the aromaconnection blog

Notes and News

Those involved in natural cosmetics and the manufacture of aromatherapy products  in the United States are not always aware of what’s percolating in regulatory circles across the pond.  There is a searchable database, COSING, established by the EU, which is extremely helpful to quickly find pertinent information.  These regs may or may not appear in our own rules here at home as the FDA continues to masticate on the globalization act of 2008.   Of the greatest interest, rules regarding the 26 fragrance allergens now required to be labeled on cosmetic packaging if in products above 10 ppm in leave-on products, or 100-ppm in wash-off products.  Perhaps 50% of these allergens are found naturally in limonene, citronellal and linalool . . . all which occur in essential oils.  In this directive, fragrance allergens are considered regardless if they come from essential oils or synthetic manufacture. 

We owe great thanks to Tony Burfield for his diligence over the past two years to provide information here on aromaconnection about EU directives, IFRA and other regulatory issues.

The volunteers at aromaconnection have all been very busy with other aspects of their lives for a bit of time, however, we hope to be back stronger than ever by the fall.      

The Senate affects Aromatics Stimulus

I took a look at the list of items cut from the Stimulus package by the Senate compromise team. Several items that will be cut may affect aromatics in the US. These include:

• $100 million cut from Farm Service Agency Modernization
• $50 million cut from Cooperative State Resources, Education, or Extension
• $65 million for watershed rehabilitation

What wasn’t indicated on the cut list whether there would be any funds remaining in these categories. What is clear that these cuts could potentially affect farming and farm services that might support aromatic crops. On the other hand, the proportion which might have trickled down to help aromatic crop farmers is probably small.

Final passage of the stimulus package in the Senate probably won’t come until Tuesday. There will then have to be a Conference Committee with the House to reconcile the differences between the House and Senate bills. It’s possible that some of these items might be put back in.

If you have any feelings one way or the other on this bill, you should contact your Senators or Congressperson.

NPA moves ahead with its "Natural" Product Seal

The Natural Products Association (NPA) has announced that applications for its "Natural Standard" certification are available. The certification process will be based on the NPA Standard published on May 1 [PDF] and discussed here previously (which is not quite ready for prime time, in this reviewer's opinion). Certification will cost $500 per product for members of the NPA, and $1,250 for non-members. The standard requires that labeled products must be made with at least 95% all natural ingredients.

Since the NPA's membership fees for suppliers are not posted on their website, it's difficult to determine what impact this will have on small suppliers who would like to use the seal.  Since the public seems to be more aware of the "Organic" designation, and there are two competing seal programs (OASIS and NSF/ANSI) out there, it may turn out that there isn't even a place for a natural products standard and certification program.  There have been other attempts to define "natural" products, notably the Natural Ingredients Resource Center (NIRC) and the Campaign for Safe Cosmetics (CFSC). The problem with all of these is that they tend to define "Natural" (a positive) by stating what isn't natural (a negative definition).

The NPA definition of "Natural" from their May 1 version of the standard is:

Ingredients that come or are made from a renewable resource found in nature (Flora, Fauna, Mineral), with absolutely no petroleum compounds.

The NPA goes on in their draft standard to specifically list allowed and prohibited ingredients (although the natural ingredients are on an attached list that doesn't seem to be attached) and then has an "Illustrative List of Allowed Ecological Processes".

This contrasts with the NIRC definition (partially quoted):

Natural Ingredients include  plant, animal, mineral or microbial ingredients...

• present in or produced by nature.

• produced using minimal physical processing.*

• directly extracted using simple methods, simple chemical reactions or resulting from naturally occurring biological processes.*

Neither of these definitions really have much "meat" compared to the definitions included in the "real" standards that have been proposed (OASIS & ANSI/NSF Organic Standards), both of which have over 60 definitions of terms that need to be precise so people know what the standard really means.

The "Natural" standard process has not been transparent and subject to the scrutiny that it needs to be subjected to. Moving ahead with it before it has been vetted by the industry and consumers is definitely not in the best interest of either. There has been some discussion of these issues in closed mailing lists, but that does little to force the NCA to open up the process and produce a real standard that has some meaning and can work effectively.

For more information, an article in the June Perfumer&Flavorist discusses "The Case for Natural Personal Care Standards." (Sorry, they make you pay for it.) Although the article contains some misinformation, it is a generally good overview of the state of standards issues as it stood before the Natural Beauty Summit.

Technorati Tags: natural products,definition of natural,NCA,NIRC,natural standards

Natural Beauty Summit tackles certification fragmentation

Cosmetics Design-Europe reported on the natural Beauty Summit held last month in New York with the headline Natural Beauty Summit tackles certification fragmentation.  We reported in this blog on the Summit before it happened, and although we were unable to attend, have been gathering information that goes beyond the sketchy report in CD-E, and we'll be reporting more in depth about the various standards and the process of their development in the near future.

