Guest guest Posted September 1, 2007 Report Share Posted September 1, 2007 *Opinion:* You may remember that Danish dermatologists had previously panicked the EU into precipitous action over fragrance allergy - which eventually resulted in the notorious '26 allergens' debacle under Directive 2003/15/EC. The controversy and industrial damage which accompanied these measures halted any further legislation on alleged allergens at the time, but IFRA and EFFA now seem to have found a back-door way of creating some further progress - by invoking QRA methodology which manifests in the enormously complex 40th IFRA Amendment. This will presumably ensure that they continue to successfully take the lead in hi-jacking fragrance regulation under their banner of toxicological imperialism. Curiously, although DG-Ent appear to have invited EFFA to submit a scheme using the 40th Amendment framework for new considerations for sensitisers (citral, farnesol & phenylacetaldehyde), to be submitted to SCCP for rubber-stamping, they do not include the opinions of any other interested parties - such as those dermatologists who have suggested that the EU Commission defines the criteria for the inclusion of allergens into regulation, those that suggest the " 26 allergens " legislation includes many substances which do not present a proven history of clinical allergy, and those dermatologists who suggest that many substances included as allergens under the " 26 allergens " legislation are not allergens at all, or are too weak to be labelled as allergens. Cropwatch can't believe that DG-Ent or other Brussels staff have failed to be aware of this situation. - after all 30 seconds on Google will easily reveal it. Cropwatch led a popular campaign in early 2007 against the implementation of the 40th IFRA Amendment, which was widely reported in the media, and forced a time-concession from IFRA to implement the complex legislation for SME's. Cropwatch doesn't seem to have been asked by the Brussels regulators to contribute to questions to the SCCP on the present issue, which according to the way we read the Rules of Procedure, is actionable. We have therefore officially submitted an objection to the procedure (attached). N.B. We won't re-expose you to the article on the abandoned quenching hypothesis mentioned in Cropwatch Objection attached, but if you want to re-consult it, it is to be found in the June 2007 /Cropwatch Newsletter/ at http://www.cropwatch.org/newslet8.pdf We go into high gear on the opposition front if this presently-sought SCCP Opinion goes ahead - Cropwatch is not prepared to watch the destruction of what is left of the European fragrance/essential oils industry by moves like this coming from career toxicologists who do not work in the industry, & their seemingly bemused & obedient EU lawmaking counterparts, without a fight. Tony Burfield. Kendra Kirkham. Co-founders of Cropwatch. -- Sincerely, Anya of Natural Perfume Natural Perfumers Guild http://NaturalPerfumersGuild.com Natural Perfumers 1200+ members Group http://tinyurl.com/78kmv Quote Link to comment Share on other sites More sharing options...
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