More on NTEF and Angel Perfume

UPDATE: This is a response to a long comment to the previous post.

Brief History

1. Aromaconnection featured an article on the NTEF's attack on Angel Perfume on Nov 12th 2007. I (Tony Burfield) had some previous correspondence with Angel de Fazio, styled as President of the National Toxic Encephalopathy Foundation NTEF in Jan 2007 on behalf of Cropwatch, in which I made enquiries on any available data - and commented on the analysis still available at http://www.national-toxic-encephalopathy-foundation.org/oculartest0001.pdf. I attempted to convey that the analysis of Angel perfume displayed was extremely poor (even this was too diplomatic) and that perhaps Cropwatch could provide a more comprehensive account of the likely components in Angel perfume. I further asked if any the components allegedly responsible for the ocular damage originally reported (actually stated as damage to the cornea) had been identified - at the time Angel de Fazio indicated that this information was not available. Angel de Fazio further indicated that the NTEF was against the perfumery & medical use of essential oils but shared Cropwatch's reservations about IFRA's apparent selective endorsement of synthetics - a position later retracted/clarified by IFRA/RIFM via a withdrawn and subsequently reworded article in Cosmetics-Design Europe - the reworded version survives at here. As an aside it might be of interest also that the private correspondence between IFRA/RIFM  and the journalist who reported the story has been internally circulated by at least one perfumery trade organisation, and that the journalist in question now works for another publication. Cropwatch has no idea whether these two events are linked. In the interests of transparency, by the way, the correspondence between the NTEF & Cropwatch is available on request from Cropwatch, as it was neither confidential nor "off the record".

2. Because Cropwatch is an Independent Watchdog, our brief is not to take sides, but to investigate issues surrounding the safe use of natural ingredients to the best of our ability. With this particular matter, we are possibly spilling over into alleged risks associated with synthetic aroma chemicals (synthetic coumarin etc.). In the real world, however, we have to be realistic: a perfume industry based 100% on natural materials would run out of ingredients very quickly, and further exploit aromatic plants to the point of extinction. It should also be mentioned that I wrote an article in 2004 on Chemophobia (on my old website at http://www.users.globalnet.co.uk/~nodice/new/magazine/chemophobia/chemophobia.htm) where I attempted to show that scare articles on cosmetics & perfumes such as those featured in the otherwise sensible Ecologist magazine, discredit themselves with poor technical content. 

3. The history of this matter can further be added to, by reference to the fact that I mentioned the 'Angel perfume story' to a senior member of DG-Ent. (in passing over a sandwich break) at the UEAPME (European Association of Craft, Small and Medium-sized Enterprises) Cosmetics Forum meeting in Brussels on Nov 9th 2007. I will now forward this note and a summary of events to the EU Cosmetic safety regulator, in the interests of background information on current topics in cosmetic safety. Of principle note is the claim that "As obtained thru' court documents, Clarins hid from the public their own laboratory’s confirmation that this version of the Angel formula was known to cause ocular cell necrosis." (see 4. below). If this is true then we need to know more about it.

4. The situation is further complicated by an allegation of reformulation (see "Is Clarins Angel Perfume by Thierry Muegler more toxic than before" by Angel de Fazio 27th Aug 2007) which you can find at http://pressreleasesonline.biz/pr/Is_Clarins_Angel_Perfume_by_Thierry_Mugler_now_more_toxic_than_before and other places. The feature contains various incorrect assumptions. The first analysis ("deformulation") is extremely poor and compounding these ingredients would produce a unholy mixture bearing no relationship to Angel perfume whatsoever. The second analysis is a merely a listing of so-called allergenic constituents in the perfume as required by IFRA/EU law.- again you could not construct an Angel perfume from this data listing. It appears to me that the allegations of reformulation of Angel perfume arise from a basic misunderstanding the true nature, purpose & usefulness of this data.

It gets worse. The article further treats us to listings of fragrance chemicals supposedly contained in Angel perfume with their alleged health risks, but the author does not seem to understand the difference between hazard and risk, or that toxicity is dose-related.  In this context a clear cut case of health risk from Angel perfume has not been presented, period. Further, many of the substances mentioned above are common ingredients of perfumes and/or essential oils, and are not unique to Angel perfume.

Angel Perfume

Cropwatch is still uncertain why this perfume has been particularly identified for criticism . The NTEF claims that it contains the allegedly dangerous ingredient: coumarin. However there are retailed fragrances still currently available, arguably with higher coumarin contents - for example the original "Joop Home" (Joop 1989) or "Le Male" (Jean Paul Gaultier 1995). Further, if you look at Cropwatch's review article on coumarin and its mistaken identification as an allergen in a previous SCCP Opinion at http://cropwatch.org/nlet4art4.htm you might also get some impression of the importance of coumarin in perfumery over the last century, and those natural perfumery ingredients which contain it. Coumarin was the first synthetic (synthesised by WH Perkin 1868) to be used in a fragrance (Fougere Royale), and since that time coumarin is identifiably fundamental to the fougere accord, together with lavender and bergamot.

