RQA AGM 11th March 2001 London:
Safety address by Tony  Burfield 

Introduction.

 I am thankful to Gabriel Mojay who afforded me the opportunity to make some comments and observations at this annual gathering. I commented on several matters, which broadly fall into two main subject areas:

1. An International ad-hoc committee for Aromatherapy? 

Paraphrasing the comments in the Health Which report Feb 2001 there is no globalised agreement of a negative list of essential oils for Aromatherapy (AT). It would seem worthwhile to endeavour, via the good offices of the professional Aromatherapy organisations, to establish such a list, and hence to try and counter  criticism of our profession.  Further to this I have made the suggestion to a number of individuals, that in the first instance, an ad-hoc committee is set up amongst the professional AT organisations to further this aim, and at the meeting I suggested that  safety representatives from ISPA, IFA and RQA would be welcomed in this forum. 

I also suggested some further aims for the ad-hoc committee: 

  1. To promote safety awareness, policy and education more generally in AT. 

  2. To promote opposition to the COLIPA (European Cosmetic Toiletry and Perfumery Association) list (explained further below) 

  3. To explore common ground with other organisations which also use essential oils with respect to impact of legislation etc. I foresaw those organisations as including perfumery, flavours, cosmetics, herbalism and pharmacology. 

Whilst I saw myself as a potential catalyst and agitator for the establishment of the ad-hoc Aromatherapy group, and not necessarily its’ convenor, I have suggested an opening policy gambit for the rapid establishment of a negative list. This would basically consist of following the safety policy outlines put forward at National Association of Holistic Aromatherapy’s biannual meeting in Seattle last year. Here is was recommended to the membership that a voluntary code of practice is followed, which mirrors the IFRA (International Fragrance Research Association) Code of Practice for fragrance ingredients as it specifically applies to natural ingredients (i.e. essential oils, absolutes, resinoids & gums etc. etc). I further suggested that the “IFRA banned List” and the “IFRA Restricted list” be followed per se, and a further list should be considered for discussion. Although these are posted on www.atlanticinstitute.com for convenience they are additionally reproduced below. 

Banned IFRA list

IFRA Restricted list

Angelica root oil Angelica archangelica (phototoxic) 0.78%

Bergamot oil expressed Citrus aurantium ssp. bergamia (phototoxic) 0.4%

Bitter Orange oil Citrus aurantium (phototoxic) 1.4%

Cassia oil Cinnamomum cassia (sensitizer) 0.2%

Cinnamon bark Cinnamomum zeylanicum (sensitizer) 0.2%

Cumin oil Cuminum cyminum (phototoxic) 0.4%

Grapefruit expressed Citrus paradisi (phototoxic) 4%

Lemon oil cold pressed Citrus limonum (phototoxic) 2%

Lime oil expressed Citrus aurantifolia (phototoxic) 0.7%

Tagete oil & absolute Tagetes minuta (phototoxic) 0.05%

Oakmoss absolute & Resinoid Evernia prunastri (sensitizer) 0.1%

·         Pinaceae oils to have a peroxide value of less than 10 millimoles peroxide per litre (sensitizer)

·         Rue oil Ruta graveolens limit (phototoxic) 0.78%

·         Verbena absolute Lippia citriodora (sensitizer) 0.2%

·         Treemoss absolute Evernia furfuracea (sensitizer) 0.6%

First Additional list for discussion: Should we also recommend that the following oils also not be used?

·         Laurel leaf oil Laurus nobilis: many fragrance houses have internally imposed lists restricting or banning this product.

·         Thuja occidentalis oil (neurotoxic)

·         Tansy Tanacetum vulgare (neurotoxic)

·         Pennyroyal Mentha pulegium/Hedeoma pulegioides and other high      Pulegone oils (e.g. Micromeria

·         Parsley seed oil Petroselinum crispum (hepatoxic)

·         Parsley leaf Petroselinum crispum (hepatoxic)

·         Boldo oil Pneumus boldus (acute oral toxicity)

·         Massoia oil (Cryptocaria massoia) Powerful irritant.

·         Melaleuca bracteata oil. Methyl eugenol is a suspected carcinogen. We should not allow oils like M. bracteata (95% methyl eugenol) in AT?

N.B. This list was quickly drawn up and may not be fully up to date. The IFRA guidelines can be viewed on their official site at http://www.ifraorg.org/GuideLines.asp

2. “Death of Perfumery”. 

Since some legislational aspects pertaining to AT were covered in Sylvia Baker’s address at this conference, another more industrial perspective on matters surrounding essential oil usage was given by the author. The “death of perfumery” is a somewhat melodramatic phrase, lately coined by some practicing perfumers, following a turn of events which outwardly may appear benign, but whose far-reaching effects are being felt by the aroma industry and may eventually seriously affect AT. The story here starts with the requirement for a more precise wording for labeling cosmetic products than the mere statement “contains parfum” required by the Cosmetics Directive. (Some background information on the Cosmetics Directive may be of interest to many Aromatherapy suppliers who sell creams, body lotions etc., and can be found at  http://dg3.eudra.org/cosmetic/pdf/vol_1en.pdf ; the infamous Sixth Amendment is outlined on http://members.aol.com/acolli3210/page14.htm . The “contains parfum” issue can be referenced on http://www.dti.gov.uk/access/cosmetic/appendix.html.

