oil, the rectified forms of ho oil with negligible camphor content have provided a highly exploitable source of 98-99% natural laevo-linalol, often at a bulk price cheaper than synthetic racemic linalol. Where will the market go now to find natural linalol? The answer perhaps lies with more extensive production coriander seed oil from which attractively-odoured dextro-linalol is easily isolated. Unfortunately coriander seed is currently quite scarce, and therefore the essential oil is relatively expensive.
Cropwatch updates contentious areas such as animal products used in fragrances, and examines the differing interpretations of CITES meeting outcomes over animal by-products such as ambergris, as shown by national governments (e.g. Australia). We also feature a definition of natural products which includes no animal-derived materials and the key phrase "must benefit the poor". As an example of matters working in the opposite situation, we look at the Buchu oil situation in South Africa. In spite of industry trade hype and grandiose statements from SA government agencies talking up the future of SA buchu oil production, the situation on the ground has not been properly explained. Whilst the manner in which wild-gathering of buchu (which included uprooting the plant from the ground, including the roots) undoubtedly further endangered its ultimate survival, it also gave desperately needed income to S. African peoples, some 20% of whom live in total abject poverty. Now legal moves on buchu gathering (permits are required for growing & gathering) give powerful sole rights to rich farmers and prevent “buchu poaching”, ultimately endorsing an industry which has been described as “plagued by Mafia-like hierarchy and overt corruption” (Ashoton 2003). Its' hard to see how these moves can "benefit the poor", rather, as with many other valuable aroma products, the rich seem to get richer, at the direct expense of the poor.
In the update we look more intently at the sandalwood industry and Australian officials’ apparent ambitions to corner the market, & we suggest by inference that government scientists who talk-up the sandalwood oil prospects in the world markets should learn to speak in the widely understood terms which the market uses. We further update Aquilaria (agarwood) entries to CITES Appendix II listings and speculate that a new generation of young aromatic material users will only have the opportunity to experience adulterated or low grade plantation products (for both gaharu & sandalwood qualities), and that the 'old hands' in the trade are rapidly forgetting what the 'real stuff' used to smell like. We substantiate this theory by quoting the amounts of both West African sandalwood oil and logs, and the amount of Australian sandalwood logs delivered to East Indian Sandalwood distilleries. Smell a rat anybody?
In the next Cropwatch Newsletter we also feature a presentation by Professor Jurgen Reichling of the University of Heidelberg given at the 38th ISEO Symposium in Graz in Sept 2007 entitled “External application of essential oils in animals. In addition we feature a presentation by Dr. Hassan Khalid et. al. on “Trade of Sudanese natural medicinals and their role in human & wildlife healthcare.”
Cheers,
Tony.
Posted by Rob on November 5, 2007 in Ecological/Cultural Sustainability, Ecological/Cultural Sustainability, Notes and News, Notes and News, Organizations, Organizations, Regulatory Issues, Regulatory Issues | Permalink | Comments (0) | TrackBack
November 03, 2007
EcoPort: A Biodiversity Data Base Tool
When I first discovered EcoPort:the consilience engine I was quite excited. I had discovered a tool for classifying and tracking the biological diversity of the Earth, in particular, from my interest point, the aromatic diversity. After I had explored it a bit, I began to realize that this tool has the potential for doing what I wanted, but because the database is not populated to any great degree for aromatic plants, it probably isn't as useful as I had hoped.
The database has a powerful and fast search engine that allows searching its own and several other databases. I tested it with lavender and vetiver. Searching for all entities with lavender brings a long list of animals and plants with lavender in their name; you need to limit the search to Plants. Once you get the list of plants, you can click on a link to pictures, or to a main entry. You can then get a lot of information about the plant, its biology, its uses, etc. There are some links to other databases with additional information.
Ecoport is like Wikipedia in that it is designed for the users to enter additional information. You need to be an editor and I get the impression that there aren't that many. To make it truly usable for aromatic plants, our community needs to organize the effort to update the database. We have our own databases that have been developed by individuals and who usually hope to be compensated for their hard work, so it may be difficult to find volunteers or public domain information to update the Ecoport database with.
