The "REAL" facts the industry does not
want you to know
(A rebuttal to the fragrance industry's publicity campaign)
Halifax, Nova Scotia has been at the forefront of efforts to educate and increase awareness of health issues related to exposures to fragranced products. Realizing this was not an issue that was going to go away and indeed may spread to other areas, the fragrance industry launched a publicity campaign to discount health concerns that have been raised.
The fragrance industry has found itself in a rather difficult position. It must appear sympathetic toward those claiming fragrances have negative consequences, while discounting the validity of what they are saying. On June 20, 2000 the industry came to Halifax to launch their publicity campaign. The Scented Product Education and Information Association of Canada (SPEIAC) sponsored an "education" forum in which representatives from Health Canada, the scientific community, Halifax policy makers, and individuals representing the anti-scent movement were invited. The press was not invited to this forum; instead a press conference was scheduled for later that morning.
The forum consisted of a presentation by the fragrance industry representatives: Carl Carter of the Scented Product Education and Information Association of Canada (SPEIAC) and William R. Troy, Ph.D., Chair, Scientific Advisory Committee of the Fragrance Materials Association. Charles Low of the Canadian Cosmetic, Toiletry and Fragrance Association moderated the meeting. The industry contends that there is no scientific basis for fragrance bans, either voluntary or mandatory. After the presentation there was an opportunity for questions to be asked, but no opportunity for advocates of scent reduction policies to present the considerable scientific data that are available.
Since no opportunity was given during the forum to formally present this scientific data to the industry, a point by point examination of the materials presented and questions raised by the industry's press release and ad follows. The public has a right to more than "sound bits" and publicity campaigns on which to base their opinions and health decisions.
Response to SPEIAC Press Release and Ad Campaign
Assertion 1:
"The anti-scent policies - both formal and informal - that are prevalent in the
Halifax area appear to be based on an appalling lack of factual information,"
said Carl Carter, Communications Director of SPEIAC. "It's time to get the facts
straight and put an end to the sensational claims that are being made by
advocates of scent bans."
Reply:
Fragrances are respiratory irritants, which can trigger asthma, allergies and
other respiratory problems. Migraines and other neurological effects can also be
triggered by exposures to scented products. For those who suffer these effects,
even small amounts can trigger symptoms. Fragrances are volatile compounds that
greatly add to air pollution. In addition, there are environmental concerns with
synthetic musk compounds being found in waterways and aquatic wildlife
worldwide. All of these facts are well documented in peer- reviewed scientific
journals.
Assertion 2:
"We respect the fact that some individuals appear to react excessively to many
common everyday substances, including scented products," continued Carter. "At
the same time, we also know that scented products are as safe as the foods we
eat, and the many other products we use in everyday life."
Reply:
Unfortunately the comparison to foods and other products we use in daily life
may be all too accurate. Very frequently the news media reports incidents of
food poisonings and other aspects of concern related to food safety.
Incidentally, the "flavors" in foods are very often the same chemicals that are
the "fragrance" in scented products. There are valid concerns over the safety of
these materials in foods as well as in fragrance.
Assertion 3:
"Responsible public policy-making should be based on accurate information and
the best available accepted science," said Carter. "That is why SPEIAC is making
an effort to correct the misinformation that is being circulated."
Reply:
The best available science states that those with asthma, vasomotor rhinitis,
and migraines need to avoid exposures to triggers. Since there are no tests to
determine which fragrance chemicals trigger these disorders, and because
present labeling does not allow one to determine which chemicals are
problematic, avoidance of all fragranced products is the only way to
prevent triggers. Since symptoms are often triggered by fragrance chemicals in
the air, limiting or eliminating personal use of scented products is not
sufficient to prevent problems.
Assertion 4:
A presentation by Bill Troy, Chair of the Scientific Advisory Committee of the
Fragrance Materials Association (FMA) explained the steps taken to ensure the
safety of fragrance materials and the type of testing that is done. "Fragrance
industry associations around the world work closely with the Research Institute
for Fragrance Materials, an international, independent organization devoted to
evaluating the safety of fragrance ingredients," said Troy. "This is a
responsible industry that takes safety seriously."
Reply:
The Research Institute for Fragrance Materials (RIFM) has evaluated the safety
of less than half of the over 3000 raw fragrance materials in use. Individual
raw materials are evaluated, not the mixtures that are in actual use. Chemicals
in combinations often act very differently than singular materials, as they
involve synergistic, additive, and modifying effects.
Testing by the RIFM focuses on acute and oral toxicity as well skin effects. Testing is not routinely done for respiratory, neurological, and/or systemic effects.
William "Bill" Troy, Ph.D. is a reputable scientist. He was working at Avon in 1975 when, during routine animal patch skin testing, it was discovered that something in the product was turning the skin of the animals blue. Further testing revealed that the chemical Acetylethyltetramethyltetralin (AETT) caused serious neurological conditions and discoloration of the skin and organs of animals and also penetrated the skin of humans. If there had not been a change in skin color, it may not have been discovered that this material was neurotoxic.
Avon was the only company that used AETT whose testing discovered it posed a serious health risk. This material was widely used in fragrances and also used in lesser amounts in flavors. This demonstrates that present testing is not adequately protecting the public.
AETT had been in common use for over 20 years when this discovery was made in 1975. Neither the company originally producing the material, nor any other companies using it had discovered it was severely neurotoxic. The industry "voluntarily" withdrew the material from use in 1977, with one company continuing to use it until 1978. There was no recall of products on the shelf or public notification.
