Fragrance Notes Issue 2, 2019 - Page 47

DEVELOPMENTS Fragrance Creators will continue to utilize a multi-pronged approach to advancing the approval of new chemicals, including follow-up with Assistant Administrator Alexandra Dunn, who leads the Office of Chemical Safety and Pollution Prevention (OCSPP). In June 2019, Fragrance Creators submitted comments to the EPA regarding the prioritization of HHCB (Galaxolide). Because of our existing relationship with OCSPP, we heard directly from leadership that our comments would be thoughtfully considered. In accordance with congressional intent, LCSA Modernization should promote safety, innovation, and sound science. intends to have its rulemaking ready for review by its Board in late 2020. VOC Activity: California Air Resource Board FDA Proposal: Assessing Safe Use Levels for Fragrance Allergens The California Air Resource Board (CARB) has broad statutory authority to adopt regulations to achieve the maximum feasible reduction in volatile organic compounds (VOCs) emitted by consumer products. In its 2016 Fragrance Survey and 2013-2015 Consumer Product Surveys, it is apparent that CARB makes a number of inaccurate and incomplete assumptions about fragrance. CARB has initiated a rulemaking to meet 2023 and 2031 goals. On July 10, Fragrance Creators presented to CARB. This presentation highlighted the importance and benefits of fragrance, how fragrances are made, and key assumptions that CARB should reconsider. Specifically, Fragrance Creators recommends that CARB use data that clarifies fragrance is not 100 percent VOC and that fragrance ingredients are far less reactive than CARB currently calculates. Fragrance Creators joined HCPA, PCPC, and ACI in technical presentations to CARB from July 10 – July 12. CARB indicated a desire to follow-up directly with Fragrance Creators in early August for additional insights. Fragrance Creators will continue to work closely with the CARB Task Force to participate in and shape the rulemaking process. The goal is that—by being a resource to CARB and supplying more complete data and narratives—the industry will influence CARB as it drafts its recommendations for reducing VOC emissions from consumer products. CARB Canada: CMP 3 The Environment and Climate Change Canada (ECCC) has drafted a comprehensive VOC regulation, similar to CARB. We are aware that ECCC would like to implement CARB standards, but, based on the draft released on July 6, 2019, ECCC does not yet align with CARB, particularly regarding exemptions. Feedback on ECCC’s draft is due September 19, 2019. Fragrance Creators has been communicating with CCSPA and HCPA and will be engaged in the rulemaking process. Per FDA’s request, Fragrance Creators is leading industry in dialogue with FDA on its upcoming efforts in quantifying the level of safe use of materials that have been identified by the EU as being fragrance allergens.  Fragrance Creators, joined by its members and representatives of RIFM and PCPC, held a second meeting with Dr. Linda Katz, Director of the Food and Drug Administration’s (FDA’s) Office of Cosmetics and Colors, and senior staff. As a result of the active engagement of Dr. Katz and her team, Fragrance Creators further developed its relationship with FDA; obtained clarity about FDA’s thinking and needs related to allergen communication; shared information about Fragrance Creators’ initiative to educate the public about fragrance, The Fragrance Conservatory; and facilitated further education about RIFM and QRA2. Fragrance Creators will continue to leverage opportunities to advocate for the correct interpretation of the QRA model, with the desired outcome of having a consistent way of evaluating the safe-use level of fragrance allergens. 2016, will address the remaining 1550 priority chemicals out of the original 4300 chemicals identified as priorities during the categorization. Fragrance Creators has been monitoring the evaluation of “musks” under CMP 3 since these chemicals are fragrances and/or fragrance ingredients. In July, the final screening assessment for the chemicals that fall under the “Musks” category was released. The final conclusion was that these substances are not harmful to human health or the environment, and no further action (restrictions, controls, etc.) will be implemented at this time. Canada: Hotlist The Cosmetic Ingredient Hotlist (Hotlist) is an administrative tool that Health Canada uses to communicate to manufacturers and others that certain substances may be prohibited or restricted for use in cosmetics. On July 1, Fragrance Creators submitted comments regarding Eucalyptus Oil (proposed new warning) and Dihydrocoumarin (proposed change from prohibition to restriction). Fragrance Creators will continue to engage and will inform the RSEC regarding any updates. FN Canada: CMP 3 The Chemicals Management Plan (CMP) is a Government of Canada initiative aimed at reducing the risks posed by chemicals to Canadians and their environment. The next phase of the CMP 3, launched in May Issue 2, 2019 | FRAGRANCENOTES.ORG | 47