If you want to find out more about this tool, you can link to their information page for a good description of the goals and purposes. But the best way to find out about it is to jump in with both mouse fingers to the entry page and then the search engine. Browse around and try it out. Or check out the sponsors page that lists 208 organizations throughout the world that have supported or participated in Ecoport.
Posted by Rob on November 3, 2007 in Biology, Ecological/Cultural Sustainability, Organizations | Permalink | Comments (0) | TrackBack
October 29, 2007
ICMAP
One of the projects we are working on for the blog is to catalog all the various organizations and entities that deal with the subject matter of the blog. We've established a database for organizations and web sites and are working on filling it out. It is a work in progress and will probably never be completed as new entities are discovered and then we add the links to other organizations that are on their link sites. Our intent is to write a series of blogs about the various aspects of the world aromatic community. We started with regulatory agencies, both governmental and non-governmental, and started following links from them, some to others we already have in our data base, and others that branch out into entirely new areas. Today I came across entry 108, which of course will lead to another half dozen organizations from their link page, a few of which we already have but there will probably will be at least two or three new ones. Obviously, at this rate if we wait until the list is finished (or appears finished) to start writing about the organizations, we'll never get anything written, you will never find out about all the neat things we are discovering, and the organizations will never receive the interest or (in some cases) scrutiny they deserve. So I've decided to start a series of blogposts about them as I find them. The analysis of the interconnections will come later as we gather all the links. (As you'll see below, in the process of writing this post, I've discovered two links, without even going to their link page--which has 15 more.)
So, to start out this series of posts, that will be categorized under Organizations, I'm going to start with:
ICMAP is the INTERNATIONAL COUNCIL for MEDICINAL and AROMATIC PLANTS. Established in 1993 following the recommendation of the 1st World Congress on Medicinal and Aromatic Plants for Human Welfare (WCOMAP), on it's website the organization describes itself as:
an international non-governmental body with the name: International Council for Medicinal and Aromatic Plants (ICMAP) with the general objective as promoting international understanding and cooperation between national and international organizations on the role of medicinal and aromatic plants in science, medicine and industry, and to improve the exchange of information between them.
This Council coordinates and stimulates cooperation between partners by providing a forum for mobilizing ideas, actions, discussions, long term visions, measures in education and training in all fields related to these plants that play such an important part in the lives of human beings throughout the world.
The group is has a Secretariat in Turkey and holds World Congresses every five years. The next world Congress on Medicinal and Aromatic Plants for Human Welfare will be will be co-organized on 9-14 November 2008 in Cape Town, South Africa (held in conjunction with the African Association for Medicinal Plant Standards).
The organization publishes a Newsletter and News Sheet which are available on their web page (enable popups and click on the dropdown to select the one you want to read or print out).
An interesting feature on the web site was this mysterious symbol.
When clicked, it leads to another interesting web site that will be the subject of the next post in this series.
Posted by Rob on October 29, 2007 in Organizations | Permalink | Comments (0) | TrackBack
September 27, 2007
Events of Interest
ALLIANCE OF INTERNATIONAL AROMATHERAPISTS: After 5 years of developing educational newsletters and teleconferences as well as a staging a successful conference in 2005, the group formed as Aromatics in Action has officially launched under their new name, Alliance of International Aromatherapy. Now a fully-formed 501(c)3 nonprofit, they are holding their second major conference in Denver CO October 18-21, entitled Celebrating the Past - Creating the Future of Clinical Aromatherapy. Presentation topics are diverse and contemporary and are sure to challenge and excite those who attend, covering safety issues, sustainability, clinical research, product quality and purity, global and planetary healing and a wide range of issues confronting aromatherapy. . . including, very smartly, a session on Growing a Successful Organization presented by Sonja Simpson who will help inform strategies as a potential plan of action for the continued success of AIA. The efforts of this emerging organization are to be commended and the event appears a welcome turn towards a more progressive organized effort for aromatherapy in the U.S. The only downside is that the event conflicts with other important gatherings in the broad range of interest to some who might otherwise attend.
