top
Environmental
Health
Network

EHN [of California]
P.O. Box 1155
Larkspur, California, 94977-1155
www.ehnca.org

Support and Information Line
(SAIL) 415.541.5075

A 501 (c) (3) non profit agency.

top
Environmental Health Network of California
Filed a Citizens' Petition With the FDA, May 1999

EHN's petition 99P-1340 is still open and accepting letters. (November 2006)

1998: Phthalates found in perfume
Analysis of one perfume:
http://www.ehnca.org/FDApetition/analysis.htm
Compounds found in six perfumes
By John J. Manura:
http://www.sisweb.com/referenc/applnote/app-73i.htm
EHN's section on phthalates:
ehnlinx/p.htm#Phthalates


Are you experiencing fragrance sensitization?

Do you want meaningful health information about
the chemicals used to make modern fragrances?

Do you believe the FDA should inform the public concerning
adverse health effects experienced by fragrance users and others?
The FDA already has a public alert message on its books:
"Warning--The safety of this product has not been determined." (21 CFR 740.10)
The FDA should enforce it!

If you feel as we do, then WRITE your letter or note to your FDA
in support of Petition 99P-1340 today!
And, copy your representative and your senators.
E-mail FDA, referencing Docket Number 99P-1340
fdadockets@oc.fda.gov

Sample e-mail and letters
FDApetition/sampletr.htm

The fragrance industry is UNregulated and
further protected by trade secret laws
and fragmentation of the little government authority that is claimed.

FDA Petition 99P-1340
Analyses, Complementary, Contact Information and
Sample E-mail and letters
plus SNIFF, too

9/29/03: The FDA has officially begun "Preliminary scientific reviews of the petition."
Write your letter, email or fax to the FDA before it is too late.

CITIZENS' petition, Docket Number: 99P-1340, was filed on behalf of everyone who feels
We The People have a RIGHT TO KNOW about the superfluous toxins in our synthetic fragrances.

All YOU have to do is write to the FDA about your adverse reactions --
first-, second or thirdhand -- to synthetic scents. If you've yet to suffer adverse effects,
but just want effective labeling, please also write to the FDA. In any case you must
reference Docket Number: 99P-1340.

September 2003: EHN has no idea when the FDA will close the petition, but it may be
soon now. Please write your letter, note or email to the FDA as soon as possible
about your -- or your children's, or your elderly parents' -- negative reactions to
synthetic fragrances. Do not include social security numbers or other such identifying info.

The FDA has written to EHN stating that they have not closed this docket number,
and they are continuing to accept letters and supplemental materials. The FDA
contact information for this petition is in the middle part of this panel.

All letters supporting EHN's petition to require warning labels on fragrance products
must contain: Docket Number: 99P-1340.

The docket number identifies the FDA petition to declare Calvin Klein's Eternity eau
de parfum "misbranded." If the FDA rules favorably on this petition, then it stands to
reason that all synthetic scents released to market without substantiation of safety will
also have to carry the FDA's required warning label.
It is unlikely that the FDA will move on this topic UNLESS it hears from several hundred
thousand people. Remember the USDA and ORGANICS. Let the FDA hear from YOU
. . . and please, spread this information far and wide.

Analyses
FDApetition/bkgrinfo.htm#Analyses

Background information, including Cosmetic Handbook regulations

Petition Index

Product Label
FDApetition/eterbkpg.htm

Sample letter
FDApetition/sampletr.htm#Sample

   Letters to FDA and other information

   Letters of support appearing on EHN's site
FDApetition/letindex.htm

   Search the FDA's Daily Log for 99P-1340
   http://www.fda.gov/ohrms/dockets/dailys/dailys05.htm

   1,377 Comments received by the FDA
   as of May 9, 2003 -- letters by year
   FDApetition/letinfda.htm

Media Covering FDA Citizens' Petition 99P-1340


Select just one method of communication with the FDA.

    Please make sure your constituents realize that their comments are in
    the public docket, including their names and addresses. They may even
    be posted to the web. Also, please ask them to put the docket number in
    the subject line of their e-mails as this will help us file it in the proper docket.

    Thanks.

    Jennie Butler
    Director, Division of Dockets Management




YOUR letters or notes supporting 99P-1340 may be
e-mailed, faxed or mailed to the FDA, but please, choose just
one method to inform the FDA. You may write many times over.

Email Address -- fdadockets@oc.fda.gov
FAX Number -- 301.827.6870
Letters may be mailed to:
Division of Dockets Management
Food and Drug Administration
Department of Health and Human Services
5630 Fishers Lane, Room 1061
Rockville, MD 20852


Return to top


Correspondence from the FDA:

May 11, 1999: FDA's acknowledging letter (via The Wayback Machine) --
http://web.archive.org/web/20000901221329/ http://www.fda.gov/ohrms/dockets/dailys/051199/ack0001.pdf

November 30, 1999 -- EHN has been informed that the petition is OPEN and accepting
letters and documentation supporting your claims that synthetic fragrances
adversely affect your health, the health of your children, or the health of your elderly
parents. The FDA responded to EHN in a little over its required response time of
180 days from receipt of petition (May 11, 1999).

Inquiries as to FDA progress on EHN's petition:

Subject: Docket Number: 99P-1340
Date: Thu, 28 Sep 2000 14:09:32 -0400
At this time your petition is still open and is receiving comments.
Jennie Butler

January 2001 -- another check with FDA and the petition is still open. -- barb

February 2002 -- the petition is still open and accepting letters and documentation. -- barb

September 29, 2003 -- The FDA has officially begun "Preliminary scientific reviews of the petition."


October 24, 2003 -- Phthalates are added to California's Prop. 65 list of chemicals.

Phthalates were found in the analyses of the perfumes
that form the basis of EHN'sFDA Petition 99P-1340. (OEHHA:
http://www.oehha.ca.gov/prop65/CRNR_notices/list_changes/6Ddehpnot.html.)


With all the information recently made availab le on the reproductive toxicity of phthalates,
one hopes the FDA will keep our future generations in mind as they review the combinations of
toxic chemicals used to concoct fragrances we use on/in our bodies. The manufacture of
fragrances changed during the past 30 years from largely plants and animal essences to those
derived from petrochemicals. In the manufacture of fragrances, phthalates are commonly used to
make the scent last. (In the manufacture of plastics, phthalates are used to soften.)

