vendredi 15 mai 2009

IFRA's Stephen Weller Answers Grain de Musc (Part II)

I know: it's long, it's not particularly sexy reading and I promise I'll get back to more distracting perfume topics next week. Meanwhile,this is the 2nd part of Stephen Weller’s answer to my letter. To read Part I, click here.

Why isn’t the industry involved in a more pro-active public campaign to disprove the bad science which supports the claims of anti-fragrance lobbies?

We are just getting started. Watch this space. It takes a while for an organization and an industry to gear itself up to communicate on a broad scale when it has not had to in the past. In future you will see much more openness and pro-active communication from IFRA in order to clarify the facts and refute false claims made on the basis of poor science.

Aren’t the EU regulations of REACH, which compel all manufacturers and importers of chemicals [to] identify and manage risks linked to the substances they manufacture and market”, the real problem?

I think it is important to clarify the regulatory issue here. It is not REACH. The fragrance industry is quite able to deal with the demands of REACH, albeit at a cost. The real issue lies with the Directorate General for Consumer Protection (DG Sanco) and the Scientific Committee for Consumer Safety (SCCS), which I mentioned earlier. It has a stated policy aim to reduce the risks any product poses to EU consumers, including contact dermatitis. Studies have shown that allergies to fragrances affect less than 2% of the population. However, the European Union is committed to ensuring that citizen’s health and safety are properly protected and any risk, it seems is too high. This is the political reality faced by all manufacturers of all products, not just the fragrance industry. Many of the materials we have to address at IFRA are due to a direct request for data from the SCCS. They tell us that there could be a problem with a material and we then have to provide data to support the continued use of that material. This is how it works in the EU. We at IFRA spend our time defending molecules for perfumers.

Several of the natural materials listed in Amendment 43 (or concerned because they contain listed molecules in high proportions) have been used for centuries without, apparently, decimating entire populations. Couldn’t there have been a communications campaign, directed towards political authorities and the general public, on this point? After all, one of the main causes of allergy is hay fever, and no one is campaigning to pull out trees from cities. Contact dermatitis is easier to avoid than breathing in pollen-laden air…

I can assure you that it does not matter to a regulator if a material has been used for centuries, quite happily, without harming anyone. They will regulate based on the current data on a material and the results of a Risk Assessment. Where the data is wrong or incomplete, we at IFRA along with RIFM endeavor to correct it and usually do. We cannot get away from the fact that some fragrance materials, be they natural or synthetic, elicit contact dermatitis in some people. This has to be addressed in order for fragrance to survive at all in the modern regulatory environment.

Some general comments:

You mention that you are not aware of any anti-fragrance campaigns [in my letter, I was referring to the situation in France, and stating that these campaigns seemed to me to be predominantly Anglo-Saxon and Scandinavian], but I can assure you there are many. I do not wish to give oxygen to their campaigns here but I encounter them daily and we do our best to respond. It is not an Anglo-Saxon issue, it is a global issue. A trend beginning in Canada or Norway will soon be seen in France and Australia. Regulations are global now. So is business and so are NGOs. The current debate with the NGO community is based on the argument that Risk-based decisions are not adequate, that we must now regulate using Hazard-based decisions[1]. This approach would mean that water and oxygen would have to be banned since everything is hazardous depending on it use. It seems absurd and in many cases it is, but the concept has political traction.

I would be happy to enter into a dialogue on these subjects. I realize that there are many, many people interested in this subject and I feel that they should have the facts. As you rightly say the problem is the wish for a 'risk-free' society. This is the political reality we face globally. The fragrance industry is doing its best to navigate this regulatory environment and keep as many materials available as possible for the creation of fragrances. The conspiracy theory you mention simply does not make commercial sense. All fragrance houses use synthetic and natural materials. Some are captive and under patent but most are not. The system of patents ensures continued innovation and R&D for new molecules. Without a patented period there would be very little return on investment and thus no incentive to innovate. This is true for most industries not just fragrance.

I hope this has answered your questions.


Stephen Weller

Director of Communications

International Fragrance Association (IFRA)

[1] What’s the difference between “hazard” and “risk”? According to the Aromatics Online website, “The hazard associated with a chemical is its intrinsic ability to cause an adverse effect. Risk is the chance that such effects will occur. For example, whilst a chemical may have hazardous properties, provided it is handled safely under contained conditions, then any risk to human health or the environment will be extremely low.”