WILD PLANT HARVEST: OPPORTUNITIES AND THREAT: Aromatic plants, along with their medicinal, food and ornamental counterparts, are more and more frequently harvested from the wild, including public lands. If harvested in a sustainable way, these nontimber forest products (NTFP's) can provide economic benefits to forests and the people who harvest them, largely in rural communities. The 2007 Janet Meakin Poor Research Symposium scheduled for Friday, October 19, will feature a variety of topics to address ecological implications, sustainable harvesting, policy issues and international trade, and other management issues. Keynote luminary, Dr. James A. Duke will present a slide lecture covering Medicinal Plants of the bible featuring slides by Peggy Ann K. Duke and a highlight will be the presentation of an international, multidisciplinary collaborative effort to value the pharmaceutical potential of plant diversity of Cuc Phuong National Park in N. Vietnam, presented by Dr. Djaja Doel Soejarto, professor of pharmacognosy and biology, University of Illinois at Chicago. Other featured speakers include Colin Donohue, executive director of the National Network of Forest Practitioners (NNFP), Dr. Tamara Ticktin, associate professor of botany U. of Hawaii at Manoa with others. Online registration deadline October 12.
If you have a major symposium or conference you wish us to announce in this periodic column, please send information and internet link to info@aromaconnection.org.
Posted by Blogmistress on September 27, 2007 in Aromatherapy, Conservation, Ecological/Cultural Sustainability, Organizations | Permalink | Comments (0)
September 24, 2007
Over-regulation Could Destroy Natural Aromatics
Cropwatch (Tony Burfield et al) presented a keynote paper on Regulation of Natural Aromatics at the 38th International Symposium on Essential Oils in Graz, Austria on 12th Sept. 2007. A copy of the full paper is posted on the Cropwatch website here. We'll be blogging about this in more detail, but if you have time, you should read the entire paper, which goes into many details about how natural aromatics are being over-regulated.
The paper presentation starts out with this historic photo:
[Note to American Readers: this may seem less relevant to us because Cropwatch is trying to deal with the European Union regulations, but they are coming after us, too. Between the Codex attempts to "harmonize" food regulation, global trade laws, and side effects from confusion over the proper role of the FDA which under-regulates some things and over-regulates others, we may at some point find outselves fighting the same battles.]
Posted by Rob on September 24, 2007 in Ecological/Cultural Sustainability, Organizations, Perfumery, Regulatory Issues | Permalink | Comments (0)
September 01, 2007
More EU Allergens regulation by the back-door
Tony Burfield has sent out an emergency supplement to the Cropwatch Newsletter alerting us that IFRA and EFFA appear to have found a back-door way to sneak a number of fragrance substances into the "26 allergens" legislation without following due process and allowing public comment. I'm not as familiar as I should be with the intricacies of the EU regulatory system, and I haven't quite figured out the details of how it will work. Tony has submitted a formal objection to the process and in his e-mail states:
We go into high gear on the opposition front if this presently-sought SCCP Opinion goes ahead - Cropwatch is not prepared to watch the destruction of what is left of the European fragrance/essential oils industry by moves like this coming from career toxicologists who do not work in the industry, & their seemingly bemused & obedient EU lawmaking counterparts, without a fight.
Unfortunately the Cropwatch website seems to down right now, so I can't effectively link to the objection PDF. I will do so as soon as it is back up. And if the site isn't back up by Tuesday I'll post the document here.
UPDATE: Cropwatch is back up but Tony hasn't yet posted the document; he generally lags a few days behind the date he mails to his subscribers.
UPDATE2: Tony now has the pdf document posted here.
Posted by Rob on September 1, 2007 in Organizations, Politics, Regulatory Issues | Permalink | Comments (0) | TrackBack
July 09, 2007
Meeting Between Cropwatch - The Perfume Foundation
Meeting Between Cropwatch - The Perfume Foundation
& the EU Cosmetics Commission Staff, Brussels, July 3rd 2007
[N.B. The following is Tony Burfield’s personal account of the meeting proceedings, and does not represent the agreed minutes, or represent the opinions of the other attendees].