While harmful effects of phthalates are gaining attention, they are not the only worrisome chemicals
commonly used to make our modern scents -- as indicated by analysis. One should also look at
the synthetic musks, which are found not only stored in mothers' breast tissue, but downstream
in mother's milk. Musks are also found quite literally downstream where they adversely affect
wildlife. And then, I'd like to see the coumarins thoroughly investigated. And, this, as the
saying goes, is the tip of the iceberg. There are 3,000 to 5,000 inadequately tested chemicals in the
industry's repertoire.

I believe that the nformation available on the chemicals used to synthesize modern fragrances,
plus record of the diseases and disabilities associated with fragrance sensitization at prmary and
secondary levels of contact, warrants -- at a bare minimum -- the FDA's required message:
"WARNING: The safety of this product has not been determined." Source: FDA
http://vm.cfsan.fda.gov/~dms/cos-206.html. -- barb




Caveat Emptor!

Complementary information:

Folks, I've put some of the information I've found to be most compelling here, in chronological
order. I'd like to hear the excuses for why our government agencies, charged with protecting
public health, have allowed the various facets of the chemical industry to continue using the
population as unwitting guinea pigs. I cannot help but feel the "revolving door" 'twixt and
'tween industry and government plays an interesting role, but one not helpful to public health. -- barb

  • 1977 . . . Doctoral Dissertation: THE COMPARATIVE RESPIRATORY
    IRRITATION POTENTIAL OF FOURTEEN FRAGRANCE RAW MATERIALS

    Unpublished report to RIFM. 1977 References: Troy W.R.
    (William Troy is gainfully employed by the fragrance industry.)
    Available for purchase through http://wwwlib.umi.com/dxweb/
    You'll be taken through three pages where you enter obvious info and click "continue."
    When you reach the search page, key in the order number 7720819.

  • Science. 1979 May 11;204(4393):633-5.
    Neurotoxic fragrance produces ceroid and myelin disease.
    Spencer PS, Sterman AB, Horoupian DS, Foulds MM.
    Acetyl ethyl tetramethyl tetralin (AETT), a component of soaps, deodorants, and
    cosmetics, produces hyperirritability and limb weakness in rats repeatedly exposed
    to the compound. Brain, spinal cord, and peripheral nerves are discolored blue, show
    progressive neuronal ceroid degeneration, and develop spectacular myelin bubbling.
    These neurotoxic properties of AETT provide the basis for industry's decision to withdraw
    the compound from consumer products. In addition, AETT offers the experimentalist a
    new probe to explore the etiology and pathogeneses of human ceroid and myelin diseases.
    PMID: 432669 [PubMed - indexed for MEDLINE]
    http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=PubMed&list_uids=432669&dopt=Abstract

  • Sept. 16, 1986 -- Neurotoxins: At Home and the Workplace
    (Report by the Committee on Science and Technology to the U.S. House of
    Representatives, Sept. 16, 1986) [Report 99-827]. A few excerpts are keyed in at
    ehnlinx/n.htm#Neurotoxins

  • Feb. 05, 1990: Neurotoxin Concerns, Controversy Escalate
    By Elizabeth Pennisi
    The Scientist 4[3]:1, Feb. 05, 1990
    "Scientists are realizing that substances in the environment
    can have devastating effects on the human nervous system"
    "... Those substances are everywhere: organic solvents
    in the workplace, chemicals in perfumes, pesticides used on
    lawns, natural and added chemicals in foods, or prescribed or
    illegal drugs. The brain is the body's kingpyn organ; yet,
    once damaged or destroyed, nerve cells cannot be replaced.
    Already, the congressional Office of Technology Assessment
    (OTA) estimates that the care and treatment of neurological
    disorders and accompanying loss of productivity can cost the
    U.S. as much as $300 billion a year. No one knows how much
    neurotoxins contribute to that cost. The longer we live, the
    more evident the damage, and the more burdened the health care
    system will become to people with behavioral, mental, and
    neurological problems. "The measure of the problem is huge,"
    says Spencer. {Peter Spencer, director and senior scientist at
    the Center for Research on Occupational and Environmental
    Toxicology at the Oregon Health Sciences University in Portland} ..."
    http://www.the-scientist.com/yr1990/feb/pennisi_p1_900205.html

    September 1994: MCS: A Sensitive Issue
    Environmental Health Perspectives, Volume 102, Number 9
    Perfume and effects are included in the discussion. -- barb
    http://ehp.niehs.nih.gov/docs/1994/102-9/focus1.html

    July 20, 1995: "Multiple Chemical Sensitivities (MCS):
    What It Is, What It Is Not, And How It Is Manifested"

    By Shelia Bastien, PhD; ©
    Contains information on perfumes. By the way, I went from increasing sensitization to
    perfumed products into MCS. I didn't go gently. I struggled for 20 years to educate, while trying
    to protect my health to the extent possible in a highly perfume polluted workplace -- barb

    " ... Claudia Miller points out that many of the patients often attribute the onset of
    their illness to specific exposures (Vol. 10) such as repeated exposures to
    solvents, chemical, pesticides in sick buildings, or combustion products.

    " Patients report more problems and greater difficulties indoors where air
    fresheners, perfumes, and cleaners are used and where there are such things
    as particle board and carpets which outgas. The outgassing releases VOC
    compounds (Toxicology and Industrial Health, page 257).

    " These patients are often funneled off to psychiatrists and psychologists by
    physicians who are not familiar with MCS. "From the patient's perspective,
    they have lost their health, their livelihood, their friends and sometimes even
    family. Individuals with professional careers are likely to view their cognitive
    difficulties as most disabling," Dr. Miller added. They are often mislabeled as
    malingerers or given a psychiatric diagnosis. ... "
    newreact/sbastien.htm

    January 1997 -- The National Institute of Environmental Health Sciences (NIEHS)
    Fragrance products and pesticides are recognized as Common Indoor Air Pollutants
    http://www.niehs.nih.gov/external/faq/indoor.htm

    March-April, 1998: "Acute toxic effects of fragrance products."
    By Rosalind C. Anderson, Julius H. Anderson, Anderson Laboratories
    Archives of Environmental Health
    http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=PubMed&list_uids=9577937&dopt=Abstract

    http://static.highbeam.com/a/archivesofenvironmentalhealth/march011998/acutetoxiceffectsoffragranceproducts/

    March 24, 1999 . . . Toledo Blade
    Synthetic musk linked to environmental risks
    BY MICHAEL WOODS; BLADE SCIENCE EDITOR

    [Excerpted]
    "ANAHEIM, Calif. - Synthetic fragrances used in perfumes, soaps, laundry detergents,
    fabric softeners, cosmetics, and scores of other consumer products have become a new
    and unexpected group of environmental contaminants, scientists said.

