Tuesday, June 15, 2010


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.

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