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

Speaking to the “enemy”, are we?

Well, yes and no.

First of all, IFRA’s been getting a thorough thrashing lately in the perfume blogosphere, so it’s only fair that their Director of Communications, Stephen Weller, should be allowed to respond. This is why I wrote to him three weeks ago. He responded immediately and has kindly authorized me to publish his answer. Apart from his comment on Now Smell This, this is a first.

Secondly, it is worth asking whether IFRA is the real boogeyman here. Stephen Weller’s answer indicates that the pressure for “safer” products is both internal to the industry (self-regulatory mechanisms preceded legislation) and due to external, political pressures.

The show I was invited to along with Octavian Coifan and Bertrand Duchaufour on the French public radio on May 11^th confirmed that there are indeed major concerns in the general public about the safety of fragrances: several calls and emails touched on the matter. So did many questions directed to Christophe Laudamiel during his Boston conference the same day (as reported by Jarvis, a frequent commenter on this blog, who attended it).

Emotion-fuelled and misdirected by bad science as those concerns may be (NGO campaigns and sensationalist press articles clearly feed the paranoia directed towards synthetic materials), they do have an impact that public bodies cannot ignore; they have certainly played a role in the increasingly strict regulatory environment.

In this context, IFRA clearly has a more pro-active role to play, to disprove bad science and reassure both the public and public policy-makers. It’s a steep uphill trek: the perfume industry itself has never done much to inform the public, and outright lies (“our products are 100% natural!”) have helped fuel the mistrust of synthetic materials.

An information campaign is called for, but whether it’ll do any good to perfume, perfume-lovers and perfumers is quite another matter: more materials are coming up for restrictions, and pretty soon, I wonder what perfumers will have left to work with, and which perfumes will survive at all...

STEPHEN WELLER’S ANSWER TO GRAIN DE MUSC

As Mr. Weller’s letter is quite long, I’ll be dividing it into two separate posts for your reading comfort. My own letter restates several points I made in the one that was published on Perfumer & Flavorist’s website and in my previous posts (click here and here), so I won’t reproduce it here.

Mr. Weller has quoted my questions in his letter (they are underlined; I have emphasized certain phrases in bold; the phrases in italics are mine and refer to my letter).

Dear Denyse,

Many thanks for your email, and you are correct, this is the first time IFRA has entered into a dialogue with the blogosphere. The reason is that IFRA has traditionally focused on the IFRA Code of Practice, IFRA Standards and the industry’s Compliance Program and therefore the main audiences have been the international regulatory authorities, IFRA’s customers, the finished product manufacturers and the fragrance industry itself. In 2008 the industry collectively decided to put equal emphasis on communication and advocacy, pro-actively taking our messages to policy makers and the wider public.

I will try to answer your questions in their order and then add some comments.

Why has the fragrance industry not considered a more explicit and complete allergy warning label? After all, a rash isn’t anaphylactic shock, and food manufacturers label for peanuts which can be deadly for a portion of the population.

There are 26 fragrance materials defined by the EU Cosmetics Directive to be allergens. In Europe, these materials must be labeled on any product containing them at a concentration greater than 0.01% for rinse off and 0.001 for leave on products in order to enable people allergic to these materials to avoid the product. This should serve as adequate warning for the consumer and in most cases does. Where the problem lies is that the list of 26 allergens was drafted by the EU's Scientific Committee for Consumer Safety (originally known as the SCCNFP, then the SCCP and now known as the SCCS – click here for details online) over ten years ago. Almost half the materials on the list of 26 are not deemed to be potential allergens by dermatologists. Unfortunately regulations can take years to change and they do not always keep up with the science.

IFRA and RIFM (Research Institute for Fragrance Materials) have a great deal of expertise and data. When we detect a material has an issue via feedback from a network of dermatologists, or our own research or from manufacturers of products, we carry out a risk assessment. This is evaluated by an entirely independent panel of experts, REXPAN. These people have no connection to the fragrance industry and look purely at the science. They then make a recommendation to IFRA and RIFM for either more data, to draft a Standard or to take no action. If a Standard is required what form it takes very much depends on both the potency of the fragrance material to induce sensitization and the olfactory potency. If a threshold can be determined, below which the material in a statistically significant amount of cases does not induce sensitization and the perfumer concludes that this level is still of olfactory significance, then a limiting Standard is set. If the potency for allergic reactions is very high and would only allow insignificant or useless levels, then the material will be banned. Raw materials are also banned if there is insufficient data that allow a safety assessment (this ban can be lifted, if the missing data are established).

Through this system many materials have been saved because a use restriction has been issued, meaning that the scent can remain. If the amount used in the given product exceeds the restriction outlined in the Standard, then there is a high possibility of the material eliciting contact dermatitis. Since this approach has been active the levels of contact dermatitis have been falling with regard to fragrance materials. It is true that allergic reactions have been rising in general but not to fragrance materials (ref: Schnuch et al Contact Dermatitis, 50: 65-76 (2004)).

The reality is that most manufacturers of finished products follow the EU regulations worldwide and voluntarily label the 26 allergens if any are present in the product above the threshold. So, the labeling is there. Although the skin compatibility of cosmetics, toiletries and fragrances to the vast majority of the population is thoroughly tested, it is unavoidable that a small proportion of consumers may show a skin reaction when using products containing a natural or synthetic ingredient to which they are allergic. There is no substance that can be said to be a non-sensitizer in all circumstances and to all people. At the other end of the scale there are materials to which a significant proportion of people will respond even at very low levels of exposure. Within these extremes there are materials that will only affect a very small proportion of the population, provided exposure is kept below a level peculiar to the specific substance. These are known as weak sensitizers and the fragrance industry uses a number of them as important ingredients.

A lot of the materials we are exposed to in our every day life could be regarded as weak sensitizers. Their benefit is generally much higher than the risk of adverse reaction. In fragrances, they are used due to their unique smell, which cannot be achieved by using other materials with a better risk/benefit ratio.

Allergy to fragrance ingredients does exist and the industry is dedicated to reducing its incidence to the lowest level possible. The current labeling practices may help to reduce an already low incidence by providing greater information to consumers that experience sensitivity.

(To be continued)

Image: Eugenol. This molecule, which gives cloves their scent, is an essential material of perfumery. Its use is now strictly regulated.