1. Lecture by Dr. P. Cadby
on fragrances and scents
It becomes normal
practice that the scientific
committee invites experts to
give a presentation on an issue
of particular interest to the
committee. For the 3rd plenary
meeting, Dr. Peter Cadby was
invited to give a lecture on
industry views on the safety
aspects of fragrances and
scents with respect to
consumer's health including
toxicological,
dermato-(toxico)logical/allergenic
aspects etc.
The lecture was followed
by a discussion.
2. Adoption of the
Agenda
The agenda was adopted.
3. Rules of Procedure
This version of the
Rules of Procedure has been
discussed and adopted by the
Scientific Steering Committee.
The document was now presented
to the SCCNFP for comments.
However, the member were
reminded that it is the
Commission's intention to have
only one set of "Rules of
Procedure" applicable to all of
the 9 scientific committees. As
a result, it was decided not to
go into discussion during this
meeting but to send comments
directly to the secretariat for
discussion at a later date.
As regards the two
annexes to the document, namely
the Annual statement of
member's interest (annex 1) and
the Declaration concerning
confidentiality (annex 2), the
members were asked to complete
and to sign, if appropriate,
and to send it to the
secretariat.
4. Approval of the minutes
of the 2nd plenary meeting of
21 January 1998
The minutes were adopted
subject to the correction of
the typographical errors.
5. SCCNFP Specific Working
Parties
5.1 Alternatives to Animal
Testing & Dossier
In his report (Annex I),
the co-ordinator gave an
overview of the meetings held
since the 2nd plenary meeting
and of the issues discussed. He
mentioned that the WP met
several cosmetic industry
scientific experts to discuss
those aspects of alternative
methods for which possibilities
exist to conclude on the
replacement of animals or on
the reduction of the number of
animals in a short period of
time (before the year 2000).
The main areas of concern are :
eye irritation, in-vitro
photo-irritation, human skin
compatibility, percutaneous
absorption and skin
sensitisation.
Photo-toxicity : the
Co-ordinator mentioned that an
in-vitro methodology to
identify the photo-toxicity of
chemicals was defined and
validated. Depending on the
validity of the results
obtained and on the
availability of all the data,
the WP should be in a position
to conclude on this issue
during 1999.
Percutaneous absorption
: it is a general opinion that
early 1999, it should be
possible to conclude on some in
vitro methodologies as the
suitable or adequate procedures
to define the level of
percutaneous absorption of
cosmetic ingredients.
Human testing : the
SCCNFP is ready, upon request
from the Commission, to work on
a guideline on human testing
for skin irritation for the
evaluation of finished cosmetic
products.
A revision of some of
the annexes of the Notes of
Guidance has started as a
consequence of the
scientific and technical
progress made by industry, and
by the cosmetic industry in
particular.
A mandate for the SCCNFP
WP Alternatives to animal
testing' was drafted by DG III.
It states that the SCCNFP shall
act as a resource of technical
expertise to the European
Commission with regards to the
development of alternative
methods, to give pro-active
advice to the cosmetic industry
on research proposals or
on-going studies and, if
appropriate, to peer review
study data.
The mandate was
subsequently adopted by the
plenary meeting subject to the
correction of some
typographical errors.
5.2 Hair Dyes
In his report, the
co-ordinator gave an overview
of the meetings held since the
2nd plenary meeting and of the
issues discussed. Only one
meeting took place during which
a number of draft opinions were
discussed and sent to the
plenary meeting for adoption.
These draft opinion are
:
A18 :
1,5-Dihydroxynaphthalene - doc
n° XXIV/1285/97
This substance was given
a classification B by the SCC
in 1993. A further study on the
chromosome aberration on
mammalian cells grown in vitro
was required and performed.
Based on the data
presented, it was concluded
that A18 does not pose a health
hazard for the intended use and
at the dose level of 1% in hair
dye formulations, which
corresponds to 0.5% upon
application.
A classification 1 was
adopted.
B31 : Kardinalrot - doc
n° XXIV/1287/97, rev. 9/97
Based on the data
presented, it was concluded
that B31 does not pose a health
hazard for the intended use in
semipermanent hair tinting
products, colouring setting
lotions and permanent hair dye
formulations at the dose level
of 2.5% in semi-permanent and
1.25% in permanent
respectively.
A classification 1 was
adopted.