    "The chemicals are accumulating in human fat tissue, blood, breast milk, drinking water
    supplies, lakes and streams, fish and wildlife, and elsewhere in the environment,
    according to scientists interviewed here. They are presenting scientific reports at a
    national meeting of the American Chemical Society.

    " 'I think there is reason for public concern about possible effects of these fragrances,'
    said Dr. Sebastian Kevekordes of the University of Gottingen in Germany.

    "One compound, musk xylene, has carcinogenic, or cancer-causing, effects in laboratory
    mice, Dr. Kevekordes said. Another, musk ketone, damages genes in animal
    experiments and has other worrisome effects.

    "Many of the studies identifying synthetic musk compounds in human tissue and the
    environment have been done in Europe and Japan. Dr. Kevekordes said that synthetic
    musks are used just as widely, or more so, in the United States, where fragrances have
    been used even in trash bags and product packaging. ..."


    May 1999 -- EHN filed this Petition, 99P-1340, with FDA.
    Analyses of perfumes

    FDApetition/bkgrinfo.htm#Analyses

    Safe Notification and Information For Fragrances act (SNIFF)
    September 21, 2000 -- SNIFF (Safe Notification and Information For Fragrances act):
    Thanks to efforts of her constituent, Lynn Lawson, Rep. Jan Schakowsky (D IL)
    introduced SNIFF in the 106th Congress, 2d Session, bill number: H. R. 5238; Co-sponsor: Rep Shelley Berkley.

    May 22, 2001: SNIFF -- Reintroduced by Rep. Jan Schakowsky (D IL) for herself
    and Ms. Berkley in the 107th Congress, bill number: H. R. 1947; Co-sponsor:
    Rep Fattah, Chaka - 7/18/2001 [PA-2]

    September 14, 2001 -- Occupational Acute Anaphylactic Reaction to Assault by Perfume
    Spray in the Face
    by James E. Lessenger, MD, From a private practice.
    [J Am Board Fam Pract 14(2):137-140, 2001. Đ 2001 American Board of Family Practice]
    http://www.familypractice.com/references/referencesframe.htm?main=/journal/2001/v14.n02/1402.07/art-1402.07.htm

    2001 - 2003 . . . Date unknown, but based on work Janitorial Products Pollution
    Prevention Project,
    the US Department of the Interior has laid guidelines for "green"
    cleaning in its "Guidance and Training on Greening Your Janitorial Business,"
    CHAPTER 2: Traditional Versus "Green" Cleaning Products

      Excerpted from "Green products" --
    • "Must not contain any carcinogens, mutagens, or teratogens designated by federal law."
    • "Must not contain any ozone-depleting compounds, greenhouse gases, or substances
      that contribute to photochemical smog and poor indoor air quality." ... Also,
    • "Must not contain petrochemical-derived fragrances." [Emphasis added.]
    http://www.doi.gov/greening/sustain/trad.html

    Feb. 6, 2002 -- "Scents and sensitivities
    What to know before buying a Valentine's Day perfume"

    By Francesca Lyman; MSNBC CONTRIBUTOR
    And, I might add, Mother's Day or Father's Day perfume, et al. In this article, the industry
    admits it has begun the first study to test fragrances for effects upon inhalation and for
    systemic effects . . . as it also claims it always thoroughly tests before marketing. -- barb

    Mirrored by kind permission of Ms. Francesca Lyman and MSNBC
    FDApetition/flscents.htm

    Had been at: http://www.msnbc.com/news/702445.asp

    July 10, 2002 --Not Too Pretty
    A report on phthalates, including information about their effect on developing male
    fetuses.
    This is a MUST read. -- barb
    http://www.NotTooPretty.org

    Dec. 9, 2002 -- Sperm Damage Linked to Phthalate Used in Fragrances, New Study
    by Harvard Researchers Finds

    http://www.NotTooPretty.org/ms_en_spermdamage.htm

    Jan-Feb 2003 -- [US Access] Board to Undertake Project on Indoor
    Environmental Quality

    "The Access Board is an independent Federal agency devoted to accessibility for people
    with disabilities. "
    http://www.access-board.gov/news/Access%20Currents/Jan-Feb03.htm#Board
    Note: Tue, 8 Apr 2003 -- Contract with NIBS has been signed for the IEQ (Indoor
    Environmental Quality) project.

    Feb. 12, 2003 -- "What the nose knows"
    By Francesca Lyman; MSNBC CONTRIBUTOR
    Still available 9/4/03 . . . get it while you can! MSNBC removes articles after some months.If the
    entire story doesn't come up, click on "Print" and it should appear in a separate window. -- barb

    http://msnbc.msn.com/id/3076635/
    Also at:
    http://www.mindfully.org/Pesticide/2003/Nose-Knows12feb03.htm

    Mar-Apr 2003 -- Breathing Better: Action Plans Keep Asthma in Check
    By Michelle Meadows; U.S. Food and Drug Administration; FDA Consumer magazine
    "...Common asthma triggers include dust, pollen, cockroaches, cold air,
    smoke, and other strong odors, such as paint, cleaning fluids, perfume,
    hair spray, and powder.
    ..." [emphasis added]
    http://www.fda.gov/fdac/features/2003/203_asthma.html

    April 7, 2003 -- Health Care Without Harm's The Issue
    You'll be able to click out to information on Cleaners and Disinfectants, Fragrances, Pesticides
    and Resources. All worth printing out and sharing with your doctor and healthcare facilities,
    schools, workplaces, places of worship, government entities, etc. -- barb

    http://www.noharm.org/pesticidesCleaners/issue

    September 7, 2003 -- New York Times
    WHAT THEY WERE THINKING
    Julianna Martin, 25, Syracuse, N.Y., Aug. 24, 2003
    " 'I don't shop without my respirator on. I've got extreme hypersensitivity to everyday
    chemicals -- fragrance, perfume, shampoo, candles, cleaning products. It's hard to
    do anything.' ..."
    Story with picture: http://www.nytimes.com/2003/09/07/magazine/07WTWT.html

    Printer friendly: http://www.nytimes.com/2003/09/07/magazine/07WTWT.html?pagewanted=print&position=

    I hope Julianna Martin knows about EHN's petition 99P-1340 and takes the time to
    write to the FDA. -- barb


    December 2003: SNIFF -- We are awaiting re-introduction of this bill into the
    108th Congress; now it seems to be on hold for a bit longer. Follow its progress via
    THOMAS Legislative Information on the Internet at
    http://thomas.loc.gov/home/thomas.html
    or by information on EHN's site under SNIFF.

