Last week the US/ EPA celebrated its 40th anniversary and honored the many accomplishments of their staff to identify and improve human and environmental conditions. Please read the remarks by Administrator Lisa Jackson, who has strongly lead the essential direction of this front line government agency for the past two years.
Very noteworthy to this blogger is last month's release for comment, the proposed fragrance ingredient enhancements to the DfE (Design for the Environment). This report was prepared by the EPA in consultation with Fragrance material toxicologists, trade associations, cleaning industry formulators, fragrance industry product development and marketing representatives. Equally important was the sponsorship and organizational guidance from GreenBlue and CleanProduction.
The process of developing and/ or organizing attributes and criteria for human and environmental safety guidelines fell to a group called the Fragrance TAC Team. Wisely the TAC did not cover air fresheners (allergens) or personal care liquid soaps and shampoos. The focus was on standards for institutional and consumer product cleaners, the largest volume of product usage for worker and consumer safety. It still took nearly four years for the proposal to be submitted.
Several scientific norms and task behaviors needed to be addressed before the TAC was comfortable to be forthcoming in the twenty plus telephone conferences and side meetings. One reason, most members of the Team were involved in the "tox" reviews of the fragrance formulas. Almost all submissions for sponsored formulators were rejected and assigned to a pending status. These TAC members were confused what exactly to do and instruct their Perfumers. They all looked to work with detailed guidance from RIFM/ IFRA the leading trade association. Membership requires strict adherence to RIFM guidelines. ["Anyone who conducts an argument by appealing to authority is not using his intelligence; he is just using his memory", Leonardo de Vinci (1452-1519)]
A second reason, RIFM's extensive fragrance material data is based on QRA (quantitative risk assessment), with no effective link to a Hazard based approach vital to environmental modeling for population centers. After several failed strategy attempts to "shrink environmental science" as not equal, the top toxicologists and trade associations relented because they had no environmental data for the workhorse fragrance materials used in cleaners. Essentially in the last decade, they underachieved their own profession, trade members and employers. Worse they had no authority to quit the TAC.
The lead industry scientists did rally beyond their negociant procedures and assembled new criteria for essential oils, a material that will need closer examination because of a lack of quality standards between perfume and technical grades. Going forward, instead of merging DfE data from RIFM members, a consortium was formed. Their first task is to hire a consultant (budget $150,000) as the popular complaint is the proposal document is too complex. Or is this retort still a rivalry of aims? Certainly the work of the consortium will be time consuming and cause an undetermined delay. Ummm.
Tuesday, December 7, 2010
Thursday, September 2, 2010
One Who Serially Sits on Committees
After five years of planning, organizing and numerous meetings, the DfE program now has the fragrance ingredient criteria to execute a more effective program with stakeholders. Why the five year struggle? How unique is a fragrance formula? What is the effect of transparency? What really matters?
What matters is SAFETY for consumers, workers, children, pets, and the environment.
The committee members of the Fragrance Technical Group do deserve credit for their time and transformation. As a member myself I want to think that everyone involved will show support and do the tasks ahead. We don't need more discussion or definitions, just action.
What matters is SAFETY for consumers, workers, children, pets, and the environment.
The committee members of the Fragrance Technical Group do deserve credit for their time and transformation. As a member myself I want to think that everyone involved will show support and do the tasks ahead. We don't need more discussion or definitions, just action.
Monday, August 23, 2010
Moral Hazards
Does belonging to IFRA under today's regulatory climate constitute a moral hazard? This is a question that was tossed at me recently. Another question and statement was how Fragrance industry regulators are only interested in expanding their numbers, influence and dragging out "comment periods."
In a recent article observing that the moral hazard with self regulatory groups, "Leniency in Private Regulatory Enforcement: the Role of Organizational Scope & Governance." is greatest when enforcement includes products that entice customer loyalty.
The article proposes that internal regulatory enforcement is higher rather then at a self regulatory agency because there is no consequence to the independant regulators.
IFRA members please resign and demonstrate to your clients a higher enforcement standard.
In a recent article observing that the moral hazard with self regulatory groups, "Leniency in Private Regulatory Enforcement: the Role of Organizational Scope & Governance." is greatest when enforcement includes products that entice customer loyalty.
The article proposes that internal regulatory enforcement is higher rather then at a self regulatory agency because there is no consequence to the independant regulators.
IFRA members please resign and demonstrate to your clients a higher enforcement standard.
Tuesday, July 27, 2010
RESIGN IFRA
Science has it's rhythms.