Apparently the discussion got rather heated as the panel made presentations focusing on six different approaches to standardization for certification of natural and organic personal care products in North America: the USDA NOP, a Retailer's standard proposed by Whole Foods markets, Organic standards proposed by NSF and OASIS. CD-E referred to the NSF standard as being for consumer goods, but it appears to us to be equivalent to the OASIS standard and they seem to be two wheels on the same unicycle.

However, when it came to the panel discussion, Horst Rechelbacher, founder of Weleda and Intelligent Nutrients, and chair for the conference's first session on Sustainability, chose to challenge the panel on the fact that they were contributing to the fragmentation of the certification process and consumer confusion.

The panel discussion became heated, with Rechelbacher accusing the panel representatives of being self-serving and panel members defending themselves by explaining that the development of the market in the US had made private certification necessary.

Rechelbacher apologized for his comments, but stressed that he wanted to see greater regulatory harmonization.

The Natural Products standard proposed by the NPA apparently wasn't included in the discussion. As we pointed out in our discussion of that standard (see link) the orderly Standards development process mandated by ANSI isn't being followed by most of the standards developers. The one exception is the standard being proposed by NSF, which is going through the ANSI standards development process and has gone through it's first round of review, although the public has apparently not been brought in on the process yet. And neither have the independent small producers.

Coming soon: a comparison of the NSF and OASIS organic standards.

Technorati Tags: OASIS Standard,Body Care Standard,Organic Standards,Natural Product Standards

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.     

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!

Technorati Tags: organic standards,natural standards,cosmetic standards,NSF,OASIS Standard,ECOCERT Standard,BDIH Standard

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

http://www.wikipedia.org/

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

Technorati Tags: Cropwatch,natural aromatic products,perfumery,natural perfumery

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.  

The Sky Fell In

Part of the sky fell in over the weekend. The UK's Times newspaper ran a 2-page story (see Times OnLine ) describing how the new Natural Healthcare Council modelled along the lines of the General Medical Council, (GMC) will regulate aromatherapy, reflexology, massage, nutrition, shiaztzu, reiki, naturopathy, yoga, homeopathy, cranial osteopathy & the Alexander & Bowen techniques in the UK. Nigel Hawles, the health editor for the Times, described the move as a success for the Prince of Wales. I believe, on the other hand, that it will be an unmitigated disaster for CAM.

What is the real motivation behind this? Its all about money & control. The pharmaceutical trade has for a long time looked with envy at the £130 million per year turnover generated by Complementary Alternative Medicine (CAM), which is expected to rise to £200 million within four years (Hawkes 2007) and its storm troopers have sought to kick complementary alternative medicine in the head, via adverse media coverage, at every possible opportunity. The threat posed is that the rise of complementary therapies and the popular use of natural products such as tea tree oil, ginseng, valerian etc., diverts attention from convention medicine & the potential income from conventional synthetic drug sales. Therefore any negative utterance by some academic 'expert' (who those of us within CAM have generally never heard of) knocking aromatherapy, herbal medicine, homeopathy etc. is faithfully reported by various lightweight science reporters who work for the supposedly independent quality UK newspapers such as the Guardian, the Independent or the Observer. Cropwatch has been puzzled as to why our rebuttals of the shallow, non-investigative & biased reporting has never been featured in the letters pages of these organs. We don't have to look far for an answer. Its down to sinister lobbying organisations and their many sympathisers, such as Sense About Science (hilariously described as ‘a charity’ by obedient newspaper hacks) who are thought to be indirectly financed by the pharmaceutical & chemical organisations & trades, and who exert their considerable influence in distorting media science reporting, defending GM products and. promoting an anti-environmentalist stance - for example dismissing industrial pollution effects in terms of false illness beliefs, arguing against organic food & vitamin supplements, alternative medicine and so on.. For the real low-down on Sense About Science (SAS), see the LobbyWatch website at http://www.lobbywatch.org/profile1.asp?PrId=151, or Martin Walker's free downloadable E-book: Cultural Dwarfs & Junk Journalism. One of SAS's more chilling beliefs is that public discussion of scientific matters & their ethics should be discouraged and legitimate arguments trivialised or dismissed as fantasy, since the SAS view is the only valid one. The Corporate Science supporter Ben Goldacre, who runs a 'Bad Science' column in the Guardian which exercises a vendetta against various CAM professions such as homeopathy & nutrition, is under the Guardian's editorship protection, such that counterattacks to some of his nonsensical ramblings never see the light of day. Goldacre, who professes to be a mere hospital medic, whilst being quick to criticise CAM, refuses to comment on his own profession's lamentable failings (such as the abysmal statistics surrounding the failure of MD's to correctly diagnose & prescribe the appropriate treatment for a given patient's ills, the hundreds of thousands of patients who die or who's health is severely adversely affected by the unwanted side-effects of prescribed pharmaceuticals, or the hilarious but thorough reporting of an extensive study by the Union of Concerned Scientists that following a course of conventional drug treatment appears to statistically increase the chances of shortening your life, not to mention the serious chances of dying or losing limbs from hospital acquired infections!).