    2004

    February 19, 2004 (last update)
    Sources of Indoor Air Pollution - Organic Gases (Volatile Organic Compounds - VOCs)

    Excerpted:

      "Organic chemicals are widely used as ingredients in household products. Paints,
      varnishes, and wax all contain organic solvents, as do many cleaning, disinfecting,
      cosmetic, degreasing, and hobby products. Fuels are made up of organic chemicals.
      All of these products can release organic compounds while you are using them, and,
      to some degree, when they are stored.

      "EPA's Total Exposure Assessment Methodology (TEAM) studies found levels of about
      a dozen common organic pollutants to be 2 to 5 times higher inside homes than
      outside, regardless of whether the homes were located in rural or highly industrial areas.
      Additional TEAM studies indicate that while people are using products containing
      organic chemicals, they can expose themselves and others to very high pollutant levels,
      and elevated concentrations can persist in the air long after the activity is completed.

      "Sources
      "Household products including: paints, paint strippers, and other solvents; wood
      preservatives; aerosol sprays; cleansers and disinfectants; moth repellents and air
      fresheners; stored fuels and automotive products; hobby supplies; dry-cleaned clothing."
      http://www.epa.gov/iaq/voc.html
    The EPA mentions "cosmetic" in the first paragraph and "air fresheners" (what a misnomer that
    word is!) in the last paragraph, adroitly circumvented the word FRAGRANCE.
    Fragrances: the ubiquitous chemical pollutant affecting air, bodies of users and nonusers, land
    and water. Amazing how FRAGRANCE cannot say its name out loud. -- barb

    March 26, 2004 -- Environmental Working Group's Campaign for Safe Cosmetics
    Survey: Personal care products
    http://www.ewg.org/survey

    April 2004 -- Environmental Health Perspectives
    "Grand Rounds in Environmental Medicine: Information on MCS Needed"
    Excerpted from letter by Barb Wilkie in response to "Grand Rounds in Environmental
    Medicine: Cases from an Emerging Discipline,
    by Howard Hu (2003) [EHP]"

      " ... As Hu (2003) also noted, other factors are beginning to be accepted as
      environmental health hazards, such as cockroach allergen and violence.

      "Hu (2003) continues:

        " Some [Grand Rounds cases] pertain to illnesses arising from occupations that
        entail combinations of exposures that may have acted synergistically. Some arise
        out of new research on illnesses and exposures that had not previously been linked
        together, such as infant pulmonary hemorrhage/Stachybotrys mold and possible
        estuary-associated syndrome. Others explore illnesses that are still of uncertain
        etiology and biology, such as multiple chemical sensitivities.

      " I would be even more pleased if modern flavors and fragrances appeared in the list.

      I am often displeased to see articles in mainstream newspapers in which doctors advise
      patients with asthma to rid their homes of the "usual suspects"--cats, cockroaches,
      and dust and dust mites, sometimes including mouse feces and mold for good measure--
      without mentioning the potential harm that fragrance chemicals can cause for people
      with asthma or other diseases exacerbated by fragrance products. ..."
      http://ehp.niehs.nih.gov/docs/2004/112-5/correspondence.html



    April 2004 . . . AB 2025 (Chu) Remove Chemical Hazards from Cosmetics
    http://www.leginfo.ca.gov/pub/bill/asm/ab_2001-2050/ab_2025_bill_20040415_amended_asm.html

    Alas, withdrawn because Chairwoman of the Health Committee, Rebecca Cohn, refused support.

    If you wish to thank Assemblymember Chu for her efforts, and encourage her to revisit this much needed endeavor, please write to her via her contact page at http://democrats.assembly.ca.gov/members/a49/contacts.htm

    or by mail at:

    Capitol Office
    State Capitol
    P.O. Box 942849
    Sacramento, CA 94249-0049
    Phone: 916-319-2049
    FAX: 916-319-2149

    April 2004 -- Anderson Laboratories makes available a brochure in text format. "Perfumes and Asthma - donžt mix" was a collaborative effort by:
    Julius H. Anderson, M.D.Ph.D.(ALI);
    Betty Bridges, R.N.(FPIN);
    Lynn Lawson, M.A. (Chronic Fatigue Syndrome, Fibromyalgia,
    & Chemical Sensitivity Coalition of Chicago).
    Lawrence A Plumlee, M.D. (Chemical Sensitivity Disorders Association); and
    Barbara Wilkie (EHN).

    May 2004 -- Air-fresheners cause a stink
    Fears raised as plug-ins linked to cancer compounds.

    Mark Peplow Đ Nature News Service / Macmillan Magazines Ltd 2004
    "A potentially harmful smog can form inside homes through reactions between air-fresheners and ozone, say researchers at the US Environmental Protection Agency (EPA). The reactions generate formaldehyde, classed as a probable carcinogen, and related compounds that many experts believe are responsible for respiratory problems.

    "The researchers studied the reactions between ozone gas and fragrance molecules such as pinene and limonene, which are emitted by air-fresheners that plug into electrical outlets. Ozone, produced at ground level when vehicle exhaust emissions react with sunlight, is a common urban pollutant, and environmental bodies have set limits on outdoor levels of it. ..."
    A HREF="http://www.nature.com/nsu/nsu_pf/040503/040503-11.html">http://www.nature.com/nsu/nsu_pf/040503/040503-11.html


    June 2004 -- The Honorable Judy Chu
    P.O. Box 942849, Room 2148
    Sacramento, CA 94249-000
    California AB 2012 -- June 18, 2004; pending legislation
    The following quotes from letter of support by the National Environmental Trust.

      „AB 2012 for the first time requires full content disclosure of
      ingredients in common personal care products, giving California
      consumers the ability to make more informed choices about the
      cosmetics they purchase. The bill also prohibits the use of the
      hazardous coal tar and phthalates. „

    While AB 2012 doesnžt deal specifically with the topic of fragrance pollution, it does
    talk to phthalates, which are commonly added to fragrances to make the scent last.