These rhythms are often beautiful to observe and listen. Right now environmental science is stroking the rhythm of safe cleaning products in consumer and workers hands. How and why? Mostly from sound and steady intellectual improvements, organization and openness. Essentially environmental scientist called for precautionary principles rather then bans.
Now that the DfE standards for safe cleaning product ingredients are established, it is time to step back and take account the main players in the process, in particular the last four years when the attributes and criteria were organized.
My call to arms is Fragrance Houses resign from IFRA. Let the industry "core company" board members run it, pay for it and audit themselves. The principle material data is available and future changes must be published. There is no obligation that any of you must don the IFRA RIFM FMA hair shirts.
Go out and do what you do best. Innovate. Make great colognes, skin products, again. Follow the rhythms of the crowd, trend setters or savants. Devote your resources to creativity and safe practices. It's about customer requirements.
But when it comes to rinse-off products, don't be evil. Relax on trying to delight consumer test panels and overwhelm our senses by trickle downing every innovation and condition the masses. Be transparent, disclose your inventory and you will not have to open your formulas. Ever.
These rhythms are often beautiful to observe and listen. Right now environmental science is stroking the rhythm of safe cleaning products in consumer and workers hands. How and why? Mostly from sound and steady intellectual improvements, organization and openness. Essentially environmental scientist called for precautionary principles rather then bans.
Now that the DfE standards for safe cleaning product ingredients are established, it is time to step back and take account the main players in the process, in particular the last four years when the attributes and criteria were organized.
My call to arms is Fragrance Houses resign from IFRA. Let the industry "core company" board members run it, pay for it and audit themselves. The principle material data is available and future changes must be published. There is no obligation that any of you must don the IFRA RIFM FMA hair shirts.
Go out and do what you do best. Innovate. Make great colognes, skin products, again. Follow the rhythms of the crowd, trend setters or savants. Devote your resources to creativity and safe practices. It's about customer requirements.
But when it comes to rinse-off products, don't be evil. Relax on trying to delight consumer test panels and overwhelm our senses by trickle downing every innovation and condition the masses. Be transparent, disclose your inventory and you will not have to open your formulas. Ever.
Tuesday, June 15, 2010
IFRA: NAVEL GAZING
It's often been stated by scientists that the weakest science is medical studies. Their conclusions are based on small surveys, numerous measurement errors and the tendency to discard data that does not fit. Ultimately, that is why health issues represented by self-regulated industry associations are most times wrong.
The trouble with wrong positions is, they are justified by an institutional imperative of mindlessly imitating peers, no matter how foolish. This imperative is so deeply supported, entrenched and enforced, often the wiser choice must wait till the leadership changes.
Some examples; whenever a specific material's safety in use is challenged, IFRA's first reaction is to divert attention to the entire body of work. Yet every chemical examined (+3000) has a different back story __ why, how, when and who supported the cost.
-Ingredient transparency is not a threat to formula disclosure.
-Toxicology studies sponsored by NGO's are not evil. Their intent is universal, like worker, child and water safety.
-Environmental data gaps are not justified. "Spray and pray" is how grandfather did it.
-The non-disclosure/ transparency terms for the proposed "open to all" consortium for assembling DfE criteria will
stall conversion to safer compounds.
The biggest threat to "business as usual" comes from the EU REACH program. But the response from the IFRA Board and guardians has only increased cost and risk to all segments served. As I have stated before the industry should have focused on revising fragrance compounds in products that are rinsed off. That solution is still in hand.
One sure action, Business Managers, stop approving expenditures for outside consultants. Your own regulatory staff have been lazy, self-absorbed, wasting time and money while taking IFRA's lead...... navel gazing.
The trouble with wrong positions is, they are justified by an institutional imperative of mindlessly imitating peers, no matter how foolish. This imperative is so deeply supported, entrenched and enforced, often the wiser choice must wait till the leadership changes.
Some examples; whenever a specific material's safety in use is challenged, IFRA's first reaction is to divert attention to the entire body of work. Yet every chemical examined (+3000) has a different back story __ why, how, when and who supported the cost.
-Ingredient transparency is not a threat to formula disclosure.
-Toxicology studies sponsored by NGO's are not evil. Their intent is universal, like worker, child and water safety.
-Environmental data gaps are not justified. "Spray and pray" is how grandfather did it.
-The non-disclosure/ transparency terms for the proposed "open to all" consortium for assembling DfE criteria will
stall conversion to safer compounds.
The biggest threat to "business as usual" comes from the EU REACH program. But the response from the IFRA Board and guardians has only increased cost and risk to all segments served. As I have stated before the industry should have focused on revising fragrance compounds in products that are rinsed off. That solution is still in hand.