So why is Cropwatch opposed to the Natural Healthcare Council regulating CAM? The Nigel Hawkes article suggests regulation is needed partly because of high-profile cases where therapists have reportedly attacked clients. This argument is clearly absolute nonsense – the National Health Service has always represented much more of a risk. For example here in the UK, an inquiry started in 2000 decided that the medical practitioner Dr Harold Shipman allegedly killed up to 250 of his patients, some 218 of whom have been subsequently identified. Health care authorities subsequently carried out heavy modifications to medical practice to increase patient protection, but this move was merely 'shutting the stable door after the horse has bolted'.

As it is, regulation has all but destroyed the perfumery trade, & Cropwatch spends most of its spare time fighting the absurdities of the EU regulation outfall, and UK/Canadian/US National legislation that concerns natural aromatic & medicinal products. Within the EU in the cosmetics/essential oils sector, a bunch of Brussels lawyers with no scientific knowledge are advised by so-called 'expert' committees (themselves a bunch of academics with no trade experience) who rely on big industry to provide scientific evidence on ingredient safety & other regulatory matters. Of course big industry biases furnished safety evidence to 'expert' committees towards to their Corporate interests, and they employ and finance toxicologists to support their hyperbureaucratic policies, which are themselves so complex, that they profoundly disadvantage all of the less powerful competition with less available technical manpower resources. A similar state of affairs exists in Biocides regulation, where EU Directives are completely written around the interests of the chemical industry, making it virtually impossible cost-wise for small natural biocides with their small financial resources producers to sell their relatively safer products in Europe. It is a running open sore.

If the Natural Healthcare Council were to fully regulate all the CAM areas mentioned in the first paragraph, it would require a complete college-full of multi-disciplinary experts to administer the eleven or so areas mentioned. It will be very interesting to see who they put up to do this - we are promised eight of these regulators, who we learn elsewhere will be probably lay people under the chairmanship of Dame Joan Higgins.. What it probably would mean, is that those who passionate about CAM are going to have to spend much of their time, unpaid & unrewarded, teaching the regulators (and no doubt their “expert” advisers) how to do their job properly. If previous patterns are repeated, the regulators will make inappropriate decisions based on biased evidence proffered by those with hidden agendas, which the rest of us will have to spend years undoing. Although Cropwatch has made some unacknowledged headway in doing exactly this in other areas (cosmetics, biocides), it is extremely dispiriting the think that there is potentially much more to take on here as well.

First indications are that joining the proposed scheme will be voluntary, eventually to be obligatory. The Council will (initially) only have powers to strike off errant or incompetent therapists, or to set minimum standards for practitioners. This latter prospect is, in itself, most intriguing. Within aromatherapy, the low educational entry requirements & abysmal course standards set in UK colleges are a national joke, so setting minimum standards for practitioners will presumably be a great source of material for satirical magazines such as Private Eye. The profession is starved of finance, so no substantial evidence-based aromatherapy data-base exists as such - anything that does exist is likely to consist of published (so-called) aromatherapy studies by non-practising academics, rather than tapping the massive collective experience of everyday practitioners. Aromatherapy trade & academic magazines are owned by aromatherapists, their chums, & aromatherapy supply sellers - who profit from promoting their own businesses within the magazines.

But of course it is perfectly possible to be a fantastic massage therapist, aromatherapist etc., without having the dubious benefit of attending some badly-taught aromatherapy course and getting the duly signed piece of paper at the finish, and/or having to be obligatorily registered with and represented by some professional aromatherapy organisation or another. Perhaps this consideration should be the first lesson for the potential regulators of the National Healthcare Trust. Or perhaps, as in France, where aromatherapy has been legally designated as a 'sect' (in spite of the fact that now according to some with national pride, aromatherapy was invented in France), it may have to go underground for a while to survive. In any case the freer CAM is from regulation the better. Sure, these professions have an element of scientific content, but basically they are a folk-art, sympathetic to concepts of spirituality & energy flow, and they need to be severely left alone, and they are doing just fine from receiving no attention whatsoever, thanks, from a UK government obsessed with control. Finally, if you have any doubts about how a GMC-styled regulatory body might eventually end up in regulating the CAM profession, have a look at Martin Walkers's account (again in Cultural Dwarfs & Junk Journalism) on how the GMC and some of the major players have dealt with Dr Andrew Wakefield. Wakefield, you will remember dared to raise issues about the safety of the MMR vaccine and possible links with autism, and who is currently involved in GMC a fitness to practice hearing.

Tony Burfield.

P.S. Please pray with us that Prof. Edvard Ernst is not promoted to a position of adviser or authority within the National Healthcare Council. Ernst is a Corporate Science sympathiser who is working undercover as Director of Complementary Medicine at Exeter University, & whose sole purpose seems to be to rip the soul out of CAM, armed only with a Corporate Science device called "the meta-analysis". Ernst's stature & reputation is such that it has even over-awed normally sensible Herbalgram staff who worship & reproduce his every utterance, & who apparently haven't noticed that now HE'S WORKING FOR THE OPPOSITION. Wake up!

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