I was wanting to wait a little bit longer before tackling this subject but recent events have forced me to comment a little sooner than I expected. Last Thursday February 13, 2014 the European Union (EU) has announced a three-month period of consultation on fragrance allergens. The regulations under review are recommendations by the Scientific Committee on Consumer Safety (SCCS) to ban three substances from being used in perfume; two of the molecules found in oak moss and tree moss, and a lily-of-the-valley chemical called Lyral. There are an additional 12 molecules and 8 naturals which would be severely restricted in concentration and require labelling on the perfume it was contained in. The reasoning behind the SCCS’ recommendation is these are allergens and removing them from fragrance is in the interest of public health. As a scientist who works on the pharmaceutical side of things I’ve watched this debate and have been amazed at many aspects of it.
A Skin Irritation test with 2 controls and and 4 concentrations of the test molecule
The data used to determine the allergen potential of these molecules is scientifically and statistically unsound. Many of the studies used to determine these molecules as skin irritants lacked the necessary statistical and scientific structure to come to the conclusions they have reached. The studies conducted on the three banned molecules that have been published were done with small groups of patients with no control. When I am developing a topical drug formulation I would have to have multiple groups of 30 patients treated with the drug in varying concentrations in one place on each patient as well as what we call a control patch of skin on the same patient. You usually use a negative control you expect to cause no effect, like water, and a positive control that you do expect to cause an irritation. These are used to calibrate the skin of the patient being tested. If the patient shows a reaction to the negative control, which remember is just water, any other result would have to be thrown out because the patient has responded to only water. This is called a placebo effect and it occurs in 15-20% of patients. For a molecule to have a statistically relevant response it would have to have a response rate 20% greater than the placebo effect. The studies these bans and restrictions have been based on were performed one time at one concentration on 25 patients with no controls, positive or negative! This is what makes me shake my head as this is not good scientific practice and the conclusions made are very preliminary and possibly incorrect.
An even bigger flaw is the idea that it’s really only 23 molecules, so what? If these single molecules are restricted and banned it will have a ripple effect throughout many more raw materials. A natural oil is not a single molecule it is a combination of as many as hundreds of individual molecules. Any one of which could be identified as one of the “bad 23” which would then make that natural oil unusable as well. In Denyse Beaulieu’s blog Grain de Musc, The Different Company CEO and Creative Director Luc Gabriel expands on this thought as he worries at the impact of these changes on the industry.
All of this is complicated by the fact that there is no unified response. According to some sources LVMH and Chanel are extremely concerned. Other brands like Coty and L’Oreal seemingly stand on the sidelines. The Fragrance Foundation has stayed away from this debate with a ten-foot pole. Some of the raw material houses like Robertet have tried to get their lavender fields and products protected under French heritage law.
Until last Thursday this mix of concern and apathy was the norm now a 90-day clock has been turned on. Let me offer a solution to propose to the EU. Let LVMH, Chanel, and any other company that wants to participate, fund a full-blown study of these 23 substances under the highest scientific and statistical standards. Multiple controls, multiple concentrations, multiple patient groups spanning different ethnicities. In other words prove that these molecules are as “bad” as they are reported to be. This is a study that could easily be performed in 12-18 months to add a level of scientific rigor sadly lacking in the process so far.
The time to offer solutions is now and the time for discussion has been forced upon us by the EU. Together the industry and those of us who love perfume need to stand up and be heard or we will pay a price I think none of us wants to pay.
–Mark Behnke
Best post in the entire perfume blogosphere since 2008. I'm spreading this around. Any testing that the industry does in response to the recommendations needs to be done in the context of scientific opinions like this. Alas, so much of science is now politicized – I think you may have just fired the first wire-guided missile at the tank of EU regulation – something which was not supposed to meet any organized opposition.
I was recommending that oakmoss replacements be found with a drug industry focus. I think you've hit on a very analogous and even more critical idea – the deletion of oakmoss, treemoss, lyral and the "dirty dozen" should not occur without drug industry testing.
Red,
I hope its an RPG and not a spitball. 🙂
You and I have discussed this many times in the past and I think now that there is a ticking clock perhaps there will be more consolidation of response. I know I’ve had this discussion one-on-one with people at all levels within the industry and they all agree something needed to be done. Maybe the EU has done us a favor of sorts. If apathy rules the next 90 days then the perfume houses will reap a bitter crop. I am more hopeful that now that a time bomb has been set there will be a concerted effort to defuse it.