      „Not only do women of child bearing age frequently use products
      containing such chemicals, they also transfer many of these chemicals
      across the placental cord to the developing fetus. „

    Alas, defeated in August 2004 because of strong chemical and fragrance industry pressure . . . and walking Democrats. -- barb June 14, 2004 -- Environmental Working Group's investigation: A safety assessment of
    ingredients in personal care products . . . Fragrances <
    A HREF="http://www.ewg.org/reports/skindeep/report/allergies.php">http://www.ewg.org/reports/skindeep/report/allergies.php

    "... Based on their experience in treating people sensitized to cosmetics, the American
    Academy of Dermatology recommends that sensitized patients use only fragrance-free
    products, and avoid all perfumes, colognes, after-shaves, fingernail care products,
    and hair spray (AAD 2000). ..." The Petition begins at
    http://www.ewg.org/reports/skindeep/petition/index.php

  • EWG files petition with FDA: SKIN DEEP -- June 4, 2004
    I'd add: . . . And BEYOND!, for these chemicals go into your body via absorption and
    inhalation.
    Fragrances adversely affect user and nonuser, who really is an nonconsenting
    secondhand user. -- barb

    http://www.ewg.org/reports/skindeep/report/executive_summary.php

    Printer friendly
    Return to top of page




    Over a thousand Comments received by the FDA about Docket 99P-1340 since it was accepted on May 11, 1999

    For letters appearing on EHN's site (with permission), please visit FDApetition/letindex.htm


    As of JMay 15, 2003, I've found a count of 114 ECs, 444 EMCs and 754 comments (C), at least five batches of form letters were sent in, but each batch counted as one entry (total count: 70; adjusted: 65). My calculations bring us to a total of 1377 comments via mail or electronic format sent to the FDA since May 1999 regarding Docket Number 99P -1340. Some people have granted permission to post their letters on EHN's site, and you'll find those by visiting FDApetition/letindex.htm.

    Compared with the USDA receiving over 200,000 letters regarding their planned manipulation of organic standards, 1353 letters seems a rather puny number. But if you take into account that it has been reported in the New York Times that 100 letters on a topic is a lot for the FDA to receive, 1353 letters is a large number. Just think, this petition, which has been ignored by most mainstream media, has generated letters averaging 436 letters A YEAR. And yet, the FDA believes the harmful effects suffered by people of all ages,races and genders as a result of the chemicals, including phthalates, coumarin and musks, used to concoct synthetic fragrances are "not considered a priority." ("Scents and sensitivities" by Francesca Lyman, 02/06/02, FDApetition/flscents.htm . . . formerly on MSNBC at http://www.msnbc.com/news/702445.asp.)

    It seems to follow that if our concern were something other than the harmful effects of synthetic scents, this many letters sent to the FDA would surely make it into the New York Times. It hasn't. Therefore, YOU must help us spread the word.

    Lest you think I'm exaggerating, take a moment to read "Time to Review Your Cosmetics, Under Bright Light," By JANE E. BRODY; May 22, 2001; PERSONAL HEALTH, New York Times
    http://www.nytimes.com/2001/05/22/health/22BROD.html

    In the article, Brody writes:

      " ... As of July 1997, the Food and Drug Administration reports on its new Web site (vm.cfsan.fda.gov/~dms/cos-toc.html), the agency had received about 100 reports of adverse reactions to products containing A.H.A. The reactions ranged from mild irritation and stinging to blistering and burns.

      "Although 100 reports may not sound like much, you can be sure they represent the very tip of a large iceberg since fewer than 1 percent of problems involving such over-the-counter products are ever reported to the agency. The agency estimates that it receives only one in 50 reports of cosmetic-related complaints made to the industry. ..."

    Remember the industry is NOT regulated by the FDA .. . it is self-regulated through its Cosmetic Ingredient Review (CIR). It states:

      The Cosmetic Ingredient Review (CIR) was established in 1976 by the Cosmetic, Toiletry & Fragrance Association (CTFA) with support of the U.S. Food & Drug Administration and the Consumer Federation of America. Although funded by CTFA, CIR and the review process are independent from CTFA and the cosmetics industry. The Cosmetic Ingredient Review thoroughly reviews and assesses the safety of ingredients used in cosmetics in an open, unbiased, and expert manner, and publishes the results in the open, peer-reviewed scientific literature.
      http://www.cir-safety.org/

    The analyses, which are part of the FDA Petition, suggest that not enough information is known about individual chemicals used to make fragrances. There is no indication that the industry thoroughly tests chemicals used individually, let alone as combined to manufacture a scent. The industry claims it has only begun to study fragrances for effects upon inhalation, yet these products are made to be inhaled (smelled).**

    I've yet to see results of industry studies of fragrances for neurotoxicity, yet that was the suggestion made by the National Academy of Sciences before the 99th Congress, way back in September 1986. And, where pray tell are the reports on studies of systemic or long-term effects of fragrance chemicals? Fragrances enter the body through inhalation, via absorption and enter the brain directly (ehnlinx/b.htm#Brain). Fragrance chemicals include known sensitizers and irritants, as well as known or suspected carcinogens, neurotoxins and teratogens. Some of the fragrance chemicals are known or suspected hormone disrupters, some bio-accumulate and some have synergistic effects. A common fragrance chemical is coumarin. What effect does this chemical, which quickly enters the body, have on developing embryos and fetuses? We know that pregnant women cannot use Coumarin for its anticoagulant properties during pregnancy, but does anyone give a hoot about Coumarin in perfume and its possible effects? (See Coumarin at ehnlinx/c.htm#Coumarin)

    To me, it seems to follow that if one recognizes the neurotoxicity properties of fragrance chemicals, then one would wonder about their effects on our infants and children. Do synthetic scents play a role in premature death and in the skyrocketing "unexplained" rates of ADD and Autism? It seems to me that until we look mighty closely at the chemicals -- and ALL of their effects -- which we find in our commonly used synthetically scented products, we cannot dismiss fragrances as benign. Until the industry and the FDA do their duty by the public, making certain that we have safe products prove safe for the youngest, the oldest and the already ill among us, we should take heed of that sage advice: Caveat Emptor!

