May 7, 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: Petition to Have Fragrance Misbranded

Dear Sir or Madam:

The Environmental Health Network (EHN) petitions to have Eternity eau
de parfum declared misbranded. EHN has selected Eternity for this petition,
because it is one of the brands we hear about the most, one that has caused
drastic health problems for many, many people. Eternity is also
representative of the type of fragrance formulation that is frequently cited
as causing problems. The enclosed lab analyses, material safety data sheets,
and other information clearly establish the potential dangers of many of the
ingredients contained in this product. Eternity is manufactured by Calvin
Klein Cosmetics Company, Trump Tower, 725 Fifth Avenue, New York, New York,
10022-2519, USA. 

Due to the "trade secret" status of fragrances, little information is
available to the consumer as to what is in the product. The consumer is
totally dependent on the integrity of the company producing the product and
trusts the Food and Drug Administration (FDA) to enforce existing laws. But
the ingredients in fragrances are not listed on the labels and there are no
warnings. When there are no warnings on the label, the consumer naturally
assumes the product has been adequately safety tested via all routes of
exposure and is safe for use. Most consumers are not aware that the fragrance
industry does not routinely test for neurological, respiratory, or long term
effects of the materials and that most fragrance materials have only limited
safety testing.

As our petition will show, this particular product contains toxic
ingredients and there is no warning label.  The FDA’s enforcement of the
required warning label on the product is essential in order for consumers to
make informed choices about its safety. We feel consumers have a right to
know the status of safety testing of the ingredients in products such as
Eternity so that they might protect themselves from toxic chemicals that may
cause or exacerbate acute or chronic health problems.

There are published studies that have previously identified some of
the volatile organic compounds (VOCs) commonly used in fragrances and
fragrance products. Widespread use of these products contributes
substantially to indoor air pollution at work, home, schools, health care
facilities, and recreational settings. Like tobacco smoke, the harmful
chemicals currently used in these products may effect the health of many
people, including:

• people with asthma and reactive airways disease, who may suffer
potentially fatal attacks when exposed to these products;
• people with chemical sensitivities, chronic fatigue, and other
environmental illnesses;
• children, who are exposed to and harmed by the toxic chemicals
found in products purchased and used by their parents, care
givers and teachers.

In addition, the hazardous ingredients contained in these types of
products give them the potential to be used as “inhalant” drugs by children
and teenagers. This is a growing drug abuse problem, and has even proved
fatal. Children have already died from “huffing” air fresheners, perfumes and
common household cleaners. These are products we are led to believe are safe
because they are sold without warning labels.

EHN was founded over ten years ago to serve people who have been
chemically injured. We receive many health complaints from people who have
been exposed to chemicals used in perfumes and other fragrant consumer
products. People suffer particularly in the workplace when exposed to
fragrances and fragrance products, because their complaints are often
dismissed as frivolous (because there is a widespread misperception that
fragrances are safe). Because of this, many people (including those with
asthma) suffer permanent damage to their health due to fragrance products
used on the job. People have become disabled by exposure to these chemicals
and have lost their jobs.

In some cases, fragrance products have even been used by disgruntled
co-workers and students to deliberately attack and harass those who complain
about ill effects from exposure to fragrance chemicals. The case of Judith
Sanderson, a high school biology teacher with reactive airway disease, is an
example. She originally became ill from a formaldehyde spill in her lab,
which sensitized her to other chemicals as well. Her condition deteriorated
after numerous fragrance attacks from students who objected to her ban on
fragrance use in her classroom. Finally, after three years, she won her right
to protection and accommodation at the school through binding arbitration
handled by her teacher’s union (1997). At her school (in Culver City, CA),
student fragrance attacks are now considered assaults.

We hope that your consideration of our petition will result in
warning and ingredient labels for Eternity fragrance products.
Thank you.

Sincerely,


Amy Marsh
President

enc.
       

    ____________________________________________________________________      ENVIRONMENTAL HEALTH NETWORK    P.O. Box 1155 .
                                                                                                        Larkspur, CA 94977                                                                                                            (415)541-5075

The information contained on this site has been compiled by

Betty Bridges,RN

mailto:bcb56@ix.netcom.com

E-Fax:: (801)340-3578

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