B49 :
1-Amino-2-nitro-4-(b
-hydroxyethyl)-amino-5-chloro-benzene
- doc n° XXIV/1288/97, rev.
9/97
This substance was given
a classification C by the SCC
in 1992. Adequate studies on
dermal absorption, skin- and
eye-irritation, sensitisation
and teratogenicity were
required.
Upon fulfilment of this
requirements, a classification
1 was adopted.
B52 : 1-Methoxy-2-(b
-hydroxyethyl)-amino-5-nitro-benzene
- doc n° XXIV/1289/97
A classification 1 was
adopted without further
remarks.
B58 :
1(-2-Hydroxyethyloxy)-3-methylamino-4-nitro-benzene
- doc n° XXIV/1290/97
A classification 1 was
adopted without further
remarks.
B66 :
1-Amino-3-methyl-4-(2-hydroxyethyl)-amino-6-nitrobenzene
- doc n° XXIV/1291/97
A classification 1 was
adopted without further
remarks.
B67 : 1-(b
-Aminoethylamino)4-(b
-hydroxyethyloxy)-2-nitrobenzene
- doc n° XXIV/1292/97
A classification 1 was
adopted without further
remarks.
B81 : 1,5-di-(b
-Hydroxyethylamino)-2-nitro-4-chloro-benzene
- doc n° XXIV/1293/97
A classification 1 was
adopted without further
remarks.
A21 : Hydroquinone
A draft opinion on
Hydroquinone as a skin
lightener was tabled. The draft
opinion stated that
hydroquinone should not be used
as a skin de-pigmentation agent
in cosmetic products due to its
observed clinical side effects.
This conclusion was endorsed by
the plenary meeting.
Consequently, hydroquinone, as
a skin lightener, was
classified 2a.
However, it was
concluded that the use of
hydroquinone as a hair dye
constituent needed further
investigation. A re-evaluation
of its NOAEL data will be done
and the margin of safety
re-established. Therefore, the
issue was re-addressed to the
WP Hair Dyes' with the request
to draft an opinion for the
next plenary meeting of 23
September 1998.
5.3 Inventory
In his report, the
Co-ordinator said that this
Working Party discussed the a
number of issues in order to
establish a suitable work
programme for the improvement
and updating of the present
version of the inventory.
On each of these issues,
namely on incorrect entries, on
common names of cosmetic
ingredients, on the correction
of the INCI names of
ethylhexyl- and
ampho-derivatives and on
nomenclature conventions of
botanicals, documents were
prepared. Each of these
documents was commented by the
co-ordinator, discussed, and
subsequently, adopted by the
plenary meeting. Meetings are
planned to discuss each of
these issues with
representatives of the industry
concerned.
A mandate for the SCCNFP
WP Inventory' was drafted by
DG III, which defines the
precise role of this Working
Party and the working
procedures to be followed for
improving and updating the EU
inventory. The documents was
commented by the co-ordinator,
discussed, and subsequently,
adopted by the plenary meeting.
5.4 Preservatives, Colorants
& Fragrances
In his report, the
Co-ordinator commented the
issues dealt with since the
last plenary meeting. Although
opinions on P71 and P91 has
been adopted, the committee was
asked to re-evaluate these two
substances as to recent
developments in the domain.
Specific questions were asked
to the cosmetic industry in
this respect and a
re-evaluation will start as
soon as the respective replies
are received.
Other pending issues are
the a - and b -hydroxy acids,
acrylamide and carbamide
peroxide. For each of these
items, dossiers were received
and conclusions are expected
later this year.
In response to the
growing concern over the issue,
the Working Party initiated its
work on the review of the
safety of fragrance materials.
With reference to the questions
asked, it was decided to start
with the labelling of all known
fragrance allergens on
cosmetics and with defining a
maximum concentration under
which the labelling of such a
fragrance might not be
required. A meeting with EFFA
to discuss their lists of
restricted and not-recommended
ingredients with a view to a
possible inclusion of these
ingredients in Annex II,
respectively III and to discuss
section 2 of the inventory is
planned.
The assistance of the
SCCNFP was requested over the
claim hypo-allergenic',
commonly used on cosmetic
products. The input of the
SCCNFP was requested as to
whether the claim is indeed
necessary, and if so, the
criteria to support it. A draft
statement on the issue was
produced in a sense that the
consumer might be mislead by
this term and that the use of
the term should be discouraged
in the description of cosmetic
products. The statement was
endorsed and adopted by the
plenary meeting.
