Health Canada asked about fragrances, so share your concerns!
Government consultations are sometimes so narrowly scoped that they miss important aspects. This happened when Health Canada asked about fragrances and asthma. Fragrance chemicals are added to many products, with the intention to improve the odour. Traditionally these were natural extracts, but today most are complex mixtures of synthetic chemicals. Asthma is well known to be triggered by fragrances, as are rashes, migraine headaches, and initiation and triggering of multiple chemical sensitivities. Given that ingredients in fragrances include endocrine disruptors and carcinogens, cancer is a significant concern.
PCN contributed to a joint response to the review of fragrances and asthma, available here. Since then, an extensive Canadian research paper described how volatile organic chemicals (VOCs) such as fragrance ingredients can affect many body systems, with a focus on neurological decline and multiple chemical sensitivities. These mechanisms are also relevant to cancer.
Health Canada welcomes your views, so share your concerns about effects of fragrances on health via email: email@example.com and copy your Member of Parliament, The Honourable Jean-Yves Duclos, Minister of Health, and The Honourable Steven Guilbeault, Minister of Environment and Climate Change Canada
Some points you can consider including:
- Fragrances should be reduced and eliminated, on the basis that potential ingredients can interfere with biological signalling, cause diverse toxic effects beyond asthma, such as sensitization, immune toxicities, endocrine disruption, neurotoxicity and contributing to cancer. These are airborne chemicals.
- Fragrances should be reduced and eliminated according to first principles of modern chemical regulation:
- Essentiality (e.g., fragrances do not improve the primary purposes of cleaning products or cosmetics); and
- A Climate Lens on high-volume petrochemical products with large greenhouse gas footprints from bitumen to bottle on the shelf. Fragrance chemicals themselves are also greenhouse gases.
- Fragrances should be avoidable, with fragrance-free products universally available rather than largely being more expensive, niche products. Options that are healthier because ingredients are omitted should not be a luxury. Affordable and preferred access to safer products could reduce health risks, as well as barriers to indoor spaces.
- The labelling loop-hole permitting masking agents (meant to deaden the sense of smell or obscure unpleasant odours) in “unscented” and “scent-free” products should be closed. (“Fragrance-free” products are not supposed to contain masking agents.)
- A climate tax or stronger actions should be taken to provide incentives to decrease these high-volume sources of easily preventable greenhouse gases.
Fragrances are high volume, big business.
Industry research states that the global fragrance and perfume market was US$42 billion in 2022, and is projected to increase to US$44 billion by 2026.
Fragrances are just for marketing.
Cleaning products, fabric softeners, cosmetics, personal care products, diapers, female hygiene products, wipes, toilet and tissue paper, and the ubiquitous hand sanitizers often contain fragrances. Fragrances do nothing for the primary purposes – to make things cleaner, contain excretions, or eradicate contagion. Indeed, there is often little difference between brands of these products apart from odour and branding, and of course the associated risks of adverse reactions (that can also worsen outcomes of infections).
Fragrances may include hazardous chemicals. A narrow focus on asthma leaves aside other health effects.
The International Fragrance Association (IFRA) publishes a “Transparency List” of over 3000 chemicals that might be in a formulation. This lists includes endocrine disrupting chemicals such as phthalates, potential carcinogens such as alkyl benzenes and naphthalene, synthetic musks that may also be endocrine disruptors and are toxic to aquatic life, and poorly characterized petroleum streams such as naphthas.
The Transparency List is of uncertain reliability. For example, we noted in our 2021 consultation response that the list included benzene (a known carcinogen). Interestingly, following this alert to Health Canada, benzene had been deleted by December 2021. We are unaware of any associated product recalls.
Ingredients of an individual fragrance mixture are unknown.
Fragrance mixtures contain a confidential selection from thousands of possible chemicals, so in effect the composition is unknown.
“Fragrance” chemicals are also used to mask unpleasant odours in products, such as rendered animal remains used in fabric softeners. Products labelled “unscented” or “scent-free” may contain these neurologically active substances, whereas “fragrance free” products are not supposed to contain “masking agents.” This distinction is a misleading loop-hole, and results in exposures to masking agents among those intentionally attempting to avoid them.
The origin of the “Transparency List” may be traced to pressure from occupational health groups, as well as “eco” labelling initiatives. Providing overwhelming, unhelpful information in this manner is sometimes termed “malicious compliance.”
Fragrances do not improve performance of scented products, and may be toxic and counter-productive.
At a minimum, fragrances in personal care products, cleaning agents, fabric softeners, and items and products placed even on babies’ permeable skin, are unnecessary. Worse, some ingredients are toxic. Indeed, “cleaners” that leave behind potentially harmful chemicals are arguably misnamed and counter-productive.
Fragrances have disproportionate impacts on women and workers.
Fragrances have long been occupational health, gender and social issues. Women tend to use a larger number of personal care products, and are also the predominant workers in nail care, hair styling and cosmetics sales, where products may be heavily scented as well as presenting other hazards, for example in nail and hair products. Cleaning personnel may also be highly exposed, both to fragrances and harmful antimicrobial chemicals.
In addition to asthma, workers may develop chemical intolerance, become dizzy, weak, fatigued, have difficulties thinking, develop cardiac and digestive problems, or have difficulties conceiving and carrying a healthy baby to full term, among numerous adverse health effects.
Fragrances pollute indoor and outdoor air, and leave a large climate footprint.
Commercial fragrances are complex cocktails added to everyday products. These chemicals contaminate the indoor air with volatile organic compounds (VOCs), and many are harmful to humans, non-humans, and the environment. Many locations such as federal and other workplaces and many health care facilities have scent-free policies. Fragrances are also significant contributors to urban emissions of organic chemicals.
In nature, airborne VOCs can carry essential signals.
Scents and pheromones help to attract pollinators to flowers, signal fertility to potential mates, mark territory, help in forming maternal/infant bonds, warn against potentially harmful substances such as rotten food and much more. Chemicals in modern commercial products may interfere with these important actions, and bear little if any similarity to historical practices.
Have your say!
An industry of this size, and their end users, hold sway. Health Canada and Environment and Climate Change Canada must hear from you!
Email your concerns to: firstname.lastname@example.org and copy your Member of Parliament, The Honourable Jean-Yves Duclos, Minister of Health, and The Honourable Steven Guilbeault, Minister of Environment and Climate Change Canada
Published by Prevent Cancer Now, December 2021.
For feedback and further information, please contact email@example.com