Usually the RIFM does not evaluate raw materials for safety until the patent expires. This means materials can be in common use for close to 20 years before being evaluated outside of the company producing them. Most of the testing done within a company is never made public. Once a material has been in use that long, it is often assumed to be safe, and other companies may mistakenly assume it has been adequately tested. Indeed the RIFM often uses the manufacture's data in the evaluation process.
This also means that many of the newer synthetics that have been developed in the past few decades have not been independently evaluated. This is of special concern, because many of these materials are used at much higher levels than traditional materials.
Much has been learned over the past few decades. It is now known that many materials once considered safe are not. More is known about toxicity and dangers than was known even a decade ago. Much more aggressive evaluation is necessary, not only of singular chemicals, but also combinations that are in common use. Neurological, respiratory, and systemic testing are needed. To contend that "there is no proof our products are not safe" is hardly the attitude expected from AN industry that is able to regulate itself. If the industry wants to continue to self-regulate and avoid increasing regulation it must leave no doubt that the products are safe for the user, those inadvertently exposed, and the environment.
Assertion 5:
Fragrances are primarily composed of water and grain alcohol - of the same type
and purity we drink in beverages - together with essential fragrance oils. This
basic composition has remained unchanged for hundreds of years.
Reply:
The amount of "fragrance" varies by product. Typically perfumes are considered
the most concentrated form of a scented product and contain 10-30% fragrance,
with the remainder being ethyl alcohol. Some fragranced products contain as
little as 0.5% fragrance. In spite of the relatively low concentration of
fragrance in products, fragrance is the number-one cause of allergic reactions
to laundry products and cosmetics.
Only the basic composition, such as the percentage of alcohol to the percentage of fragrance, has remained mostly unchanged. The "fragrance" portion of the product; however, is considerably different than it was even 30 years ago. In general, newer formulations are primarily made of synthetic fragrance oils, not essential oils from plants. History of use does not apply when newer materials are used and when the applications for these materials are different.
Assertion 6:
"People need to know that the ingredients in scented products are tested for
safety and that fragrance formulations do not contain the dangerous substances
that some people are claiming," continued Carter.
Reply:
Some ingredients have not been adequately tested, and others have not been
tested at all. Information from Material Safety Data Sheets and reputable
scientific data raises concerns about the safety of materials used in
fragrances. If this information is inaccurate, then it is up to the industry to
provide peer-reviewed evaluation of the materials. Until this happens, the
available scientific data must be used.
Assertion 7:
"They also need to know that just because a material is synthetic doesn't mean
it is harmful. The safety of a substance is not determined by whether it is of
synthetic or natural origin. In fact, synthetic materials are often purer and
help us preserve natural resources.
Reply:
It is true that a natural material is not necessarily safer than a synthetic
material. However, natural materials do have a longer history of use,
therefore more is known about them. The fragrance industry often tries to apply
this history-of-use argument to modern fragrance formulations. But
history of use does not apply when either materials or use is different. Even
natural materials that were safely used for centuries became problematic when
used in different applications.
Assertion 8:
Perfumes and scented personal care products are regulated by Health
Canada.
Reply:
Products are not required to
be tested before marketing. Ingredients in the fragrance portion of the product
do not have to be revealed to any regulatory agency. There is minimal regulation
and even that is rarely enforced. Canadian law requires a warning of known
health hazards. Fragrances are known to be skin sensitizers and respiratory
irritants. Products do not carry a warning of these well established health
hazards.
Assertion 9:
"These are just a couple of examples of the erroneous beliefs that are the basis
of informal, but widespread, public policies in the region," said Carter. "But
public policy should be based on accurate information – not beliefs. This is
vital to the protection of individual rights and freedoms."
Reply:
Obviously there are vastly different positions on the safety of fragranced
products. The best way to resolve these differences is with a cooperative
effort. Those having adverse reactions to fragrances can provide valuable
information to the industry that will help pinpoint problematic or unsafe
materials so they can be eliminated from use. Education can increase awareness
and consideration of those who suffer adverse effects from fragrances. The
problems will not go away; they will only increase. It is up to the industry
whether battle lines are drawn or problems are resolved.
Assertion 10:
SPEIAC continues to advocate responsible use of scented products and advises
that everyone has a personal scent circle about arm’s length from the body. The
Association recommends exercising restraint when using scented products so that
it is not noticeable outside your scent circle.
Reply:
It is impossible to keep scent within a "personal scent circle". To suggest this
is possible ignores basic scientific principles. There are many factors that are
involved in diffusion of a material in the air. It is impossible to control
these factors in actual use conditions. Fragrances are volatile organic
compounds and get into the air. Once in the air, containing them in a scent
circle is impossible. No one takes a "circle of air" with them and some of each
fragranced product used is left behind in the air wherever the individual goes.
It must be further considered that because of the widespread use of many fragranced products both in personal and environmental applications there is always a background of "fragrance" in the air. Considering only singular products does not adequately address the problems. Air fresheners, scented cleaners, laundry products, and toiletries as well as products such as perfumes that are used primarily for scent must be taken into account.
Many fragranced products are deliberately formulated to be high impact. This means they diffuse into the air quickly and can be detected even before encountering the individual wearing them and long after that individual has left.
It is ironic that the industry is advocating a solution that it should know will never work.