    We need better information from the fragrance industry and an FDA interested in carrying out its mission to protect public health. Tell your friends and write your newspapers about this formal petition, which allows the pubic to speak its voice. If enough of us write, we will be heard. -- barb

      **Scents and sensitivities
      What to know before buying a Valentinežs Day perfume

      By Francesca Lyman; Feb. 6, 2002; MSNBC CONTRIBUTOR
      And, I might add, Mother's Day or Father's Day perfume, et al. In this article, the industry admits it has begun the first study to test fragrances for effects upon inhalation and for systemic effects . . . and it also claims it always thoroughly tests before marketing. I smell a hint of duplicity in the air. -- barb
      Mirrored through the kind permission of Ms. Francesca Lyman and MSNBC
      FDApetition/flscents.htm

      Formerly on MSNBC at
      http://www.msnbc.com/news/702445.asp

      You may be interested in also checking out,
      Letters logged on FDA's Daily Dockets
      FDApetition/letinfda.htm





    Covering the FDA Petition

    Newsletters, online magazines and online news covering petition

    • David Lawrence Dewey
      author/syndicated columnist

      • So You Smell Good Using Perfumes and Colognes
        However... You Could Be Giving Yourself Cancer and God Knows What Else!
        7-24-99

        Slowly scroll through this page and you'll learn a lot of valuable information.
        If you want to quickly get to the article on perfume and the FDA Petition,
        use your find command, keying in "Eternity." -- barb

        http://www.dldewey.com/chealth.htm

      • Colognes - Perfumes - Pesticides Are They Slowly Killing You?
        October 7th, 1999
        http://www.dldewey.com/perfume.htm

    • Environment News Service (ENS) 2002
      • Labeling Cosmetics May Help Prevent Cancers

        "CHICAGO, Illinois, August 15, 2002 (ENS) - It's a right to know issue. Women who are sensitive to chemicals should have the benefit of warning labels on their cosmetics identifying those chemicals, say six environmental groups and Samuel S. Epstein, M.D., chairman of the Cancer Prevention Coalition.

        "One of the groups, the Environmental Health Network of California, is petitioning the U.S. Food and Drug Administration asking for warning labels on cosmetics to identify allergens and hazardous substances contained in the hair spray, deodorant, nail polish and perfume that many women use every day. ..."
        http://ens-news.com/ens/aug2002/2002-08-15-01.asp

    • MSNBC
      Scents and sensitivities
      What to know before buying a Valentinežs Day perfume

      By Francesca Lyman; MSNBC CONTRIBUTOR; Feb. 6, 2002
      Mirrored through kind permission of Ms. Francesca Lyman and MSNBC
      FDApetition/flscents.htm

      Formerly on MSNBC at
      http://www.msnbc.com/news/702445.asp

    • The New Reactor; May-June 1999 issue; EHN's newsletter
      Available hard copy only, but of course, you are at the site of the petition online. -- barb
      newreact/ehnnr.html

    • WSFA
      Some say a popular perfume is a health danger!!
      Includes interview of Judith Sanderson, Teacher, Culver City High and this statement:
      "After contacting Calvin Klein for a response to the petition that the group filled with the FDA the company had this statement: "All of Calvin Klein's products meet or exceed the requirement of the Federal Public Food, Drug and Cosmetics Act."
      http://www.wsfa.com/Global/story.asp?s=58076

        Dr. Jacob Offenberger
        Quoted from Some say a popular perfume is a health danger!!, above:
        "Dr. Jacob Offenberger is an Allergist; 'No manufacturer would like to sell any product that has real toxins in it or real irritants in it because it won't sell.' Dr. Jacob Offenberger is spokesperson for the Asthma Foundation of America. "

        What? Dr. Offenberger hasn't heard of the tobacco industry? On his own website Dr. Offenberger states ...
        "The worst disease in the world is ignorance. Anything that can alleviate ignorance will contribute to the wellness of society." -Jacob Offenberger, MD. (Go to About Dr. Offenberger.)
        http://www.asthmadoc.com/

    Petition Press Releases
    • Perfume: Cupid's Arrow or Poison Dart?
      Released by EHN jointly with Dr. Epstein, Cancer Prevention Coalition; 2-7-00
      PressReleases/fragfda3.htm

    • Hundreds of Consumers Ask FDA to Put Warning Labels on
      ETERNITY Perfume -- EHN Finds Hazardous Chemicals in Designer Fragrance
      ; Aug. 18, 1999
      PressReleases/fragfda2.htm

    • WARNING ALL MOMS: TOXIC CHEMICALS FOUND IN DESIGNER FRAGRANCE; May 6, 1999
      PressReleases/fragmisb.htm

  • Summary of Regulatory Requirements for Labeling of Cosmetics Marketed in the United States
    http://vm.cfsan.fda.gov/~dms/cos-lab1.html#summary

  • Why Petition the FDA?
    Comments by Betty Bridges, RN and Barb Wilkie
    FDApetition/whyfda.htm

  • WRITE the FDA -- includes SAMPLE LETTER - contains contact information and sample letter. Letters do not have to be long. But, please, WRITE! Please print out this information and share with others who may not have online access. Thank you.
    FDApetition/sampletr.htm


    Note: EHN and Fragranced Products Information Network (FPIN)
    are mirroring the FDA petition. http://www.fpinva.org/petition99P1340.htm

    Also visit FPIN for well-researched information about fragrance chemicals.


    Caveat Emptor!
    Additional supporting information

    • 1986: The National Academy of Sciences targeted fragrances as one of the
      six categories of chemicals that should be given high priority for neurotoxicity testing.
      Neurotoxins: At Home and the Workplace (Report by the Committee on Science and
      Technology. U.S. House of Representatives, Sept. 16, 1986) [Report 99-827]
      ehnmsofs.htm#National

    • 1991 EPA report: Identification of Polar Volatile Organic Compounds in Consumer Products and Common Microenvironments
      Thanks to Jacki . . . -- barb
      http://www.ourlittleplace.com/epa.html

    • 1992 EPA report Polar Organic Compounds in Fragrances of Consumer Products, Final Report
      Thanks to Betty . . . -- barb
      http://www.ameliaww.com/fpin/fragrance_rti4948.htm

    • May 1999 EHN's Citizens' Petition of FDA
      EHN entreats the FDA to follow its regulations already in place to require warning labels on fragrance products released to market without adequate testing of the fragrances and the individual chemicals from which the fragrances are synthesized.
      This page:FDApetition/bkgrinfo.htm

