Just before Valentine’s Day a set of recommendations were presented to the European Union (EU) by the Scientific Committee on Consumer Safety (SCCS) to ban or restrict 23 fragrance raw materials. A few days after that I wrote an editorial about the lack of scientific rigor that was applied to that decision and asked for a real scientific clinical study with appropriate controls to be performed to truly determine the real potential of these materials to produce an allergic effect. About a week after that editorial I was pointed to a website called IDEA (International Dialogue for the Evaluation of Allergens) and once I spent some time reading what was there much of my concern for the future of raw materials has been alleviated.
IDEA was formed in May of 2013 and has had four separate workshops since then about how to classify, test, and unequivocally determine which materials are allergens. Their Annual Report (click here to read it) was released a week after the SCCS made their recommendation to the EU. While the SCCS recommendations caused a lot of people, I included, to exercise our best Chicken Little impressions. After spending the last couple days reading the IDEA Annual Report I am no longer worried.
IDEA has representation from every stakeholder in this; IFRA, SCCS, EU, the big perfume firms, the big perfume producers, and particularly important dermatologists and clinicians. They have been spending this first year doing workshops with participation from all involved and they are evolving an action plan which will once and for all determine in a scientific and statistically sound manner whether any specific material is an allergen. This is what any of us who have looked at this data from a scientific point of view have asked for and it is now happening.
I also spoke with a few of my contacts within the industry and they all seem to think that if the EU takes any action at all in May, when the 90-Day comment period is up, it will be increased labelling. Something which alerts a consumer to the presence of a potential allergen without making it seem like the Surgeon General’s warning on a pack of cigarettes.
A month after I was busy running around yelling “The Sky is Falling!” it looks like the solutions are all in place to make sure that only the best scientific data will eventually determine which raw materials will be banned or restricted and that is the best outcome I could have asked for. Which leaves perfumery, like Mark Twain, to say, “The reports of my death have been greatly exaggerated.”