One sure action, Business Managers, stop approving expenditures for outside consultants. Your own regulatory staff have been lazy, self-absorbed, wasting time and money while taking IFRA's lead...... navel gazing.
Wednesday, May 19, 2010
NOSE CANDY part 2
The recent publication about disclosure of unsafe fragrance materials found in an analysis of leading consumer products has had a response from FMA aka IFRA North America. The complete response can be found on FMA's website under two sections, "Fragrance Safety is No Secret (5/12/10)" and "FMA Finds New Cosmetics Report Misleading (5/13/10)."
The Green Nose finds these statements to be the most responsible, open and carefully considered comments by IFRA. Bravo for coming out of the gates swinging.
But before IFRA and the FMA's organization arm, The Robert's Group, get too crafty, haughty and confident in their lobbying efforts, peer review is not always relative to argue about and opens yourself to similar claims. For example, The publication of IFRA's fragrance tested material list makes no claim to its completeness with it's member companies. Nor did the release have any disclaimer or statement about new chemicals, revised processes or proprietary materials that have not been peer reviewed.
The Green Nose does give extra weight to environmental toxicity since I want to equalize the human and environmental safety concerns. I wrote before how a former employer accidentally caused a DEP spill and it entered a stream resulting in a noticeable fish kill. The amount of DEP was very small as it came from empty drums that were left outside without their bungs (root cause). Some quanity of rainwater accumulated in a weeks time and the drums were drained in our plant yard by the drum recycler. I can't relate this tale to FMA's dosage statement about a grain of sugar in an olympic swiming pool but what I do know is the minuscule amount was detectable to the water commission's GLC and their claim that DEP is an oxygen depleter. Should we have insisted on a group of scientist to review the findings when the state Water Commission shut us down?
The Green Nose finds these statements to be the most responsible, open and carefully considered comments by IFRA. Bravo for coming out of the gates swinging.
But before IFRA and the FMA's organization arm, The Robert's Group, get too crafty, haughty and confident in their lobbying efforts, peer review is not always relative to argue about and opens yourself to similar claims. For example, The publication of IFRA's fragrance tested material list makes no claim to its completeness with it's member companies. Nor did the release have any disclaimer or statement about new chemicals, revised processes or proprietary materials that have not been peer reviewed.
The Green Nose does give extra weight to environmental toxicity since I want to equalize the human and environmental safety concerns. I wrote before how a former employer accidentally caused a DEP spill and it entered a stream resulting in a noticeable fish kill. The amount of DEP was very small as it came from empty drums that were left outside without their bungs (root cause). Some quanity of rainwater accumulated in a weeks time and the drums were drained in our plant yard by the drum recycler. I can't relate this tale to FMA's dosage statement about a grain of sugar in an olympic swiming pool but what I do know is the minuscule amount was detectable to the water commission's GLC and their claim that DEP is an oxygen depleter. Should we have insisted on a group of scientist to review the findings when the state Water Commission shut us down?
Tuesday, April 20, 2010
NOSE CANDY part 1
With Earth Day approaching there are some things to be thankful for.
The official announcement for the merger of RIFM and FMA into IFRA.. This reorganization of resources may give a greater promise to a greener result for fragrance materials. This should signify the end of the protectionist stances and a shift to the innovationist. I am hopeful that this will forward transparency into the supple chain, and provide identity to aromatic materials that pass EPA's DfE review for human and environmental safety.
The completion of the Fragrance Technical Action after nearly three years. The how, what and when of the DfE program will have a seperate session at the second Sustainable Fragrance conference in May.
Procter & Gamble, who directly creates, compounds and markets Fragrances that would rank them in the top three companies has started a sustainability expert panel. This may compensate for P&G not becoming one of the primary member firms in the new IFRA structure. This glaring ommission maybe due to an arcane by-law of RIFM membership, if so that should be changed. P&G are today the only major "soaper" who creates their own compounds and largely responsible for the polycyclic musk environmental contamination.
THE HISTORY OF BEAUTY by Geoffrey Jones is published. This respected business study brings positive attention to the industry I love.
The official announcement for the merger of RIFM and FMA into IFRA.. This reorganization of resources may give a greater promise to a greener result for fragrance materials. This should signify the end of the protectionist stances and a shift to the innovationist. I am hopeful that this will forward transparency into the supple chain, and provide identity to aromatic materials that pass EPA's DfE review for human and environmental safety.
The completion of the Fragrance Technical Action after nearly three years. The how, what and when of the DfE program will have a seperate session at the second Sustainable Fragrance conference in May.