      • Also, visit EHN's General Links, pages F and P and click out to info on
        fragrances and perfumes
        F - ehnlinx/f.htm

        P - ehnlinx/p.htm

    • July 2002 Not Too Pretty
      A report on phthalates, found through analysis, in fragrances and cosmetic products; includes information about phthalates effect on developing male fetuses.
      This is a MUST read. -- barb
      http://www.NotTooPretty.org

        Supporting groups:
      • Coming Clean
        "Coming Clean was formed in early January 2001 to take advantage of the
        tremendous public education opportunity provided by the PBS broadcast of
        Trade Secrets: A Moyers Report."
        http://www.comeclean.org/homecc.htm

      • EWG's (Environmental Working Group) Chemical Industry Archives
        http://chemicalindustryarchives.org/

      • Health Care Without Harm
        http://www.hcwh.org/

      • Science and Environmental Health Network
        "... SEHN is concerned with the wise application of science to the protection of the environment and public health. ..."
        http://www.sehn.org/


    • Adulterated cosmetics
      Search the United States Code - Office of the Law Revision Counsel
      Enter "21" in the title box and "361" in the section box and click search
      Then repeat, entering "362" in the section box to get to Sec. 361. Adulterated cosmetics
      http://uscode.house.gov/usc.htm

    • Around the World With Fragrance Sensitization
      A visit to EHN's International MCS links will give you a clue as to the breadth of
      this serious public health problem. Fragrance sensitization is taking its toll worldwide.-- barb

      ehnlinx/mcs.htm#International

    • Cancer Prevention Coalition
      http://www.preventcancer.com

    • Cancer Research America, Inc.
      http://www.CancerResearchAmerica.org/

    • Fragrance Products Information Network
      http://www.fpinva.org

    • The Fragrant Door
      Perfume blisters a classroom door. Sprayed by students who were not in the classes of this teacher. What does it do to those who absorb it through their skin or eyes? And what does it do to those of us who have to breathe it even though our doctors tell us: "AVOID FRAGRANCES!"? I know the answer to my own rhetorical question!!! It makes us mighty sick, too often with death-defying events. -- barb
      ehnhompg/doorjudy.htm

    • From Trade Secrets to Betty Bridges, RN
      MARCH 27, 2001: Link to site of Betty Bridges, RN from the
      Bill Moyers' special report:Trade Secrets
      Go to the drop down list and choose bathroom. Click on "fragrance," then read the info in the boxes and click out to Betty's site. Her new domain name is www.fpinva.org. -- barb
      http://www.pbs.org/tradesecrets/options/protecting.html

    • Healthy Communications - Health, Awareness and Harmony
      Shelley Kramer
      Public Health and Cancer Prevention Educator
      Los Angeles Director of the Cancer Prevention Coalition
      888 377 8877
      310 457 5176
      Fax 310 883 2082
      email: helthcom@aol.com
      http://www.healthy-communications.com/

    • Icons - Or a picture IS worth a thousand words!
      FDApetition/iconsfis.htm

    • Julia Kendall's Twenty Most Common Chemicals Found in Thirty-One Fragrance Products
      ehn20.htm

    • Perfumer's World
    • Phthalates found in May 1999 FDA Petition, Docket Number 99P - 1340
      ehnlinx/p.htm#Phthalates

    • Prevalence of fragrance use - marketing
      Check the rates of asthma for people of all ages who are African-American and Hispanic,
      and for children across all cultures. Do you see the increased use of synthetically scented
      products for personal care and/or cleaning and maintenance correlating with the skyrocketing
      rates of asthma? How is it our experts continue to tell us the increased rates of asthma are
      "unexplained" when they never look at this correlation? LOOK at the chemicals used to make
      synthetic scents and the increase in asthma and other chronic illness should not be too hard to fathom. -- b arb


      • African-American Women
        Business & Industry Database
        "Study finds African-American women as a group are more than twice as likely as
        women of other races to buy fragrances Original Title: Ethnic Fragrance Market
        Source: Chemical Marketing Reporter, VOL:251, ISS:22, PG:25, June 02, 1997.
        ISSN: 0090-0907 "
        http://chemweb.com/

      • Children
        12/2/00 -- Now there's proof positive that our children are being targeted by the fragrance industry. See Fragrance Foundation's Events for 2000-2001. Scroll down to March 2001.

        This site is set up in frames. It is likely to beam up on, "Holiday '99: Malicious Lies &
        Tantalizing Truths - The Fragrance Foundation and the New York Times invite you
        to the first meeting of the New Millennium," so click on "Back to Events" and then
        click on "Fragrance Foundation's Events for 2000-2001."

        By the way, if you ever have wondered why the truth about the toxicity of fragrances is
        notreadily available through the mainstream media, this should give you a clue: TheNY
        Times joined The Fragrance Foundation in hosting "Malicious Lies..."
        "Malicious Lies:" Are they referring to the advertising? The REAL truth is far from
        tantalizing.

        For the REAL TRUTH, visit the Citizens' Petition currently before the US FDA -- this page!

        The Fragrance Foundation writes, in its Think Tank 2000 Series:
        "The first Think Tank of the series, ėGetting/Keeping the Teen Market," was held on
        September 29 at the new Conference Centre at The Fragrance Foundation. . . ."

        The Spring/Summer 2001 Trends Forecast
        NEW YORK í "If a guy tells you, you smell good í you are definitely going to wear
        that fragrance again* said Sarah, a New York City teenager and one of the teen
        panelists. Sarah was one of 5 teenage panelists to share quite candid remarks
        about fragrance, their preferences, and how it is marketed to them at The
        Fragrance Foundation's bi-annual Spring/Summer 2001 Trends Forecast Seminar."
        http://www.fragrance.org/cgi/fetch_outer_events.cgi?thing=1831359

      • Hispanic Women
        "Business & Industry Database
        "Survey finds US Hispanic women spend 43% more on fragrance products and 27% more
        on makeup than the average American woman Original Title: COSMETICS MAKERS
        TARGETING HISPANIC MARKET Source: Miami Herald (FL), PG:N/A, March 03, 1997.
        ISSN: 0898-865X Document Type: Regional NewspaperPublication Country:
        United States Language: EnglishRecord Type: Fulltext, Abstract Word Count: 849"
        http://chemweb.com/


