Susan M. Cooper

June 6, 1999

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 effect the health of many people, including: people with
asthma, reactive airways disease, chemical sensitivities, chronic
fatigue, and other environmental illnesses.  Children are particularly
vulnerable to toxic chemicals found in products purchased and used by
their parents, caregivers and teachers.

When I am exposed to certain fragrance products, such as "Eternity," I
experience sudden, painfully sharp headaches, loss of concentration,
unusual tiredness and lethargy, foggy thinking, irritability, tingling
sensation on my scalp, increased nasal and chest mucus, coughing,
burning eyes and nasal passageways, and bronchoconstriction resulting in
decreased peak expiratory flow values (exacerbation of my asthma)
requiring use of my rescue inhaler, which lasts anywhere from several
hours to 3 or 4 days, depending on the product, proximity, and length of
exposure.  I have had to purchase a special air purifier which rids the
air of volatile organic compounds in order to function at work where
people around me wear various perfumes includning "Eternity."  I have
had to stop attending my church because of the abundance of perfumes
there.  All this occurs despite my taking 7 to 9 medications daily to
control my allergies and asthma.

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 and
severely limited the activities of others.

Thank you.

Susan Cooper