Introduction
Representatives from Cropwatch and The Perfume Foundation met senior personnel from the EU Cosmetics Commission at their avenue d’auderghem offices in Brussels on the afternoon of Tuesday July 3rd 2007 for a meeting that lasted 1h. 40 mins.
Tony Burfield, Co-founder Cropwatch
Creezy Courtoy, Chairman, Perfume Foundation
Henke Meijerink, Technical Director, Perfume Foundation
Sabine Lecrenier Head of Unit, Cosmetics Commission
Barbara Mentré, Administrator, Cosmetics Commission
Takis Daskaleros, Senior Administrator, Cosmetics Commission
Annette Orloff, Seconded National Expert, Cosmetics Commission
This cordial and constructive meeting started with individuals from all parties briefly explaining their respective roles, operating briefs & constraints. In what must be at times a difficult & maybe under-resourced position, the Commissioner explained the role of Safety Management & the role of DG Ent (Risk Assessment).
Areas of Improvement
The Commission staff explained that Cropwatch’s opinions had been instrumental into revisions of procedures Areas for improvement include transparency, data-gathering & the recruitment of further expertise e.g. in botany/economic botany. We all welcome attempts to strive for better standards & performance.
Areas of recommendation
Cropwatch was deeply concerned at the level of reliance & trust placed with industry & its privately funded research organizations, both to provide scientific data to the SCCP, & to source authentic samples of cosmetic ingredients for scientific investigation. The forwarding (say, to the SCCP, by industry) of a careful selection of certain scientific publications on cosmetic ingredients can, of course, provide the potential to generate slanted Opinions & policy, unless balancing data from more comprehensive data-base searching is made available. Further, the opportunity for the continuing development of ‘Corporate Science’ (as opposed to truly Independent Science) is surely present where so many industry-based toxicologists are busy employed feeding (often unchallenged) data into EU expert committees. There is a need for an independent assessor as a buffer between industry-generated information & EU scientific administrative staff & lawyers.
An urgent recommendation was also made by Cropwatch to independently establish sample authentication, batch tracking & purity data for proffered commercially sourced samples, & to send back submitted data where these requirements are not satisfactorily established. This will save a considerable amount of time in preventing the adverse reactions of ingredients being wrongfully ascribed to the substance under investigation instead of the synthetic impurities.
Areas of Disagreement
Cropwatch & the Perfume Foundation identified a number of areas where the parties have fundamentally opposing views. .
1. Cropwatch & The Perfume Foundation believe that we need to establish a Fragrance Commission which is specifically concerned with the matters concerning fragrance regulation. Fragrance covers not only cosmetics, toiletries & fine fragrances, but air-freshners, candles & incense, & household & miscellaneous categories also. The alternative can only be that the EU Cosmetics Commission urgently reforms, correct & modify its existing remits & practices.
2. Risk-benefit analyses for the evaluation of the safety of fragrance ingredients was ruled out as a` possibility by Takis Daskaleros in conversation. This is not acceptable to Cropwatch, who anyway believe that EU staff misunderstands the concept of ‘benefit’ in this context – but there was not an opportunity at the meeting to explore this point further.
3. Since fragrance is as much a high-art form as much as it is a science, the existing. tunnel-visioned approach by the present Commission to perfume safety to the exclusion of socio-economic, ecological, cultural & heritage matters is simply not acceptable. Joined-up thinking with regard to consequences of cosmetic policies needs urgent consideration, perhaps in conjunction with other EC or globally-based organizations. At a time when we are all working for a better & greener planet, the Cosmetics Commission cannot excuse from the ecological consequences of its policies just because of its authoritative position.
4. Although the Cosmetics Commission is responsible for seeing that manufacturers place safe cosmetics on the marketplace, the Commission point-blank refuses to define “safety”. We believe that this position is untenable. European taxpayers are entitled to a quantification of the relative risks of using cosmetic preparations & ingredients. We further believe that the latest SCCP operating CoP (which maintains that risk assessment quantification is outside its scope) needs rewriting to justify its policies wrt to perceived risk.
