Tony Burfield's Letter to IFRA regarding the petition and issues surrounding the 40th Amendment

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STOP THE FDA GLOBALIZATION ACT OF 2008

1st March 2007

Dear Sirs,

Please find attached the petition posted up at http://www.ipetitions.com/petition/ifra40/http://www.cropwatch.org/40thpetition.htm.

You will note that there are approx. 740 signatories to date, including perfumers, natural perfumers, MD's of aroma ingredient companies, aroma technicians, academicians, soap makers, staff from cosmetic & natural products companies as well as natural products commodity end-users from countries as diverse as Russia, Iceland & USA. There are a number of anonymous signatories, and to avoid any unfair accusations of ballot-rigging or signature duplication, we are quite willing to submit the owner's version of this petition (which reveals fuller identity details), to an independent 3rd party (who will need to agree to absolute confidentiality), if the need should arise. I think you if you read the comments section of the petition - scroll through http://www.ipetitions.com/petition/ifra40/signatures.html - you will be taken aback by the depth of feeling many have about over-regulation in cosmetics and interference with respect of freedom to use natural products generally.

Cropwatch believes IFRA has lost its way in recent times, and has effectively become over-influenced by the views of aroma megacorporations and career toxicologists, to the detriment of the perfumery art. We believe that IFRA's precautionary-principled interpretation of health & safety, does not find widespread public support, is sometimes based on selective interpretation of the available scientific evidence, & has knowledge gaps & shortcomings, some of which may due to limitations of available funds. Further, the window-dressing provided in the Jan 2007 IFRA Newsletter, designed to 'soften-up' industry over the 40th Amendments QRA scheme, does not fool us. The fact is that perfumery has become a somewhat tawdry money game, where the principle players have nothing to do with the art.

We believe that it is a very unhealthy situation: that IFRA/RIFM, being such influential bodies, are not independently financed. We believe that their findings & policies should be completely opened up for public discussion, and the existing exclusive & secretive 'Brussels regulatory club' reorganised in the interests & transparency & democracy. Further and most importantly, RIFM needs to be overhauled so that its capabilities can cover a proper risk/benefit analysis for all cosmetic ingredients - rather than delivering a mere risk analysis, as at present. Additionally RIFM/IFRA as powerfully influential bodies, have a social responsibility to those people they disadvantage and put out of work with their safety policies. Where natural ingredients are restricted or prohibited, they need to work with producers & manufacturers to find ways of reducing adverse reactions, which can be applied across the board to all natural ingredient producers - including the economically disadvantaged ones.

Finally, as is indicated by of the petition comments, IFRA needs to show 'joined-up-thinking' with other regulatory bodies as far as ingredient legislation is concerned. It's no good that FAO other EU Commission Depts, or Nation State Government Departments providing funds to farmers & producers to grow aromatic crops, if IFRA or the SCCP are subsequently going to recommend their restriction or banning in cosmetic commodities. It just makes for more unnecessary regulatory incoherence and social hardship.

Yours sincerely,

Tony Burfield
for & on behalf of Cropwatch -
the Independent Watchdog for Natural Ingredients.
www.cropwatch.org proposing the Boycott of the 40th IFRA Amendment, for reasons set out at

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