Mark
Dear Mr. Behnke,
Thank you for your kind words on my post, as well as for the link. I found your discussion of the single, solitary (!!) study to be fascinating, but not conducive to good blood pressure. I think my head may have exploded a little. A mere 25 people? With no controls??! If I knew of a way to reblog your post on WordPress so that my readers could see it and come here, I would. As it is, I will try to update my own post to reflect your information at the first available opportunity.
On a completely tangential note, I wanted to say "Congratulations" on starting your own site after such a successful tenure at CFB. Is there some sort of email following/subscription type thing for Colognoisseur that I could use? In any event, all the best for you and Colognoisseur.
Kafkaesque,
I understand the elevated blood pressure when it comes to this. I really have been disappointed in the lack of a unified response by the industry which I think is the most current danger to my cardiac health on this topic at the moment. As a scientist in my day job this kind of interpretation of poorly designed experimental data happens all too often it isn’t just the SCCS.
Thanks for the encouragement on my new endeavor. I’m still figuring it out but I’m happy to have a place to be able to expand my voice excatly for instances like this. I will be adding a Bloglovin’ link which allows for e-mail digests of new posts so hopefully that will work for you. I hope to have that up by the weekend. Thanks again.
Mark
Dear friends, you may be reassured to some extend, I shall always be ready to supply you illegally with some good perfumes containing as much natural allergens as you may wish.
AbdesSalaam Attar
AbdesSalaam Attar,
It is good to know there will be a black market in proscribed perfume ingredients if the regulators win the day. 🙂 Let’s hope you and every perfumer can make the choice that is right for their aesthettic impression without considering imperfect regulations.
Mark
I actually laughed at loud at this. Repeatedly. Like a crazy person. May God bless you, my dear Abdes Salaam, for a variety of reasons.
I shall now go back to laughing at the promise of illegality and allergens. 😉
I grew weary of blogging on this subject in 2008, and, so, in 2010, I launched the Outlaw Perfume project. Several of the Guild's perfumers took part, and it was a sensation. We flagrantly used any banned or limited aromatic we chose, and the world didn't come to an end, and nary one rash was reported by our customers. Many don't realize, but there are ongoing threats in the pipeline, and some "bills" in the US that have been voted down before they became law, but they keep popping up.
It's a complex issue that dates back to the Scandanavian dermatologists, bad scientists, and greedy bureaucrats and corporations. The perfumers in the corporations are the ones who are suffering the most. We artisan perfumers are able to fly under the regulatory radar, at least here in the USA, at least until one of those bloody bills makes it into law. I will be fighting this until the end. This madness has to stop. Just a label, for crying out loud, just a label. It's worked for the cosmetics industry for decades.
In the meantime, back to my exotic flower garden in the tropics, back to tincturing fabulous flowers into ingredients for my Outlaw perfumes.
LOL, meant to say 'bad science', although I do suspect some scientists with agenda paid for by the corporations that want to control every molecule did take part. 😉
Anya, You were one of the first voices I remember reading on this issue. It is sad that it takes being put under the 90-day gun asit were to finally get something like a unified response. Although it is still not as good a response as i would like.
I just scored vintage bottles of PRPH (including original vintage and slightly later vintage), Equipage, Aramis, Ralph Lauren Chaps, Drakkar Noir, Yardley, Aigner No 1, No 2, and Super Fragrance, and Eternity. I have just recently really gotten into collecting colognes but don't love these scents (a bit too dated for my tastes), but I'm wondering if I should rethink selling them. What if my pallate changes down the road and I end up wishing I had kept these scents when I had the chance?
AA, I don’t know if you need to start hoarding. If you read around many seem to think the eventual resolution will be some kind of labeling. It is a risky move to count on that because if the decision comes down very different then things will be worse. I would wait and see what the eventaul resolution is at the end of May and then make any decision on which fragrances you have that are affected.
Hi Mark, I wonder why EU has no the same commitment toward shellfishes, nuts, sulphamidic, glutine, orange juice, trees (why not distroy all the trees covered by moss?) all of them surely causing allergic reactions. The point is that 98% of human being have no problems with them. So what?
Incidentally: why they have not already banned cigarettes? Any doubt about their dangerous effect on human health?
Silvio
Silvio,
You are absolutely coreect in thinking that all allergens are not created equal. Perfume is an easy target as it is not considered a necessity. These allergens you listed have all been dealt wiith by using simple labeling warning about their inclusion and possible allergic effects.I am hoping that the labeling soultion is the one chosen for the short term. For the long term the work being done at IDEA will once and for all scientifically prove which of these allergens are really allergenic at concentrations typically used in fragrance. I think thiings are looking up, I hope.
Mark