5. Expanding point 3 above, joined-up thinking is especially applicable to the socio-economic & ecological aspects associated with banning or restricting cosmetic ingredients, where, as a consequence of natural ingredient usage decline, it causes hardship or threaten survival of the natural resource (cf. Peru Balsam forests in El Salvador). Cropwatch believes that cultivation or processing technical fixes are available for many of the adverse reactions produced by restricted ingredients, and we need to find funding solutions to help those social groups which are directly affected.
Individual Issues
1. Furanocoumarins. We understand that the RIFM-contracted studies on the individual FCF’s bergamottin & isopimpinellin which were undertaken by Prof. David Kirkland of Covance UK, have been forwarded to the SCCP. Cropwatch has asked that these privately submitted studies be made available for public scrutiny in the interests of transparency.
Cropwatch believes that limitation of FCF’s to 1 ppm in cosmetic products will be economically divisive and set the stage for violation of Fair Trading Principles [i.e. it will selectively disadvantage SME’s and those operating from undeveloped regions in the citrus commodity sector, who cannot afford the investment in technology to reduce FCF levels]. Cropwatch is further asking for a public consultation on the issue.
2. Inhalation toxicity.
Cropwatch-Perfume Foundation representatives were somewhat aghast to learn that inhalation toxicity / allegations of adverse connections between perfume & breathing problems, asthma etc. hardly figured on the Commissions agenda, showing how much, in our opinion, dermatological matters have over-influenced EU cosmetic safety policy, to the detriment of other areas of concern. We were assured that this omission would be put right.
3. The single ingredient approach to toxicology.
The FCF issue is a particular illustrative case where ‘laboratory bench’ investigations of the alleged toxicity of an isolated single component within a complex biological matrix may be completely misleading. We need protocols that investigate the toxicity of the actual complex ingredients themselves rather than isolated versions of the individual constituents of the ingredients, versions which are often impure (with unspecified impurities), or composed of the wrong isomer(s) compared with the natural isolate.
4. SCCP Reform. Cropwatch has been asking research teams who have submitted data to the SCCP (either indirectly via published papers, or who have submitted data directly to the SCCP), whether they consider that their work has been fairly & correctly expertly assessed & reviewed in an unbiased manner. Although Cropwatch has only carried this out on a very limited scale, the results are alarming. An urgent internal investigation is needed.
Further, Cropwatch & many of its supporters do not consider Ian White as a suitably independent & unbiased chairman of the SCCP. We would like to have certain SCCP Opinions independently re-examined, and we intend to submit or publish evidence, to support this endeavor.
5. Subject areas for safety re-assessment. There is a large group of people with independent scientific opinions who do not necessarily agree with the findings, views and policy of the EU Cosmetics Commission, and most especially with its ‘expert’ advisers. These issues include the subjects of alleged methyl eugenol carcinogenicity, certain banned or restricted materials within the Cosmetics Directive, & the large & controversial subject of alleged sensitisers amongst common aroma ingredients.
Conclusions
Although areas of disagreement are both considerable & deep, this initial meeting was very encouraging and sets an optimistic air for the future. Cropwatch would like to thank the Brussels staff for the valuable opportunity to dialogue and for each party to have an insight into each others’ policies.
Tony Burfield
July 9, 2007.
Posted by Tony Burfield on July 9, 2007 in Organizations, Perfumery, Regulatory Issues | Permalink | Comments (0) | TrackBack
June 29, 2007
A Sweet-Smelling Union/Cropwatch & The Perfume Foundation
Tony Burfield has announced what appears to be a much-needed alliance and collaboration between The Perfume Foundation and his organization, Cropwatch. This effort will certainly bring sensible debate to offset the disturbing mandates coming down from regulatory agencies, as well as give a leg up to artisan natural perfumers and aromatherapists by promoting agro-commerce in aromatic crops and supporting under-represented indigenous producers in the current legislative dialog and marketplace. Tony, a blogger here on Aromaconnection, is applauded and supported by other bloggers here for this endeavor.
The following is an excerpt from Cropwatch's June Newsletter announcing the alliance:
Preamble
A collaboration is announced to pursue mutual objectives for the further promotion of the Perfumery Art is announced between The Perfume Foundation & Cropwatch.
