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January 30, 2008


(posted with permission of cropwatch)

Editorial Comment

On 25th Jan 2007, Kim Bleimann President of Berjé Inc., made a block-buster of a speech about the state of the aroma trade entitled “What you’ll never hear from
your boss.” His audience was the Women in Flavour & Fragrances Commerce (WFFC) meeting in New Jersey, and although the talk is by now 12 months old, its message is still 100% relevant. We reproduce the speech here (with permission) in its entirety, with a strong recommendation that everyone reads it, especially the newcomers to this industry. It is rare to find in a speech where there is so much contained wisdom, abject disappointment at the way the aroma industry is being destroyed without really putting up a fight, the overall message being tempered with some wry humour.

A second lecture we are pleased to bring to a wider audience is that from Robert Tisserand, who bounced back on stage after a 10-year absence from public speaking at the Alliance of International Aromatherapists Conference in Denver, Colorado in October 2007. Robert’s paper entitled “Challenges of Essential Oil Therapy: Proof of Safety” raises some important issues in the safety area. Our particular interest would be to develop some of the themes mentioned in the lecture i.e. more attention given to matrix effects in essential oils & how the beneficial effects of individual substances contained within natural aromatic materials, which have anti-carcinogenic, anti-irritant, anti-inflammatory, antioxidative properties etc., might easily nullify the adverse effects of other substances within the same oil/ ingredient which are individually alleged to be irritant, carcinogenic etc. In this way we would hope to be eventually able to show that the existing system of single ingredient hazard-based precautionary-principled prediction attempts to estimate the actual risks presented to the end user for complex biological substances, perfume compounds or finished
cosmetics, is invalid.

The subject of coumarin has made even more twists & turns in recent weeks. Cropwatch has updated & re-issued its Coumarin – the real story document to include the National Toxic Encephalopathy Foundation (NTEF) vs. l’Oreal’s knock-about over alleged adverse effects from the coumarin-containing Angel perfume by Thierry Mugler, and punches holes in the somewhat chemophobic arguments presented by the NTEF. We separately examine the questionable Dec 2007 statement by the Federal Institute for Risk Assessment (BfR) regarding dangerous levels of coumarin exposure from applied fragranced cosmetics, especially for children. We conclude that the BfR may be another organisation apparently incapable of doing a proper literature search on ingredients – had they done so, they may not have made the statement that they did. As it is, they have been slapped down by both the IKW and IFRA. Whilst it is rewarding to see an IFRA spokesperson actually defending an aromatic ingredient for once (instead of regulating us ingredient users into obscurity), we bring you aspects of the coumarin toxicity saga that IFRA forgot to mention.

On the allergen front, a further paper from Vocanson et al. (2007) re-addresses the lack of allergenicity of pure coumarin, identifies a dihydrocoumarin impurity as the possible culprit for any slight allergenicity in impure coumarin. The SCCP are on the rack on this one - you remember that in their last Opinion they seemed to ‘misunderstand’ the results from the last paper from Vocanson & chums (Vocanson et al. 2006). Hopefully they will understand this one, and pave the way for a re-examination of all their previous contentious decisions on fragrance allergens, before they are embarrassed even further by the results of even more investigative publications.

The lack of inertia from the SCCP regarding overdue investigations of its previous shoddy work, is revisited with the tea tree oil (TTO) situation Almost four years on from the SCCP’s questionable Opinion on TTO, the negativity of which caused so much damage to confidence in the tea tree plantation business in Australia, and ten months on from the ATTIA dutifully lodging their document to fill the TTO toxicology data gaps that the SCCP identified, we still haven’t arrived at a revised SCCP Opinion on TTO’s stability & safety in cosmetics. A recent Cropwatch Statement (Jan 2008) optimistically & mistakenly identified a Brussels working group meeting on 22nd Jan 2008 (for which TTO was on the agenda) with a final SCCP meeting on the subject – we apologise for this. Apparently the SCCP is overloaded with work, and ATTIA’s TTO submission is a “big document” (nobody we know has seen it, or been able to throw it from the top of the stairs to see how heavy it is, so we can’t possibly comment on its bigness).

So it seems that we now have an SCCP ‘expert’ committee that isn’t actually expert; lacks necessary cross-disciplinary skills (admitted to Cropwatch in 2007 by Brussels regulatory staff); has previously offered Opinions when it was unable to conduct a proper literature search (admitted to Cropwatch 2007 by Brussels regulatory staff); makes flawed decisions which are being challenged in the scientific literature, and now apparently can’t get through the workload. We understand that following a contact with a Unit C7 – Risk Assessment official, a date later this year (perhaps June 2008?) to review a draft of the position is possible. The need for a separate Fragrance Commission within Brussels populated by independent fragrance experts - for which we believe there is a body of potential support in the Brussels Parliament - was never more apparent. In this way an admission of the relative safety of TTO might advantage the beleaguered TTO industry, which has suffered from Brussels wrong-footedness & dithering.

To conclude, existing EU regulatory staff continue to fail to present sensible policies for the survival of European aroma industry as they continue, unimpeded, to tunnel-vision their way from regulatory meeting to regulatory meeting, to further their repressive ingredient policy agendas. Unwittingly, perhaps, they are helping to kick the fragrance industry in the head as it lays bleeding to death, and we desperately need a new initiative from professional, trade & research organisations & industry itself, if natural aromatic products are not to become completely relegated to obscurity. The clock is ticking….


Vocanson M., Valeyrie M., Rozières A., Hennino A., Floc'h F., Gard A. & Nicolas J.F. (2007) "Lack of evidence for allergenic properties of coumarin in a fragrance allergy mouse model." Contact Dermatitis 57(6), 361-364.

Vocanson M., Goujon C, Chabeau G, Castelaine M, Valeyriea M., Floc'h F., Maliverney C., Gard A. & Nicolas J.F. (2006) “The Skin Allergenic Properties of Chemicals May Depend on Contaminants - Evidence from Studies on Coumarin.” International Archives of Allergy and Immunology 140, 231-238

Posted by Tony Burfield on January 30, 2008 in Essential Oils/Plant Extractions, Regulatory Issues, Safety/Toxicity | Permalink


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