Image: Moskene. When you Google it you get nothing but "contact allergy" articles. It is strictly verböten.

17 commentaires:

  1. 'risk-free' society? According to the World Health Organization about 3, 000 people die in crashes each day worldwide. Before the widespread use of cigarettes, lung cancer was a rare disease, it is now the leading cause of cancer deaths worldwide. Powerlines, cell phones and Wi-Fi all are a high-risk for brain tumors, leukemia, birth defects...Seriously, perfume allergens that affect less than 2% of general population it's such a joke!

  2. Si j'avais, I know it's a joke. It's a shame it's not a very funny one. But fragrance is an easy target: dispensable and futile.
    Mind you, the regulations for REACH bear on all chemicals imported in the EU above a certain tonnage.

  3. Not sexy, perhaps, but very juicy. Lots of things here to think about, especially in this section of the letter, not all of them cause for despair. Must mull quietly before further response...

    Except for this: I can't thank you enough for engaging like this D. Having been involved in lots of activism on other seemingly hopeless fronts I think I feel more optimistic than many folks about the possibilities of a vocal, highly articulate minority to create real change, especially change that depends on social perception. And this is how it starts. Even in our tiny, seemingly dispensable corner of the world.

  4. Perhaps I'm just a wonk at heart, but this stuff is utterly fascinating to me (although I'm starting to feel some sympathy for IFRA, darn it all!). Thank you so much for doing this.

  5. Alyssa, I don't know if it can do much good, but speaking directly to the people involved (Perfumer & Flavorist, IFRA) seems better to me than shrugging hopelessly. And trying to understand.
    Please comment again when you're done mulling!

  6. Natalie, wonks unite!
    I think that S. Weller's move in shifting the onus of the regulatory pressure onto the politicians and the NGOs is quite clever, and certainly not untrue. But there's a lot more to understand about the strategy of IFRA members, which may never come to light... Though I'm out there with my Maglite.

  7. I've just returned from vacation so am late to this party. But thank you so much for engaging Mr. Weller, et. al.

    On first read it appears that there is a certain amount of blaming going on. Sometimes it seems as though the world's gone off its rocker with these attempts to shield the populace from all hazard. Perhaps it started (at least in the US) when, in the early 80's I believe, some miscreant put cyanide in bottles of Tylenol. Now you have to have a penknife to open a bottle of any OTC medication; a reasonable solution, as one can tell if a bottle has been tampered with. (Note that Tylenol itself wasn't banned. I'm wondering if it would have been now, or reformulated, or at least re-named; my guess is that it would have.)

    While I believe that this is a done deal, these no-hazard groups are such a convenient excuse, aren't they? A handful of zealots with "political traction" causing a once-powerful industry to tremble and sweat, and then change all its policies?

    I see a weakness in the "if there is insufficient data to allow a safety asessment" clause. There can always be insufficient data, particularly when there seems to be no particular standard as to sample sizes, how the research is conducted, etc. In my experience, "insufficient data" also means "we need more money." So I would question, once again, the source of that funding.

    It appears that Mr. Weller is at least taking these inquiries from "the blogosphere" somewhat seriously, whatever the outcome. I doubt that investigative journalists will see perfumery as a serious enough issue to merit their attention in these times. A mistake, IMHO, because as frivolous as perfumery seems, this could be made an example of the effects of unreasonable zealotry upon industry, via the fear of litigation. But that appears to be a central tenet of modern life.

  8. Olfacta, thank you, this is exactly the type of comment I'm seeking: looking for the weak points of the argumentation.
    I believe that pressure groups are not the only players here, though, if I've understood Mr. Weller's explanations: there also seems to be pressure from the scientific commitee overseeing consumer products, relayed by EU organisations and elected officials.
    From my experience, living in Europe for over 20 years, the EU metastazises regulations.

  9. Oh, thanks for reminding me--I've promised to post my conversations with Mr. Weller on Les Tuileries but I simply forgot (so sorry if he is reading this comment). I'll do that right now.

    BTW, I'm here to announce that you've won an award! It's the "Your Blog Is Fabulous" award and here are the rules just in case...

