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.

What I find particularly worthy of note is: many of these toxic ingredients
are nearly immediately absorbed into the bloodstream because inhalation is
the route of entry whereby not just exposing the individual who has used the
product, but everyone in close proximity.  This bears a striking resemblance
to the invasive nature of second hand smoke which makes innocent by-standers
targets of exposure by way of inhalation of toxic chemicals.  The impact of
this exposure is extremely far-reaching affecting literally millions of
people.  In the interest of public health and consumer safety it is
imperative to determine the safety of these compounds and risks with regard
to  long term, low level exposures.

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,
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.

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 placed unnecessary restrictions on
many individuals who have become sensitized to these chemicals...at work,
school, Church, social gatherings and even in their own homes.  As a society
& a culture we do not tolerate external obstacles & limitations that place
further hardship & potential risk to the physically  disabled, we have
enacted laws to ensure their freedom of movement in public places.  The same
considerations should be made for those individuals disabled by asthma and
chemical sensitivities concerning exposures to substances that exacerbate
symptoms & suffering.

Your thoughtful consideration is most appreciated.

Thank you.

Regards,
Cathy Flanders
Plano, Texas