05/22/1999

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, 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 fragrance products, such as "Eternity," I
experience (list here):

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. Thank you.
Sincerely Yours,


Lawrence A. Plumlee, M.D., CoPresident
National Coalition for the Chemically Injured