From: Nancy Speer [nspeer@stcvcpa.com] Sent: Thursday, November 30, 2000 1:56 PM To: fdadockets@oc.fda.gov Subject: Docket Number: 99P-1340/CP 1 Date: November 30, 2000 Dockets Management Branch The Food and Drug Administration Department of Health and Human Services, Rm. 1-23 12420 Parklawn Dr. Rockville, MD 20857 Re: Docket Number: 99P-1340/CP 1 Petition the FDA Have Calvin Klein's Eternity eau de parfum declared "misbranded" Dear Sir or Madam: In May, 1999, the Environmental Health Network (EHN) submitted the above petition to have Calvin Klein's "Eternity eau de parfum" declared misbranded. I am writing because I fully support this petition and request that the FDA give it careful attention with regard to your regulations 21CFR Sec. 740.1, 21CFR Sec. 740.2, and 21CFR Sec. 740.10. Regulation 21CFR Sec. 740.10 specifically states: "Each ingredient used in a cosmetic product and each finished cosmetic product shall be adequately substantiated for safety prior to marketing. Any such ingredient or product whose safety is not adequately substantiated prior to marketing is misbranded unless it contains the following conspicuous statement on the principal display panel: "Warning--The safety of this product has not been determined." As the petition shows, "Eternity" contains toxic ingredients and ingredients whose safety have not been substantiated. There is no warning label on its packaging. We all have a right to know the status of safety testing of the ingredients in products such as "Eternity" so that we can protect ourselves and our families from toxic chemicals that may cause health problems. Most people are not aware that most fragrance materials have only limited safety testing. They wrongfully assume these products are safe to use in any setting and are surprised when people complain. Like tobacco smoke, the harmful chemicals currently used in these products may affect the health of many people, including: people with asthma, chemical sensitivities, chronic fatigue, and other environmental illnesses. Children are particularly vulnerable to toxic chemicals found in products purchased and used by their parents, caregivers and teachers. When I am exposed to fragrance products, such as "Eternity," When I am exposed to fragrance products I can experience any of the following symptoms based upon the chemical fragrance product I encounter: __anaphylaxis/shock __double vision __incoherence _X_nausea __anxiety, restlessness __ear pain __incontinence _X_nose bleeds __asthma __eczema __irritability _X_rashes __breathing difficulty _X_eyes, watery or dry _X_joint aches __seizures __bronchitis _X_fatigue _X_laryngitis _X_short-term mem. loss __can1/4t concentrate __flushing _X_lethargy _X_sinusitis __coughing _X_headaches _X_ swell in throat and face __sneezing __depression __heart beat irregularity __mood swings __sores, skin/mouth _X_disorientation __hives _X_muscle pain/weakness __swallowing difficulty _X_dizziness __hypertension __nasal congestion __tinnitus _X_other: 2 of my grandchildren are dealing with attention deficit disorder (one is also hyperactive) I am an organist and have had so much muscle problems and troubles with becoming disoriented from the chemical fragrance that I had to give up playing for a while until I found someone to help me with the muscle problems and a good allergist and ears, nose and throat man (who had to do major sinus surgery to open all of the passages that had almost closed). I am functioning again now and playing, but can easily become disabled from perfume. It also affects my voice, but the drawing of the muscles in the throat, legs, arms, neck, etc. is the most painful. Please listen to what we are trying to tell you. What will happen to my children and grandchildren if this is allowed to continue. Don't use us as guinea pigs. Please act on behalf of the millions of people who have suffered physical illness and injury resulting from fragrance exposure at work, at school and in social settings. These toxic chemicals act as powerful barriers to people disabled by asthma and chemical sensitivities. Toxic chemicals in fragrances have already ruined countless lives. Thank you. Sincerely, Nancy L. Speer 612 5th Way Pleasant Grove, Alabama 35127