    Upon receiving the award a blogger must:

    - Pass the award on to 5 other fabulous blogs in a post
    - List 5 of the blogger's fabulous addictions in the post
    - Copy and paste the rules and the instructions below in the post.

    Instructions: Include the blogger that gave out the award and link it back to that blog. Then one needs to name and to post five additional winners (linking them to the post as well). Don't forget to notify the fellow winners, either by emailing them or leaving a comment on their sites!

    So in case you want to read about my post here it is:

    Anyhow, xoxo! A

  10. Albert, I'm honored, but not in much of a disclosing mood... Will you forgive me if I pass up my turn on this one?

  11. Denyse: Thanks once again for a compelling journalistic piece at the bleeding edge of the controversy. I found Mr. Waller's responses thoughtful and considered, and I have been able to move away from my Chicken Little sky-is-falling hysteria to something a little more balanced (but certainly I remain concerned about the hysterics of the anti-fragrance movement).

    Recently I had the great fun and privilege of being asked by a noted perfumer to sit in on the preliminary formulation of her newest perfume -- a round table of friends and perfumer colleagues she had gathered for their impressions. What was fascinating as I watched her work with her repetoire of aromachemicals and naturals, was the sheer quantity of materials available to her. She did not seem constrained in her pursuit of her concept -- quite the opposite; there were many ways she could achieve a sought-after effect with different combinations of materials; sometimes the subtle changes in shading or nuance were imperceptible to me (but I am hardly an expert). She was aware of the relative safety profiles and took those into consideration, out of what appeared to me to be a combination of sound business practices and a concern for her potential consumer. Her creativity did not appear to be adversely affected. I had expected a lamenting of IFRA restrictions (and the topic came up) but that was not the case.

    Consider as well Jean Claude Ellena, who has been a critic of some of the IFRA rulings, but has also been able to use his considerable skills and talent to achieve extraordinary results with a masterly blend of the minimum number of materials. He has learned how deftly conjure up the impression of fragrance notes, with a limited palette. Some would say that tenacity has suffered, but it's hard to argue with his many beautiful successes.

    Sometimes, wonderfully creative things come out of the crucible of limit-setting. And sometimes incredibly banal things come out of unlimited access to money and materials (see: Las Vegas).

    Thanks again for being proactive in getting answers directly from the source.

  12. Scott, thank *you* for your story...
    I'm convinced that perfumers will be able to continue making beautiful things.

    What concerns me (and many perfumers to whom I've spoken off the record) is that the restrictions won't stop: the list is already getting longer as we speak.

    But the major scandal here is the fact that an overwhelming majority of fragrances will be covertly reformulated without apprising the customers.
    So far, Serge Lutens is the only one who's publicly owned up to it (see my post). I'm convinced he carries out his reformulations with the utmost care and artistic integrity. I can't say the same for every brand.

  13. Denyse:
    Yes! There must be truth in advertising! I completely agree. And I concur that the all-chemicals-are-bad hysteria needs to be either countered or supported by rational, scientific proof and a hefty dose of common sense.
    Thanks again for providing this important forum.

  14. Scott, Mr. Weller promises there'll be some more proactive campaigns... It'll be quite an uphill climb.

  15. Excellent two part post. Thank you for asking the questions and getting the answers. I'm encouraged that the IFRA now understands the importance of engaging the public as well as members of the industry.

    Re: fragrance allergens -- I'm one of the 2% that regularly develops contact dermatitis to perfumery materials. It doesn't stop me from enjoying perfumes, but it does make me more mindful of what I wear and the materials listed.

    While I have no wish to ban materials that others enjoy wearing, I do see the importance of proper labeling and risk/hazard assessment (and yes, I experience contact dermatitis reactions to all-natural perfumery just as often as I do to contemporary synthetic based formulae).

  16. Nathan, thanks for your comment -- of course labelling is very important. I sorted some cosmetics allergies (to particular pigments) that way.
    It's also important, as you say, to mention that both naturals and synthetics can cause allergies -- it's not all "evil synthetics" versus "virtuous naturals" out there...

  17. It is the equivalent of limiting an artist's palette. How would Van Gogh have created all of his wonderful works if he was only allowed to use white and yellow for colours. This is where the parfumeurs world is going to end up. No, citrus, no eugenol, no this no that. It is all truly a sad pathetic joke.