Dockets Management Branch
The Food and Drug Administration
Department of Health and Human Services, Rm. 1-23
12420 Parklawn Dr.
Rockville, MD 20857

Re: 99P-1340/CP 1
Petition to Have “Eternity eau de parfum”  Misbranded

Dear Sir or Madam:

In May, 1999, the Environmental Health Network (EHN) submitted the
above petition to have Calvin Klein’s “Eternity eau de parfum”
declared misbranded. I am writing because I fully support this petition
and request that the FDA give it careful attention with regard to your
regulations 21CFR Sec. 740.1, 21CFR Sec. 740.2, and 21CFR Sec. 740.10.
Regulation 21CFR Sec. 740.10 specifically states:

“Each ingredient used in a cosmetic product and each finished cosmetic
product shall be adequately substantiated for safety prior to
marketing. Any such ingredient or product whose safety is not
adequately substantiated prior to marketing is misbranded unless it
contains the following conspicuous statement on the principal display
panel: "Warning--The safety of this product has not been determined."

As the petition shows, “Eternity” contains toxic ingredients and
ingredients whose safety have not been substantiated. There is no
warning label on its packaging.

We all have a right to know the status of safety testing of the
ingredients in products such as “Eternity” so that we can protect
ourselves and our families from toxic chemicals that may cause health
problems. Most people are not aware that most fragrance materials have
only limited safety testing. They wrongfully assume these products
are safe to use in any setting and are surprised when people complain.

Like tobacco smoke, the harmful chemicals currently used in these
products may affect the health of many people, including: people with
asthma, chemical sensitivities, chronic fatigue, and other environmental
illnesses. Children are particularly vulnerable to toxic chemicals
found in products purchased and used by their parents, care givers and
teachers.

When I am exposed to fragranced products, such as “Eternity,” I
suffer from severe asthma attacks, amongst other things. I have to be
very careful and limit the number of public places that I enter due
not only to perfume use by other patrons, but the ever-increasing
number of scented products, such as candles, found in nearly every
shopping mall. These scented products are especially difficult to
deal with when entering a pharmacy to fill a prescription for asthma
medication. Access to restrooms is becoming increasingly difficult to
tolerate because of perfumes and air deodorizers used.

This actually impacts my life more than the lives of some physically
handicapped people whom I know who are in wheelchairs. Almost all
buildings today have wonderful accessibility for the handicapped. I
applaud the fact that accessibility for the physically handicapped
was seen as important enough to be acted upon. What I need is
unadulterated air, which is increasingly difficult to find given the
overuse of fragrances.

Please act on behalf of the millions of people who have suffered
physical illness and injury resulting from fragrance exposure at work,
at school and in social settings. These toxic chemicals act as powerful
barriers to people disabled by asthma and chemical sensitivities.
Because of this, toxic chemicals in fragrances have already ruined
countless lives.

Sincerely,

Rae L. Chappell