* Musk's, nitro &
polycyclic state of the art
In 1996, the SCC adopted
an opinion on nitro musk's
saying that the available data
did not justify the assumption
that their use in cosmetic
products is safe. In 1997, the
SCC adopted an opinion on Musk
Moskene and Musk Tibetene which
lead to the inclusion of these
musk's in annex II of the
cosmetic directive.
During 1996 and 1997,
further safety data were
received on musk ketone and
xylene as well as on the
polycyclic musk's AHTN and
HHCB. The evaluation of these
submissions is still on-going.
However, and to conclude
on the musk issue, the
committee stated not to take
into consideration any safety
data on these 4 remaining
musk's received after September
30th 1998 for drafting its
scientific opinion.
* Draft opinion on P21 -
Benzylhemiformal, Boric acid,
borates and tetraborates
The adoption of these
opinions was postponed to the
next plenary meeting as it was
found that both files were not
in a state for discussion and
subsequent adoption.
5.5 UV Filters
The Co-ordinator
reported on what has been
discussed in the Working Party
since the previous plenary
meeting. He mentioned that the
WP identified three imported
issues on which work will start
in the near future. These
issues are the use of sun
screen formulations and its
relation with the risk of
melanoma. Particular interest
will be given to young children
in this respect. The second
issue is the question whether
all UV filters should be
compulsory assessed by the
committee prior to their
inclusion in a proper annex to
the directive. The third one is
a draft opinion or guidance on
the Sun Protection Factor.
Next, an historical
overview was given of work done
since the very beginning. A
list of compounds ever
submitted to the committee was
annexed to this overview. Some
of the compounds listed
appeared to have been abandoned
by industry in the sense that
the data submitted were scanty
and there appeared to be no
interest in generating further
information about them and
presenting it, with a view to
obtaining approval for the use
of these compounds in sunscreen
preparations. The importance of
these "abandoned' compounds
lies in the fact that the
directive states that the
ultraviolet filters listed in
Annex VII are those intended
for use in sunscreen
formulations. UV filters which
are used in other cosmetics
(e.g., hair preparations,
creams, etc.) are specifically
excluded from the scope of the
directive, so that any of these
compounds may perhaps be used
in cosmetics other than
sunscreen formulations. A
formal letter in this respect
will be sent to the industry
concerned.
Expert panel workshop :
The committee envisages
to organise an expert panel
workshop to address issues such
as the use of sunscreen
formulation or other sun
protection measures and their
relation to melanoma or other
(skin)diseases and/or to
address health risks in general
in relation to exposure to the
sun.
6. Report of the
Chairman
In his report, the
Chairman repeated what he asked
for while discussing the rules
of procedure earlier the
meeting, namely to send him or
the secretariat comments on
this document.
A document titled
Format and structure for the
opinions of the Scientific
Committees' was tabled. Also
this document was previously
presented to the SSC and
although it does not fit in
completely with way opinions
are presented by the SCCNFP, it
is an importing step in drawing
a common look for opinions of
the 9 committees. The Chairman
asked for reactions or comments
in view of a future discussion
on this item.
The Chairman reported as
well on the work done within
the Scientific Steering
Committee. He said that most of
the time was dedicated to the
BSE/TSE issue. Opinions were
adopted by the SSC on the
safety of tallow and gelatine,
which are of interest to this
committee as well.
Of interest of the
SCCNFP is also the on-going
work on exposure limits to
electromagnetic fields.
7. Any Other Business
No topics were dealt
with under this heading.
Attendance List
Present
Mr K. Andersen, Mr R.
Anton, Mr J-F. Doré, Mr P.
Elsner, Mr V. Kapoulas, Mr F.
Kemper, Mr N. Loprieno, Mr J.
Parra, Mr C.J. Powell, Mr T.
Sanner, Mr J. Vives Rego, Mr I.
White
External experts :
Mr P. Cadby, Mrs J.D.
