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.

In 1990 I was caught in a fire and was exposed to toxic smoke and fumes. Because of this exposure to toxic chemicals I have been sensitized to a number of chemicals. Additional exposure to chemicals over the next 2 years led to long term if not lifetime disability.  This sensitivity to chemicals limits my ability to do a number of things. Because I may loose my ability to walk (I fall) and other central nervous system problems, I can no longer teach my Sunday School Class, visit in friends homes, I have to shop quickly and get out of the store etc. The reason is the Chemicals that I may be exposed to.

Now  I find out that Perfumes are not what I thought they were. No longer is the aroma of many popular perfumes taken from nature. Instead it is no more than a concoction of chemicals.

In our workplace we have a certain amount of protection with MSDS Sheets. With perfumes we need the same protection.

Our children or grand children may play grownup and try moms perfume. Children are especially susceptible to toxic chemicals and poisons. Even an infant  breast feeding or bottle feeding may be exposed to Mothers perfume (toxic chemicals). We must have protection  --  at least the protection that states:

"Keep out of Reach of our Children."

 "Warning—The safety of this product has not been determined."

In America I expect no less.

Thank you.
Earle Phillips