You could take the view that Angel by Thierry Mugler (Clarins) has the elements of a chypre fragrance (with respect to the patchouli-evernyl accord), but more importantly is perhaps the first ground-breakingly successful "gourmand" fine fragrance. It is very sweet, having chocolate, red berry, praline, vanilla & cassis aspects. In a comprehensive analysis, you would expect to find veltol, patchouli, evernyl, hedione, frambinone, vanillin, canthoxal, a cassis base and certain lactones.present. Coumarin is of course a lactone.

If there is a convincing case of an identifiable health risk due to a particular fragrance ingredient in Angel, or in any other perfume, then Cropwatch, the perfume industry, & health & safety regulators, generally want to know about it. In defence of the perfume trade, when a problem is identified, moves to ban or withdraw the product take place pretty quickly. e.g. as with the removal of versalide some time ago, and with citralva in the European market just lately (although this material still currently used in the US, or so we believe). 

Coumarin toxicity.

As we mentioned in the coumarin review indicated above, a history of scientific dithering on alleged human carcinogenicity & toxicity of coumarin, says more about questions of the robustness in the methodology employed, than anything else. For example allegations of toxicity, carcinogenicity and allergenicity have been put down to impurities arising from certain manufacturing routes, and may not be present in pure coumarin or in natural materials containing coumarin. Coumarin's regulatory limits in food stuffs in the EU imposed in 1992 (2mg/Kg max in food & beverages, 50mg/Kg in chewing gum, 10mg/Kg in alcoholic drinks & 10mg/Kg in caramel confectionery) compare with a 2mg/Kg limit currently imposed by the FDA.  I suggest to you that these limits are precautionary-principle based limits based on suspicion of human carcinogenic activity rather than its robust demonstration.

We are quite concerned about the specific point of the potential bioavailability of coumarin from topical application of Angel perfume and its subsequent proposed metabolism in the liver. We believe that the typical dose of applied perfume and the rate at which coumarin can cross the dermis is too low to present a hepatotoxic insult and that any amount which is metabolised will safely be biotransformed down the 7-hydroxycoumarin route. However we are currently looking at the literature more intently to clarify whether this view is indeed correct.

Nina Immers Comments on the Angel Perfume subject

Nina Immers' long comment mentions a number of areas where fragrances might pose health risks, including a number of articles from toxicologists, who's work, many of us in the trade are quite familiar with. No overview, analysis or critique of any of the content of any of these articles is presented. With respect, we can't find too much in the comment on that is specifically related to Angel perfume, but there is a statement that coumarin is hepatotoxic in mice because it is metabolised to  coumarin 3,4-epoxide (yes, agree!), and there is evidence that this metabolic route occurs in humans (oh really ??). Traditionally we regard the metabolism of coumarin to proceed in humans fairly exclusively via the relatively less risky 7-hyrdoxycoumarin route and not to involve coumarin 3,4-epoxide at all, so we would be interested to find out more about this specific claim.

Aside from this we can agree with Nina Immers that inhalation toxicity of aromatic materials per se has not been investigated as thoroughly or robustly as their dermatological properties, and Cropwatch has specifically made this point to the EU Cosmetics Commission. We can further agree that the link between asthma & inhalation of aromatic materials needs investigative prioritising, again a point made to the EU Cosmetics Commission, although we don't see any evidence that any expert body that we can readily identify.is capable of properly undertaking such a task. We believe it is the case that these points have been taken on board by the EU regulators. On the other hand, we believe it is a mistake to take an overly simplistic view of fragrance allergy as the cause of modern day ills presented by Nina Immers, now that advances in the understanding of genetic predisposition to allergy and other parameters (such as the contribution of dietary factors) are beginning to emerge. Further the benefit side of aromatics in the risk/benefit health equation is unaddressed by Nina Immers, which makes the presented views quite unbalanced.

Conclusion.

1. We await hard information on any substantiated proof of ocular damage from any ingredient(s) of Angel perfume.

2. As things stand, we may present a counter view to the FDA on coumarin toxicity, but only if the need arises. 

3. The authors of these pieces have done themselves few favours by presenting an unconvincing case which shows up their lack of understanding of toxicological matters as much as anything else. In Cropwatch's views the perfume industry frequently needs criticism, but is unlikely to be very bothered by the technical arguments presented in this particular attack. .

Tony Burfield

for Cropwatch

www.cropwatch.org