DEVELOPMENTS
Fragrance Creators will continue to utilize
a multi-pronged approach to advancing
the approval of new chemicals, including
follow-up with Assistant Administrator
Alexandra Dunn, who leads the Office of
Chemical Safety and Pollution Prevention
(OCSPP).
In June 2019, Fragrance Creators
submitted comments to the EPA regarding
the prioritization of HHCB (Galaxolide).
Because of our existing relationship with
OCSPP, we heard directly from leadership
that our comments would be thoughtfully
considered. In accordance with
congressional intent, LCSA Modernization
should promote safety, innovation, and
sound science. intends to have its rulemaking ready for
review by its Board in late 2020.
VOC Activity:
California Air
Resource Board FDA Proposal:
Assessing Safe Use
Levels for Fragrance
Allergens
The California Air Resource Board
(CARB) has broad statutory authority to
adopt regulations to achieve the maximum
feasible reduction in volatile organic
compounds (VOCs) emitted by consumer
products. In its 2016 Fragrance Survey
and 2013-2015 Consumer Product Surveys,
it is apparent that CARB makes a number
of inaccurate and incomplete assumptions
about fragrance. CARB has initiated a
rulemaking to meet 2023 and 2031 goals.
On July 10, Fragrance Creators
presented to CARB. This presentation
highlighted the importance and benefits
of fragrance, how fragrances are made,
and key assumptions that CARB should
reconsider. Specifically, Fragrance Creators
recommends that CARB use data that
clarifies fragrance is not 100 percent VOC
and that fragrance ingredients are far less
reactive than CARB currently calculates.
Fragrance Creators joined HCPA, PCPC,
and ACI in technical presentations to CARB
from July 10 – July 12. CARB indicated a
desire to follow-up directly with Fragrance
Creators in early August for additional
insights.
Fragrance Creators will continue to
work closely with the CARB Task Force
to participate in and shape the rulemaking
process. The goal is that—by being
a resource to CARB and supplying
more complete data and narratives—the
industry will influence CARB as it drafts
its recommendations for reducing VOC
emissions from consumer products. CARB
Canada: CMP 3
The Environment and Climate
Change Canada (ECCC) has drafted a
comprehensive VOC regulation, similar
to CARB. We are aware that ECCC
would like to implement CARB standards,
but, based on the draft released on July
6, 2019, ECCC does not yet align with
CARB, particularly regarding exemptions.
Feedback on ECCC’s draft is due
September 19, 2019. Fragrance Creators
has been communicating with CCSPA
and HCPA and will be engaged in the
rulemaking process.
Per FDA’s request, Fragrance Creators
is leading industry in dialogue with FDA
on its upcoming efforts in quantifying the
level of safe use of materials that have been
identified by the EU as being fragrance
allergens. Fragrance Creators, joined by
its members and representatives of RIFM
and PCPC, held a second meeting with
Dr. Linda Katz, Director of the Food and
Drug Administration’s (FDA’s) Office of
Cosmetics and Colors, and senior staff.
As a result of the active engagement of
Dr. Katz and her team, Fragrance Creators
further developed its relationship with
FDA; obtained clarity about FDA’s
thinking and needs related to allergen
communication; shared information
about Fragrance Creators’ initiative to
educate the public about fragrance, The
Fragrance Conservatory; and facilitated
further education about RIFM and QRA2.
Fragrance Creators will continue to
leverage opportunities to advocate for the
correct interpretation of the QRA model,
with the desired outcome of having a
consistent way of evaluating the safe-use
level of fragrance allergens.
2016, will address the remaining 1550
priority chemicals out of the original 4300
chemicals identified as priorities during the
categorization. Fragrance Creators has been
monitoring the evaluation of “musks” under
CMP 3 since these chemicals are fragrances
and/or fragrance ingredients. In July, the
final screening assessment for the chemicals
that fall under the “Musks” category was
released. The final conclusion was that
these substances are not harmful to human
health or the environment, and no further
action (restrictions, controls, etc.) will be
implemented at this time.
Canada: Hotlist
The Cosmetic Ingredient Hotlist
(Hotlist) is an administrative tool that
Health Canada uses to communicate to
manufacturers and others that certain
substances may be prohibited or restricted
for use in cosmetics. On July 1, Fragrance
Creators submitted comments regarding
Eucalyptus Oil (proposed new warning)
and Dihydrocoumarin (proposed change
from prohibition to restriction). Fragrance
Creators will continue to engage and will
inform the RSEC regarding any updates. FN
Canada: CMP 3
The Chemicals Management Plan (CMP) is
a Government of Canada initiative aimed
at reducing the risks posed by chemicals
to Canadians and their environment. The
next phase of the CMP 3, launched in May
Issue 2, 2019 | FRAGRANCENOTES.ORG | 47