The more precise labelling requisite is in consideration of consumers with known fragrance allergy, and follows statements from various professional dermatitis associations both in Europe1 and America2 urging improved labeling information to help better identify fragrance allergens. The converse of this, is the position traditionally taken by the perfumery industry, which has always maintained that in order to protect its intellectual property, research effort etc. that formulations should not be required to be disclosed (successful representation lead to the “contains parfum” situation) . The World Health Organisation and EU criteria for skin contact allergens have, however, enabled certain fragrance compounds to be identified as allergens3, and through a literature search, 24 fragrance allergens have been identified (although not all of these met the WHO criteria), 13 of which were frequently reported, and the 24 allergens as a whole are frequently referred to as the COLIPA list. This list of frequently and less frequently reported items includes a number of chemicals which commonly occurred in essential oils such as benzyl alcohol, benzyl salicylate, cinnamyl alcohol, cinnamic aldehyde, citral, coumarin, eugenol, geraniol, iso-eugenol, anisyl alcohol, benzyl benzoate, benzyl cinnamate, citronellol, farnesol, limonene and linalol.  The attitude was taken, that the presence of the substances in the fragrance mix, whatever their nature, was sufficient to warrant labeling and hence essential oils should be included, as these may be a significant source of these items. Further to this, in a very recent development, we understand that the BEOA has recently published a list of some 97 “essential oil sensitisers", with a breakdown of the levels of the sixteen chemical components noted above in each of the oils. By adding up the percentage of these 16 components to give an overall level of "sensitisers", we arrive for example at a figure of  92.3% sensitisers in clove oil and 57.5% in bergamot oil, according to this reckoning. Obviously this procedure makes a number of assumptions, not the least that there is not some quenching effect amongst constituents which mitigate against the overall sensitising effect.

Coming back to the main theme, the outcome of these measures meant that fragrance customers were unhappy about putting fragranced products onto the market which carried labels drawing attention to fragrance allergens, which in turn has created a demand for fragrances which are free of these items. Perfumers, in turn, working on fragrance briefs for these customers are often being required to construct perfumes where their usual raw materials (including many essential oils) are not available. This situation, in the opinion of many in this field, has made a mockery of the art. Major European fragrance customers have been somewhat perplexed by the situation, and now a gradual realisation is emerging, amongst those “on the ground” anyway, that a blanket ban on the whole contents of the list is impractical, and a specific number of “allowable” items might be a more appropriate way forward. Alternatively, perfumery manufacturing sales strategies may be focussed more outside European markets, where these limitations do not apply.

The implications for AT are clear. By drawing attention to the sensitising risks of essential oils in cosmetics, further examination/legal restrictions to the widespread public use and product ingredient deployment of essential oils may follow. Already as we have seen above, some impact is already being felt.

On the established use of essential oils in cosmetics, toiletries and other products to be found in any European high-street store or chemist. It is understood by the author (but subject to verification) that the EU will independently independently verify the findings on which the 24 materials in the COLIPA list are based, but they are also extending the scope of materials investigated. Meanwhile, whereas it has always been the case that fragrance customers have imposed their own restrictive ingredient lists for fragrance submissions which are often more extensive than those from IFRA, the size of these lists continues to grow.

 Notes.

1including the European Society for Contact Dermatitis (home page: http://www.dermis.net/org/escd/ and the European Environmental & Contact Dermatitis Group home page http://www.sdu.dk/Med/Homepages/eecdrg/egen.htm

2American Academy of Dermatology home page http://www.aad.org/

3See for example Basketter D., Flyvolm M.A., & Menne T  (1999) “Classification criteria for skin-sensitising chemicals: a commentary” Contact Dermatitis Apr. 1999, 40 (4), 175-182.

Selection of natural products containing COLIPA listed ingredients: (this list is by no means exhaustive, but just serves to give a few examples) 

Cinnamic alcohol: styrax oils/oleo-resins 

Cinnamic aldehyde: Cinnamic bark oil, cassia oil.  

Eugenol: Basil, Clove, Pimento, Cinnamon leaf, & Rose oils. 

Isoeugenol: Nutmeg & Ylang oils 

Citral: Litsea cubeba, Lemongrass oils

Geraniol: Citronella, Palmarosa, Geranium oils

Citronellol: Rose oil, Melissa oil

Linalol: almost ubiquitous: Rosewood, Mentha citrata etc.

Limonene: widespread occurrence: Heklichrysum, caraway, grapefruit etc.

Benzyl alcohol: peru Balsam oil, Styrax oils

Benzyl cinnamate: Ylang yalng oils

Benzyl benzoate: Jasmin absolute, ylang ylang oil.

Farnesol: Cananga, Neroli oils.

Coumarin: Tonka bean oil, deer tongue absolute, melilot absolute, cassia oil.

Anisyl alcohol: Vanilla absolute (esp. Tahiti).

Example of an Unidentified  Fragrance Customers Restricted list (natural products cited only): 

Benzoin resinoids, Calamus oil, Cananga oil, Cinnamon leaf oil, Geranium oil & absolute

Lavender oil & absolute ,  Jasmin oil & absolute, Lavandin oil, Lemongrass oil, Litsea cubeba oil, Orange flower absolute, Orris absolute, Rose oil & absolute, Sandalwood oil, Birch tar, Cade oil, Vetiver oil and Ylang ylang oil. 

 

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Copyright © 2001 by Tony Burfield All Rights reserved.