Procter & Gamble, who directly creates, compounds and markets Fragrances that would rank them in the top three companies has started a sustainability expert panel. This may compensate for P&G not becoming one of the primary member firms in the new IFRA structure. This glaring ommission maybe due to an arcane by-law of RIFM membership, if so that should be changed. P&G are today the only major "soaper" who creates their own compounds and largely responsible for the polycyclic musk environmental contamination.
THE HISTORY OF BEAUTY by Geoffrey Jones is published. This respected business study brings positive attention to the industry I love.
Sunday, February 7, 2010
Keeping the Dream: IFRA Preposes RIFM and FMA
Buy the dream and you will live forever. Betray its legacy and you will wither. Ignore your detractors and you will perish.
Protect your golden icons, drive cost from your business, promote, generate repeat sales against competitors, innovate, be transparent about what matters, and always look forward expressed in new products. Easy.
So what happened that a regulatory monopoly is now necessary? Is it just conceptional enemies or a self regulatory mobilization demanding relevance?
Lets look at the legacy and the internal and external markets that are served.
ELITES - This is the bonafide, artistic, critically acclaimed trend leaders whose work is expressed through limited, exclusive distribution. Master perfumers status and reputations are made using what nature, science and imagination can provide.
PREFERRED - These are avatars of the Elites, using more science and precision. Preferred products are intended to aspire, feed the frenzy, promote ubiquitous images/ memory and drive traffic to the dream. Supply is determined by privilege, give backs and performance.
OUTSIDERS - This is populated by technicians who satisfy real every day needs. Their art comes from existing available material sources, natural and synthetic, mid grade to technical qualities. Their products thrive in public health usages.
How will IFRA be effective serving these interests? Will they preserve the materials the Elites demand? Will IFRA's primary focus be on the EU Regulatory process and assign fiscal responsibilities in the global supply chain for the Preferred? IFRA already assumed January 1st the fragrance related regulatory functions and advisory initiatives of the European Flavour and Fragrance Association. Will IFRA personalize the transparency process for environmental science? Can IFRA inspire trust and leadership when prior self regulation tactics fostered a squeamishly incoherent anti-fragrance movement?
What is evident on the regulatory agenda are of course, educational forums. FMA just hosted a speech from Stats.org. RIFM will address this week how "Transparent Science Supports Brand Trust." And IFRA is grappling with population risk hazards vs quantitative assessments.
Upcoming in May will be a seminar hosted by EPA's DfE, and third party reviewers NSF, and ToxServices to guide Fragrance creators through the new DfE screen. This precedes the Sustainable Fragrances 2010 conference, which should be more progressive then 2009's program. Since the DfE screen should include environmental safety hazards, seminar attendance is critical, affordable and inexcusable.
[note: there have not been any press releases but excerpts from a recent interview in Perfumers & Flavorist magazine. I doubt the quotes were entirely on message.]
Protect your golden icons, drive cost from your business, promote, generate repeat sales against competitors, innovate, be transparent about what matters, and always look forward expressed in new products. Easy.
So what happened that a regulatory monopoly is now necessary? Is it just conceptional enemies or a self regulatory mobilization demanding relevance?
Lets look at the legacy and the internal and external markets that are served.
ELITES - This is the bonafide, artistic, critically acclaimed trend leaders whose work is expressed through limited, exclusive distribution. Master perfumers status and reputations are made using what nature, science and imagination can provide.
PREFERRED - These are avatars of the Elites, using more science and precision. Preferred products are intended to aspire, feed the frenzy, promote ubiquitous images/ memory and drive traffic to the dream. Supply is determined by privilege, give backs and performance.
OUTSIDERS - This is populated by technicians who satisfy real every day needs. Their art comes from existing available material sources, natural and synthetic, mid grade to technical qualities. Their products thrive in public health usages.
How will IFRA be effective serving these interests? Will they preserve the materials the Elites demand? Will IFRA's primary focus be on the EU Regulatory process and assign fiscal responsibilities in the global supply chain for the Preferred? IFRA already assumed January 1st the fragrance related regulatory functions and advisory initiatives of the European Flavour and Fragrance Association. Will IFRA personalize the transparency process for environmental science? Can IFRA inspire trust and leadership when prior self regulation tactics fostered a squeamishly incoherent anti-fragrance movement?
What is evident on the regulatory agenda are of course, educational forums. FMA just hosted a speech from Stats.org. RIFM will address this week how "Transparent Science Supports Brand Trust." And IFRA is grappling with population risk hazards vs quantitative assessments.