    • Safe Notification and Information for Fragrances Act (SNIFF)
      HR 1947 in 107th Congress-- Introduced in House May 22, 2001 by
      Ms. Schakowsky (for herself, and Ms. Berkley (D NV))
      ehnlinx/s.htm#SNIFF

    • "Scents and sensitivities
      What to know before buying a Valentinežs Day perfume"

      By Francesca Lyman; Feb. 6, 2002; MSNBC CONTRIBUTOR
      And, I might add, Mother's Day or Father's Day perfume, et al. In this article, the industry admits it has begun the first study to test fragrances for effects upon inhalation and for systemic effects . . . as it also claims it always thoroughly tests before marketing. -- barb
      Mirrored through kind permission of Ms. Francesca Lyman and MSNBC
      FDApetition/flscents.htm

      Formerly on MSNBC at
      http://www.msnbc.com/news/702445.asp

    • Janette D. Sherman, M.D.
      http://www.radiation.org/

        Books by Dr. Sherman:
        • Life's Delicate Balance - Causes and Prevention of Breast Cancer
          "[D]efines and documents known causes of breast cancer, and emphasizes the means of prevention.
          and
        • CHEMICAL EXPOSURE AND DISEASE - The Professional and Layperson1s Guide to Understanding Cause and Effect "Chemical Exposure and Disease is a must for all activists, whether lay or professional, who want to prevent disease. " http://www.janettesherman.org/order.html

        • Dr. Sherman's books also available from Safe2Use. -- barb
          http://www.safe2use.com/drsherman/about-author.htm

    • Sierra Club's 98.12.01 Excessive Use of Fragrance Products in Public Places
      Protect America's Environment: For Our Families, For Our Future
            Sierra Club's December 1998 Conservation Resolutions
      http://tamalpais.sierraclub.org/chapters/sanfranciscobay/policy/december1998.htm

    • Time to Review Your Cosmetics, Under Bright Light
      By JANE E. BRODY; May 22, 2001; PERSONAL HEALTH; New York Times
      http://www.nytimes.com/2001/05/22/health/22BROD.html

    • Toledo Blade A note from barb (11/29/99): There had been a link out to the Toledo Blade's coverage of the national meeting held by the American Chemical Society, March 1999. Unfortunately, this most informative article -- "Synthetic musk linked to environmental risks" -- has been removed and no amount of pleading has gotten the page back up. It can't be found in a search, either. We've been told by Blade staff to go to the public library to get that issue. Seems strange in that you can get other Michael Woods columns written earlier than this one. What goes on here?

      Michael Woods, BLADE SCIENCE EDITOR, wrote in part in:

      Synthetic musk linked to environmental risks
      "ANAHEIM, Calif. - Synthetic fragrances used in perfumes, soaps, laundry detergents, fabric softeners, cosmetics, and scores of other consumer products have become a new and unexpected group of environmental contaminants, scientists said.

      " The chemicals are accumulating in human fat tissue, blood, breast milk, drinking water supplies, lakes and streams, fish and wildlife, and elsewhere in the environment, according to scientists interviewed here. ..."
      http://www.toledoblade.com/

    • US Access Board
      Board Adopts Policy to Promote Fragrance-Free Environments
      Folks, this is so very important. Use it to help educate your recalcitrant employers. -- barb
      http://www.access-board.gov/news/fragrance.htm

    Now, after spending valuable time reviewing all that has been put here before you, please take another moment to inform the Consumer Products Safety Commission (CPSC) about the fragrances in cleaning and maintenance products and how they adveresely affect your health. The CPSC says it wants to hear from people regarding adverse reactions to fabric softeners, especially when on the ambient air. Remember, pesticides are also fragrance products -- scented so people don't object to inhaling those couple of chemicals they are allowed to learn about in labeling -- other, often more toxic chemicals are hidden by the misleading word, INERT, and, of course, in the added scent. See CPSC's Report Unsafe Products http://www.cpsc.gov/talk.html.

    As of 2004: I must add this caveat, based not only on my own personal experience, but comments I have received from others. When contacting the CPSC via phone, a common comment from CPSC is that your call is the FIRST they have heard of a complaint about fabric softeners.

    When they pull that on me I say: Back in 1992, when I first called you after learning of the harmful effects of fabric softeners that may have been true, but I doubt that I was the very first person to call then to complain about the polluting and sickening capabilities of fabric softeners, but now in __________ (fill in a year of your choice), that cannot be true. I alone have called any number of times down through the years and I've been led to believe that someone has always taken my information. Then their tune changes.

    So don't let the CPSC person to whom you speak get by with telling you the very same line that a company representative will tell you: "Oh, this is the first time we have received a complaint about our product." Lies, fibs, "a bigun," whatever you call it, it is mendacious whether given by the industry or the government agency charged with protecting public health. (That brings to mind Big Daddy's line that I love from Cat on a Hot Tin Roof: "Didn't you notice the powerful and obnoxious odor of mendacity in this room?"

    REMEMBER THE FDA! Write about adverse reactions AND about the absolute need for informative labeling. Reference Petition Docket Number 99P - 1340 and email fdadockets@oc.fda.gov

    Thanks, barb



  • Please write to the FDA in support of this petition.
    If you want your letter to appear on FPIN or EHN sites, please copy:
    Betty Bridges, FPIN, and EHN Advisory Board member
    Barbara Wilkie, EHN President 2000 - 2001, 2001 - 2002, 2002 - 2003

    Put FDA Letter in subject line. Thanks .

    To view a sample letters, visit:
    FDApetition/sampletr.htm#SAMPLE LETTER

    For letters appearing on EHN's site (with permission), please visit
    FDApetition/letindex.htm


    Return to top of this page:EHN Petitions the FDA


    This page is: http://www.ehnca.org/FDApetition/bkgrinfo.htm


    Return to EHN's General Links, page F (ehnlinx/f.htm)

    Return to EHN's homepage (http://www.ehnca.org)


    As with all organizations, EHN depends upon your contributions of time and energy,
    as well as your membership support. (http://www.ehnca.org/ehnhompg/membship.htm)


    http://www.ehnca.org/FDApetition/bkgrinfo.htm


    Installed 6/21/02

    The Environmental Health Network (EHN - www.ehnca.org) [of California] is a 501 (c) (3) non profit agency and offers support and information for the chemically injured. EHN brings you topics on this page that need your immediate attention The URL for EHN's homepage is http://www.ehnca.org/