Step Away from the Bottle: The debate over IFRA rules.
2012 was a year in which fragrances appeared to fall out of favor with some people (article link), and the subject of natural ingredients and allergens became a a hotly contested topic in fragrance discussions. But amidst all the disputes, one topic drew the strongest views and opinions: The IFRA (International Fragrance Association).
Background: The IFRA refers to itself as the “official representative body of the fragrance industry worldwide”. It’s existed for 40 years as an advocacy organization, but has taken a prominent role in public discourse due to its close alignment to the findings of a single research body: The Research Institute for Fragrance Materials (RIFM), an organization whose purpose is to ensure the safety of perfumery materials. Seemingly, whatever RIFM recommends, IFRA enforces universally. This doesn’t immediately seem like a bad situation until you dig further into the details.
The RIFM’s remit extends through all perfumery products, which broadly includes anything that involves the addition of a raw material that adds scent to any consumer product. This ranges from laundry detergent to baby shampoo to home air fresheners. This seems like a noble cause in keeping us safe — and to a degree it is — until you dig further once again into the list of members of the RIFM who are jointly members of IFRA. It’s a list that includes organizations such as International Flavors and Fragrance (IFF), Firmenich, Givaudan, Symrise, BASF, in addition to a number of personal care products manufacturers. But prominently displayed are the major fragrance chemical manufacturers or those whose livelihood depends on the manufacture of synthetics-as-alternative to natural elements.
The party line is the guarantee of safety of a fragrance component. Anyone who’s had a reaction to laundry detergent understands this concern. But if a detergent causes a skin rash, we usually toss it, call it a loss, and go with something either “fragrance free” or “hypoallergenic” for the care of our clothes. With perfumes, our decision is based more on personal choices; whether we enjoy how it smells on our skin — key words — and if it fits a scent profile we like. This trend or tradition dates back hundreds of years to when the only options for perfumery were those that naturally occurred as an element. Sandalwood, oak moss, bergamot oils were all elements that gave a perfume its distinctive aroma, strength and overall character.
But as RIFM — and by extension, IFRA — sees it, oak moss can be an allergen and potentially cause a skin rash on a percentage of wearers. Anywhere from 1 to 3% of the population has a reaction to oak moss resulting in skin irritation when concentration exceeds a certain level. To compensate, the IFRA has adopted standards and practices and uses its assumed power within the European Community to ‘enforce’. Remember that IFRA is a representative body, not a regulatory one, but such has become its influence that it has evolved into the Enforcer-in-Chief of anything RIFM dictates, despite neither the RIFM or IFRA having a regulatory position of authority. Keep in mind, though, that this is for the benefit of the public. In the case of oak moss, the nearly 99% of the public who do not suffer any reaction to it.
Why the furor over a few ingredients? Because it isn’t just a few. The current list of “banned-or-restricted” components is over 120 compounds long, and expected to grow.
But let’s step back a moment to the 1970′s and talk about amaranth, an inexpensive and tasteless substance that creates a bright crimson outcome when added to a product. Many will recall it as “Red Dye #2″, which is now considered illegal in the United States as a food coloring. The US Food & Drug Administration (FDA) concluded that it could cause cancer in female rats if consumed in large quantities. It’s been subsequently identified by the European Food Safety Authority (EFSA) in 2010 to be harmless. In a strange twist of fate, however, EFSA concluded that Red Dye #40, which was the US replacement to Red Dye #2, should be restricted.
But considering the costs of testing to prove the safety of Red Dye #2 in animals (and the potential public outcry over animal testing), it’s not likely that Red Dye #2 would return in the US. At least so long as #40 is still considered safe in the eyes of the FDA.
The story of saccharine causing cancer in lab rats is very similar, despite the fact that it has never been shown as a cancer risk to humans, and despite the proportionate quantities that rats were given to create the resultant outcome.
These examples help illustrate that testing can reveal a variety of results. Each day, conflicting studies on the health effects of any chemical can be found in a medical journal to argue their point. With RIFM and IFRA, only one authoritative body performs a ‘certification’ of a substance, an advocacy organization presents that data as verified fact, and various regulatory bodies become eager to vote to ban or regulate the substance and substitute it with a synthetic. Coincidentally, any one of several IFRA members are happy to provide you with that synthetic compound.
That creates a cozy business relationship based on a single set of scientific controls. While I cannot say that RIFM’s testing is completely invalid, it does invite criticism due to the closed and single-source experimentation process. After all, this is how we arrived at Red Dye #2 almost 40 years ago, and how we arrive at compounds such as oak moss, rose oil, clove oil, and other common substances that heretofore have been deemed harmless (clove oil has been used in dentistry for years without issue).
While we understand the logic behind the limitations of use on certain substances, we should be cautious about organizations that are protecting people from themselves. We become especially suspect when those organizations are supported by the industries who benefit from their findings. It can be tantamount to chartering research to support the assertion that any compound can be considered as unsafe in a specific circumstance. True protection needs to be industry independent to remove the specter of bias.
Scentrist’s View: We aren’t fans of changing the industry for everyone to the benefit of a minority. In the case of true perfumes (colognes, eau de toilettes, EDPs) rather than ancillary components of a consumer product (dryer sheets, laundry detergent, dish soap), we appear to be protecting the overwhelming majority from the reactions experienced be a small minority who probably aren’t major fragrance consumers.
We feel a better method of protection lies in information and disclosure, such as found in the pharmaceutical and food industries today, where ingredients that have been scientifically proven to cause allergic reactions can be identified and appropriate warnings can be outlined to inform consumers and health professionals. The stance being taken by the IFRA is curiously similar to the notion of banning the sale of peanuts due to a fraction of people having allergic reactions to peanuts, and where a more rational approach would be to clearly label the package (as ridiculous as it may sound) as “may contain nuts”.
But there’s more to this story, and in our next installment, we’ll outline how the fervor over this issue reached such a crescendo.
In Part Two tomorrow: How did we get here?