Upcoming in May will be a seminar hosted by EPA's DfE, and third party reviewers NSF, and ToxServices to guide Fragrance creators through the new DfE screen. This precedes the Sustainable Fragrances 2010 conference, which should be more progressive then 2009's program. Since the DfE screen should include environmental safety hazards, seminar attendance is critical, affordable and inexcusable.
[note: there have not been any press releases but excerpts from a recent interview in Perfumers & Flavorist magazine. I doubt the quotes were entirely on message.]
Thursday, January 21, 2010
Synthetic Fragrances and Essential Oils Improved Health and Environmental Criteria
Great news. The two year effort to develop environmental criteria coupled with human health data is now before the USA EPA management for internal review. Official comment is expected next month since the submission was accepted early December 2009. Be assured adherence to the criteria will provide a clear quick pathway to safe fragrances used in cleaning products.
Criteria details- The ETF (Environmental Task Force) which was organized by CleanGredients and EPA's Design for the Environment department, agreed to use specific screens based on the submitted criteria in the as-applied cleaning product for DfE's partners as follows:
1) the DfE General Screen for non-essential oil materials contained in confidential fragrance formulas at or above 0.01%
2) the High Capacity for Biodegradation Screen for essential oils or constituents there of at or above 0.01%
3) the EPI Suite Screen for fragrance materials present under 0.01%
The three screens will serve to drive data collection for higher volume-use fragrance materials and essential oils currently in the market place. This should resolve the data gaps needed for scientific relevance and policy.
Next steps- once EPA favorably responds there is general ETF agreement that two more months will be needed by the supply chain and suppliers to develop a response to their clients on the effect to existing and future formulas. Also, in order for the industry to maintain their current practices and trade secrets, a Trade group will need to build the data base for access. Currently IFRA has just published a list of all tested materials used in perfumery for all applications including cleaning products. Based on formula transparency concerns, IFRA's due paying members will be looking for further Board action.
As clear and easy the three screens will be to use and apply, there will remain complications regarding current market claims by the formulators. For example, playing on emotions and a different scientific basis, essential oils in cleaning products have been promoted with similar benefits as in personal care products. Aside from smelling nice, chemically, essential oils do harm the environment when rinsed down the drain. Technically, the grades that are affordable for cleaning products are not as refined to the safety standards used in Toiletries. There are no replacements for what Nature originally intended and evolved. This misdirection needs to be untangled as many companies "greened" their products with essential oils based on positive consumer cross product conditioning.
A Green Nose caution- the second screen, High Capacity for Biodegradation, was suggested by a special ETF sub-panel to screen perfume material that have little to no water solubility.The chemical make-up of the material still needs to pass other screens. This is not intended to be a dodge for an essential oil that is claimed to be a fixative or provide a physical benefit for a formula.
Criteria details- The ETF (Environmental Task Force) which was organized by CleanGredients and EPA's Design for the Environment department, agreed to use specific screens based on the submitted criteria in the as-applied cleaning product for DfE's partners as follows:
1) the DfE General Screen for non-essential oil materials contained in confidential fragrance formulas at or above 0.01%
2) the High Capacity for Biodegradation Screen for essential oils or constituents there of at or above 0.01%
3) the EPI Suite Screen for fragrance materials present under 0.01%
The three screens will serve to drive data collection for higher volume-use fragrance materials and essential oils currently in the market place. This should resolve the data gaps needed for scientific relevance and policy.
Next steps- once EPA favorably responds there is general ETF agreement that two more months will be needed by the supply chain and suppliers to develop a response to their clients on the effect to existing and future formulas. Also, in order for the industry to maintain their current practices and trade secrets, a Trade group will need to build the data base for access. Currently IFRA has just published a list of all tested materials used in perfumery for all applications including cleaning products. Based on formula transparency concerns, IFRA's due paying members will be looking for further Board action.
As clear and easy the three screens will be to use and apply, there will remain complications regarding current market claims by the formulators. For example, playing on emotions and a different scientific basis, essential oils in cleaning products have been promoted with similar benefits as in personal care products. Aside from smelling nice, chemically, essential oils do harm the environment when rinsed down the drain. Technically, the grades that are affordable for cleaning products are not as refined to the safety standards used in Toiletries. There are no replacements for what Nature originally intended and evolved. This misdirection needs to be untangled as many companies "greened" their products with essential oils based on positive consumer cross product conditioning.
A Green Nose caution- the second screen, High Capacity for Biodegradation, was suggested by a special ETF sub-panel to screen perfume material that have little to no water solubility.The chemical make-up of the material still needs to pass other screens. This is not intended to be a dodge for an essential oil that is claimed to be a fixative or provide a physical benefit for a formula.
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