The Perfume Foundation has been operating in Brussels since 1995, and states that its mission is “to be the leading authority on environmental and health issues related to fragrances and scents, while contributing to the cultural heritage of perfume.”
Cropwatch really commenced in earnest from 2004 as an Independent Watchdog to the Aroma trade, initially to try to counter the commercial over-exploitation & bio-piracy of rare & threatened natural aromatic plants. More recently Cropwatch has tried to counter regulatory threats against the sustainability of natural product usage in everyday life.
Mutual Interest Projects:
1. To assemble, facilitate & expand the exchange of scientific information on fragrance matters.
2. To achieve a critical mass of experts in order to challenge some of the wrongheaded outcomes from deliberations of existing governmental legislators.
3. To work to launch the “Campaign for Real Perfumes” Underlying this is the belief that natural ingredients should not be unduly discriminated against by legislators. The scope and details of this campaign are still being discussed.
4. To promote agro-commerce in safe natural aromatic materials for fragrance production in order to facilitate artisan perfumery. This may include the support of producers in undeveloped nations who are discriminated against by legislation, i.e. legislation which will only allow usage of ingredients which have been subject to high technology (& therefore high investment cost) processing.
5. To create “The Perfume Embassy” office in Brussels as an ambassador of perfume excellence.
The Problems to Overcome.
Fragrance regulation in the EU unfortunately occurs within the cosmetics sector, rather than being subject to its own Fragrance Commissioner and fragrance expert advisers. Anyone working within the cosmetics sector will be totally aware that fragrance expertise is separate and non-complementary to cosmetics expertise. Because of the way the administration has been set up within the EU, a number of critical mistakes have been made in the way the Cosmetics regulatory process operates. These mistakes need to be properly identified and put right.
Proposed Events
It is proposed that a conference be held in Brussels at a date to be announced. The conference would feature speakers with views at variance with those expressed by IFRA/RIFM, the SCCP etc. etc. The conference could also include natural ingredient manufacturers adversely affected by cosmetics sector legislation, as well as strongly featuring the cosmetic industry & its problems. Interplay with other industries who are also opposed to EU policies in their own fields is also being sought, to see if lessons can be learned.
Posted by Marcia on June 29, 2007 in Organizations, Regulatory Issues | Permalink | Comments (1)
June 08, 2007
Natural Perfumers Guild Marks Anniversary With New Look
The Natural Perfumers Guild
(formerly The Artisan Natural Perfumers Guild established in 2002 by noted natural perfumer and author Mandy Aftel) celebrates a one year anniversary in its newest incarnation wih artisan perfumist Anya McCoy at the helm. A fresh new look and spirit is depicted in the new logo designed by graphic artist and award-winning filmaker Christoph Green.
In the year since McCoy has revived the activity of the Guild, new members include the prestigious Prodarom Grasse Institute of Perfumery and the Grande Dame of American Aromatics Jeanne Rose and noted aromatherapy author Robert Tisserand (a blogger here on aromaconnection). McCoy hosts the 5-year old Yahoo Natural Perfumery Group, an online free educational discussion forum that serves as an adjunct to the Guild. The Guild is a consortion of perfumers, associates and natural aromatic material suppliers from around the world, with established and up and coming natural perfumers in its ranks. The Guild has implemented a mentoring program for entry level natural perfumers and is providing welcome assistance to the growing success of natural perfumery, dovetailing perfectly with the growing green movement worldwide. McCoy has created a sister website which will serve as the sales site for Guild members. Under McCoy's energetic leadership, the Natural Perfumers Guild promises more exciting years to come serving the ever-expanding desire for synthetic-free artisan perfumes and cosmetic products. Congratulations and Happy Birthday!
Posted by Marcia on June 8, 2007 in Organizations, Perfumery | Permalink | Comments (0)
April 24, 2007
Update on CAM Guidelines
Almost before the ink was dry on the previous two posts, I received an update e-mail from the Natural Solutions Foundation. Apparently over 100,000 people have used the link here to send a message to the FDA, but the link is either overloaded or has been sabotaged. If you try to use the link and it doesn't work, you might try this alternative address here.
