The Elephant in the Room: That ‘Not So Sexy’ CSC Report…

Copyright © Tony Burfield June 2010

Preamble

For some time Cropwatch has been maintaining that the cosmetic (fragrance) industry, the detergent & cleaning industry & the aroma ingredients (essential oil) industry suffer disproportionate and wildly over-precautionary levels of regulation in the EU, compared with other industrial sectors, such as agri-business, pharmaceuticals or food & beverages. Wherever Cropwatch has lectured, everybody has strongly agreed with the word ‘disproportionate’. And, as we have previously argued, we can point to tens of thousands of premature deaths amongst health patients from adverse drug reactions arising from prescribed drugs, but it is hard to find more than a handful of clinically referred cases of, say, acute contact dermatitis amongst the hundreds of millions of fragrance users, let alone a single instance of a death. Safety has become some high altar on which career toxicologists & regulatory officials (read: lawyers) are free to dispatch the products of hapless aroma ingredient producers to the graveyard, often on the flimsiest of toxicological evidence, to the detriment of the industry’s standards and levels of attainable perfumery excellence. Yet, apparently, none of these considerations with respect to perfumery as a damaged heritable art-form, seem to count for very much amongst the fragrance industry’s bean-counters, living in fear of media exposure and therefore loss of profit arising from the use of a perfumed commodity which contains some allegedly hazardous material.

Just as the EU Commission’s lawyers were persuaded in the 1990’s that an allergy epidemic was occurring in Europe, and Danish dermatologists and others were pointing their fingers at fragrance chemicals as a contributory factor, so we were catapulted into the inappropriate and unnecessary regulation of allergens in cosmetics in 2003 (the ‘26 Allergens Fiasco’ – see Cropwatch website). The story now given (e.g by Vey 2010) is that the incidence of allergy is presently estimated as some 9 times lower since then – difficult for me personally to swallow, but on the other hand I could believe that the clinical assessment of suspected allergy has since improved nine-fold – especially as Cropwatch has seen confidential documents from 1998 describing the shortcomings of commercial Fragrance Mix Allergy Kits used by professional dermatologists & clinicians (including the fact that the oakmoss ingredient used for allergy testing was unforgivably not genuine oakmoss!). As you will undoubtedly have gathered, restriction to the unfettered use of perfume ingredients (especially to essential oils) caused by the ill-advised EU Directive 2003/15/EC, which severely limited the concentration of alleged allergens in cosmetic products, is damage we are still trying to undo. In any fair society, something would be done, in the light of evidence that many of the alleged allergens listed are so weak or inactive that they do not produce significant levels of adverse reactions, even in patients with dermatological problems (see Schuch 2007). But it seems impossible that the ‘expert’ advisers concerned (the SCCNFP) can bring themselves to admit that they have collectively made some serious mistakes.

The ‘Not So Sexy’ CSC Report

But now history looks as if it might repeat itself, this time in the US, in yet another wave of chemophobic paranoia over fragrance chemicals. Of course, the fact that many of us might not be in absolute tip-top condition has nothing to do with bad diet, over-eating/excessive bodyweight, excessive consumption of alcohol and/or cigarettes, lack of exercise, recreational drug-taking, breathing in diesel-polluted air or anything remotely similar. Oh no. According to some, it is because, apparently, we are all being poisoned by our fragranced cosmetics. The reality is, of course, that we live in a period where cosmetics are over-safe - as soon as arsenic compounds were removed from face-powder, and musk ambrette from joss-sticks, the chances of rigor mortis setting in some after a squirt of whatever perfume some Z-list celebrity is currently promoting became pretty negligible. If you really want to know what might keep me awake at night, it is certainly not what micro-quantities of polycyclic musks might be accumulating in my body tissues from use of my personal deodorant, or how much methyl eugenol I consumed in my pesto-laden mozzarella sandwiches that day, but how many hot particles I might have stumbled into on my local beach, because the UK nuclear industry has previously seemed to be unable to keep the all of its americium & plutonium within the plant’s secondary containment!

Anyway back to the main story. As I said in my address to the World Perfumery Congress (WPC) 2010 in Cannes – see http://www.cropwatch.org/Tony Burfield at Cannes 2010.ppt - the US cosmetics industry's self-regulatory approach and lack of ingredient safety substantiation has not been without its critics, such as the increasingly influential environmental organisational groups of the Environmental Working Group (EWG), Skin Deep & The Campaign for Safe Cosmetics (CSC). The CSC’s commissioned report “Not So Sexy - The Health Risks of Secret Chemicals in Fragrance” (CSC 2010) produced by Commonweal, Environmental Working Group, Breast Cancer Fund, Women’s Voices for the Earth & Anne Steinemann (University of Washington) amongst others, certainly caused a lot of comment amongst delegates at the WPC 2010. Delegates seemed mainly concerned that the sensationalist presentation style of the report, the unsubstantiated innuendo, the biased and unrepresentational selection of toxicological evidence, coupled with the evidential lack of rationalised scientific overview, may lead many less well-informed people to link fragrance chemicals with adverse health effects – an undeserved conclusion considering the lack of direct evidence presented in the report. What Cropwatch found particularly surprising was the idea that the public would fall for the supposedly “secret ingredients” claim – i.e. the non-listing of fragrance ingredients which are not required to be shown on the product labelling under existing legislation, agreed in order to protect the intellectual property rights of the fragrance producer. We are not saying this is non-consequential, but, for example, it has been shown that for those substances currently requiring mandatory labelling in Europe (such as the chemical names of allergens on the labels of UK supermarket cleaning products), there has been almost zero levels of comprehension and near-zero levels of interest from prospective customers.

