The Natural Perfumers Guild has partnered with Cropwatch in the past, most notably in early 2007, when the Guild joined them in challenging the adoption of IFRA's (International Fragrance Association) 40th Amendment without public review or input. We further support Cropwatch in their ongoing efforts to bring an outside evaluation as to the practices related to the legislative control of natural aromatics as they are used in the body care, aromatherapy and perfumery industries. The information presented below is further documentation of Cropwatch's ongoing efforts:
CROPWATCH STATEMENT ON TEA TREE OIL Jan 2008.
The SCCP has the subject of tea tree oil (TTO) on its agenda for its Brussels meeting of 22.01.08. You will remember that allegations about the instability & skin safety of tea tree oil, as well as complaints about gaps in the toxicity data, were previously made in the flawed SCCP Opinion SCCP/0843/04, to which the Australian Tea Tree Oil Industries Association ATTIA (but not producers of Chinese TTO) dutifully responded by privately submitting evidence to the SCCP on March 31st 2007. You might want to consider some further points:
a.) That the pharmaceutical industry sees the widespread use & beneficial effects of TTO as competitive to its health-care products portfolio and that Brussels is frequently visited by pharmaceutical trade lobbyists. Aspersions are frequently made in the media against the safety or efficacy of particular essential oils (which
Cropwatch will list in detail in its next Newsletter) which have advantaged the interests of the pharmaceutical & chemical trades. Questions need to be asked why baseless allegations about TTO safety have prompted this particular chain of events starting in 2004.
b.) That ATTIA were in a privileged position with respect to fund-raising for financing the safety studies demanded by the SCCP, via Australian governmental & customer-base support. Whilst it is heartening to see the essential oil industry defending itself against toxicological imperialism for once, taking this as a precedent for further SCCP safety data demands for other essential oils & natural aromatic ingredients would seriously financially compromise the position of the essential oil producing industry.
c.) Cropwatch is grateful to Ian Southwell for delivering the ATTIA booklet to us at Graz in 2007, which summarises the TTO findings as presented to SCCP. However as we understand it, the actual experimental data has only been presented to the SCCP committee. This lack of transparency concerning privately submitted evidence to the SCCP by third parties is not uncommon - a similar situation exists, for example, with the research on photoclastogenicity for the furanocoumarins bergamottin & isopimpinellin, privately commissioned by RIFM & carried out by David Kirkland of Covance UK. RIFM's summary of the findings in its’ 2007 Newsletter does not substitute for access to the full data being available in the public domain.
1. Cropwatch has been collecting information on any end-user adverse effects from TTO oil usage, via the public returns of an extensive questionnaire on its website www.cropwatch.org. However at a meeting between Cropwatch, the Perfume Foundation & members of the Cosmetics Commission in Brussels in 2007, Cropwatch were told that end-user data on ingredients was not admissible as evidence for safety assessments. As we consider this position to be both nonsensical & legally challengeable, Cropwatch has continued to keep the TTO questionnaire running on its website, since completed questionnaires continue to be received from TTO users. We will be closing the project shortly, and the data will be independently scientifically assessed.
2. Cropwatch has no confidence in the SCCP to be able to properly assess the risks presented by the use of TTO, because, amongst other things, estimations of any actual adverse effects from end-users are ignored. It was admitted during the Cropwatch-Perfume Foundation-Cosmetics Commission meeting mentioned above that, up to that point, comprehensive data-searching of the published literature on specific topics was unavailable to Brussels staff.
Evidently then it cannot be ruled out that the SCCP Opinion SCCP/0834/04 was merely based on a trawl of selective evidence, & its conclusions have to be regarded as unsafe. Further, Cropwatch considers that a negative safety opinion on tea tree oil as a cosmetic ingredient would rebound on the more widespread use of tea tree oil as a biocide (e.g. to help combat hospital-acquired MRSA or Clostridium difficile infections).
Because risk-benefit considerations for individual ingredients are not taken into consideration by the cosmetics Commission (stated Cosmetics Commission policy to Cropwatch, 2007) the SCCP may in this instance be in danger of generating an Opinion, which either indirectly or directly, could affect public safety.
3. From information already disclosed by ATTIA regarding their full findings, and from Cropwatch's so far unpublished questionnaire returns, it would seem that predictions of adverse health effects from TTO oil usage by career toxicologists and others involved in advising the EU regulator, were considerably exaggerated.
As this is a further example of safety assessment imbalance at Brussels, Cropwatch calls for a review of the way that cosmetic ingredient safety is assessed by the regulator, since the existing (over-) precautionary principled approach is clearly failing the public.
Cropwatch Team 2008.