A request was made to the FDA to clarify the comment period, but the FDA has promptly responded refusing to do so. Thus you need to get your response in by April 30. UPDATE: Deadline has been exteded to May 29! See AAHF site for more details.
The update also includes information about the American Association for Health Freedom, and a link on their front page includes a lot more information and talking points about this issue that you may be able to use in your comments. Some of the points they make include:
The AAHF (American Association for Health Freedom) is concerned that "
1. [there be] A public hearing by the FDA before the finalization of the guidance.
2. Changing the title of the guidance to use the phrase "Complementary and Alternative Modalities" and not the prejudicial "Complementary and Alternative Medicine" as in the draft.
3. FDA recognize that "therapies that may benefit" are not the same as "treatment of disease" and do not have to be regulated as "medicine."
The page also includes a link to The Integrator Blog which I strongly suggest that you read before commenting. This article, entitled "The FDA's Guidance on CAM: What is the Appropriate Response?" puts the whole issue in perspective, suggests that perhaps the Internet has over-reacted to what the FDA claims is simply a clarification of the existing state of things, and warns of the danger of "crying wolf".
Both the AAHF and the editor of the Integrator Blog seem to feel that Congressional action may be more appropriate and necessary in the long run.
After reading all this stuff, my tendency is to comment and request an extension of the commenting date until at least July 1 so that more detailed comments can be prepared. And ultimately to follow on and work with the Health Freedom groups to get the federal and state laws changed to make things clearer and more acceptable of health freedom, and in particular aromatherapy.
Posted by Rob on April 24, 2007 in Organizations, Politics, Regulatory Issues | Permalink | Comments (0) | TrackBack
February 23, 2007
Opposition to IFRA 40th Amendment Heats Up
Tony Burfield has an excellent and well-formed front page column on Basenotes expanding upon the IFRA situation. He portrays a disdainful emerging "plantation mentality" when it comes to the lack of respect for individual perfumers themselves in the ever-expanding megacorp environment of the mainstream perfume industry and the aloof disconnect between those at the top and everyone beneath. Such human rights recidivism may not quite move us back to the era of French colonialism in the early 1900's that brought us the insensitive representation of Africans in Vigne's Golli-Wogg perfume bottle (click on thumbnail) designed by Michel de Brunhoff in 1920, whose inspiration came from the books "The Adventures of Two Dutch Dolls
and a Golliwogg" and "The Golliwog in the African Jungle", by Florence Upton based upon her experiences with a rag doll that she played with as a child in New York. Racism in perfumery at that time was also depicted in a glass Mandarin figurine bottle designed by C.K.Benda for Bryenne's Chu Chin Chow released in 1918, which presents a jaundiced Westernized view of a different culture, complete with a 'decapitated' version when the lid is removed. In the 21st Century, most of us would find this blatant racism distasteful to the extreme. So, now, in modern time, has classism replaced racism? Or are they both alive and well and we're so saturated with consumerism that most of us have lost touch with reality? The battles between human rights organizations and corporate conglomerates and intrusive governments are ubiquitous today; one can hardly fathom the rapidly changing and ever-expansive restrictive environments that drown out the voices of the people, especially because of the loss of an independent media.
The IFRA 40th Amendment controversy may seem to not carry the weight of more overwhelming issues such as AIDS and world hunger, hurricanes and floods, but it is another ka-ching in favor of big business stealing all the marbles and denying access to the game by the artisan perfumer and indie natural cosmetic products maker.
Justice Douglas once said, "Power only concedes power when demanded." With globalization, the corporate power seems more ominous than ever. So what, the population has grown also; there are more of us, too. People, that is. Real folks who need to stop behaving like the automatons these corporations would like us to be. In the weeks to come, we at Aromaconnection will put forth energy to gather action and momentum to support Cropwatch's huge (but no doubt sometimes lonely) efforts to speak truth to power for all of us.
Posted by Blogmistress on February 23, 2007 in Organizations, Perfumery, Regulatory Issues | Permalink | Comments (0) | TrackBack