Some of the fragrance ingredients identified in the CSC report are anti-oxidants or UV-stabilisers, deliberately added to the product to prevent the (unlikely) generation of sensitisers from ingredients such as limonene and linalol - a fact which weakens the CSC argument surrounding sensitisers. The relative stability of linalol and its incorrect classification as a sensitiser, for example, is well-known (Hostynek & Maibach 2008), but the CSC failed to reveal this fact in their report. Yet other ‘secret’ substances identified (alpha-pinenes, myrcene, limonene, gamma-terpinene, para-cymene, terpineol (no isomer stated) and alpha-cedrene) are all components of forest air and of natural essential oils. Millions of tons of monoterpenes, including alpha-pinene and limonene, are passed into the atmosphere per annum from biological materials (Schenk 1979, WHO 1998) for example from green leaves & therefore the needles of pine, fir, spruce & cedar trees, to an extent that both latter substances have been identified in human breast milk – but their presence has raised no public outcry (as opposed to the presence of musks). Maubert (2007) notes that the Landes Forest in SW France produces more terpenes per month than Europe’s entire consumption of essential oils in a year. So shouldn’t the CSC rather be identifying trees and forests as their imagined toxicological threat?

Other materials identified in the report (phenylethyl alcohol, benzyl acetate, benzyl salicylate, benzyl benzoate, linalyl acetate, hexyl acetate) occur in essential oils, absolutes & resinoids, and in the natural emissions of plants and flowers, although it is apparent from the text that the authors may not collectively realise this fact in all cases. It would be exceedingly unfortunate if this pressure group succeeded in bringing in restrictive legislation against these ingredients. Since legislators treat natural and synthetic forms of ingredients equally, any such restrictive legislation would have implications for the lifestyles of many of CSC’s supporters who may like to regularly use natural materials in their daily lives (essential oils, natural perfumes, aromatherapy products, natural cosmetics, natural soaps etc.). Greenpeace made much the same mistake some years ago in arguing for the REACH legislation to be brought into effect in Europe. Thanks to their support for the legislation, and their failure to help lobby for the exclusion of natural aromatic substances, we now face the disappearance of many familiar aromatic materials, unless the aroma industry can cough-up the truly extortionate toxicological testing fees required for each ingredient.

More surprising is the lack of IT knowledge collectively shown by the CSC report’s authors (i.e. how to go about accessing comprehensive toxicological data from the internet or from scientific libraries – the authors seem to have mainly relied on PubMed!), and the low level of analytical competence shown in the analysis of the chosen fragrances, which operates well below industry standard. Employing a couple of teenagers and giving them access to the internet for a few `weeks should solve the first problem, and paying a $100 dollars or so a time to a small perfume company for GC-Mass Spec analyses of the fragrances that they are interested in, should solve the second. At least they should then get detailed & dependable analyses of the fragrances, which clearly they haven’t achieved so far (in Cropwatch’s opinion) looking at the paucity of detail in the presented results.

In the “what you can do” summary section of a review of the CSC report on the CSC website at http://safecosmetics.org/article.php?id=644 you are be urged to lobby to “pass laws that shift the entire industry to non-toxic ingredients and safer production.” Since most/practically all natural products now carry some sort of (so-called) hazard labelling or risk phrasing, this effectively means shifting to the world of “safe” synthetics. Since the EU Cosmetics Commission is also dedicated to the establishment of a synthetic world which is safer than nature (Burfield 2010), so perhaps they would both like to lock themselves permanently away in it? Just leave the real world to us non-paranoid inhabitants please, so we can enjoy it in all its alarming chemical dangers – alcoholic drinks, herbs & spices, pesto, trees, flowers and, err, … fragrance!

The CSC report has been rebuffed in part by the Fragrance Manufacturing Association (FMA 2010) and IFRA. What is really needed, Cropwatch feels, is a line by line dissection of the whole 46-page report, refuting or challenging every erroneous or unproven statement made - otherwise the defence of fragrance chemicals is not adequately proven.

In Conclusion

Yes, of course it is right that consumer groups ask serious questions of the somewhat secretive fragrance industry. And its right that the FMA and the multi-million dollar IFRA organisation should respond with a highly detailed reply to all their points (N.B. a detailed reply is presently lacking). Its just a pity that the CSC have blundered in with such an accusatory and unscholarly document which may yet mess it up for all of us (for reasons stated above) – since - in spite of its scientific inaccuracy and unsubstantiated innuendo, the report will undoubtedly add more pressure to further regulate an already over-regulated industry.

References

Burfield T, (2010) – see Slide 14 at http://www.cropwatch.org/Tony Burfield at Cannes 2010.ppt

CSC (2010) – see http://safecosmetics.org/article.php?id=644

FMA (2010) “U.S. Fragrance Association Finds New Cosmetics Report Misleading – Fragrance Safety Is No Secret” May 13th 2010 http://fmafragrance.org/sub_pages/CSC_release2.pdf

Hostynek J.J, & Maibach H. (2008) “Allergic Contact Dermatitis to Linalool” Perfumer & Flavourist 33(5), 52-56.

Maubert C. “The Naturals Paradox” World Perfumery Congress 2007 Booklet presented by Perfumer & Flavourist 2007,

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.

Vey M. (2010) - remarks made during the address to the Safety Symposium, British Society of Perfumers, Cambridge Belfrey Hotel, Mar 2010.

WHO (1998) Concise International Chemical Assessment Document No 5. Limonene. International Programme on Chemical Safety.

 

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