Johansen, Mr D. O'Mahony
Commission :
Mr L. Bansil DG III, Mrs
M. Bernard DG III, Mr W. De
Klerck DG XXIV, Mr A. Van Elst
DG XXIV
Apologies :
Mr P. Blain, Mrs Y. De
Roeck-Holtzhauer, Mr B. Lina,
Mrs V. Rogiers
Annex I
Report of the
Co-ordinator of the WP
Alternatives to Animal Testing
& Dossier
Since our Second Plenary
Meeting of 20 January 1998, the
SWP has met 5 times (Feb.6,
March 5/6 and 24/25, April
20/21, May 12/13).
The mandate given to
SCCNFP specific working group
on alternative methods has been
discussed in two meetings and
it was adopted on March 5/6 as
a draft to be submitted to its
adoption by the plenary (DOC.
XXIV/XXXV/98). Briefly, the
mandate states that the SCCNFP
shall act as a resource of
technical expertise to the
European Commission with
regards to the development of
alternative methods; to give
pro-active advice to the
European Cosmetic Industry on
research proposal and on-going
studies; to offer, as
appropriate, peer review of
study data.
The SWP has met several
Cosmetic Industry's scientific
experts, COLIPA SCAAT
representatives expert
scientists in the field of
phototoxicity and statistics,
and the Director of ECVAM, to
discuss the problems of concern
giving priority to those
aspects of Alternative Methods
for which there is some
possibility in a short period
of time (before the year 2000)
to conclude on the replacement
or reduction of the number of
animals employed in the safety
testing of cosmetic ingredients
and products.
In the meantime, a
revision has stated on some of
the Annexes of the "Notes of
Guidance for Testing of
Cosmetic Ingredients for Their
Safety Evaluation" (DOC.
XXIV/1878/97) taking into
account the improvement in the
scientific progress, and the
technical progress in the
Cosmetic Industry, as stated in
the Introduction of the
Document (p.8).
The main areas of
concern of the SCAAT/COLIPA
(Steering Committee on
Alternatives to Animal Testing)
are:
(a) Eye Irritation, (b)
In Vitro Photoirritation (c)
Human Skin Compatibility (d)
Percutaneous Absorption (e)
Skin Sensitization; more than
60% of their efforts is
involved in these 5 fields.
The efforts made by
ECVAM during the last period of
time and at present, are on
some alternative toxicity
testing, such as:
(a) Eye Irritation, (b)
Skin Corrosivity, (c) Skin
Irritation, (d) Skin
Sensitization, (e)
Embryotoxicity/Teratogenicity,
(f) Phototoxicity.
The following
conclusions based on a series
of discussions with other
interested parties, can be made
at present by SWP, relatively
to only three areas.
Phototoxicity
This sector interests
all those cosmetic ingredients
which absorb UV light (See
Annex VII, Council Directive
76/768/EEC and European
Inventory: 96/335/ECC) and
might modify their molecule so
to present a toxicological
potential for consumers' health
(due to their acquired
reactivity to cell's component
and genetic material).
At present there are
neither Animal Models defined
in the OECD, nor EC Guidelines
for the evaluation of
phototoxic properties of
chemicals.
At the conclusion of two
intense research projects
developed by the EC-ECVAM and
the European Cosmetic Industry
(COLIPA) it has been possible
to define and validate and in
vitro methodology, the
so-called In Vitro
Phototoxicity 3T3 Cell Neutral
Red Uptake that is able to
correctly identify phototoxic
and non-phototoxic chemicals. A
statistical model for the
interpretation of results has
also been defined.
On the basis of these
results, DGXI and ECVAM have
signed a Statement on the
Scientific Validity of the 3T3
NRU PT Test (an In Vitro Test
for Phototoxic Potential) on 3
November 1997.
At the request if the
SCCNFP (formerly SCC) presented
in 1996 COLIPA has developed
and concluded a III Phase of
the research which applies this
in vitro methodology to the
testing of all those UV-filters
already approved by the
Cosmetic Directive (76/768/ECC,
Annex VII) on which an opinion
of safety has been expressed by
SCCNFP.
According to a letter of
COLIPA on 30 April 1998, the
Management Team of the Research
Project on Photoirritation
expects to finalise its
proposed paper for publication
by June 1998. The Management
Team proposes to meet with the
SCCNFP/SWP to discuss the
results of the special study on
UV-filters during its first
meeting after the summer
holiday period.
To be mentioned here,
that a Report on the results of
this special study has already
been presented to the meeting
of the ECVAM-ESAC at the end of
March (a specific study on UV
Filter Chemicals from Annex VII
of the EU Directive 76/768 in
the 3T3 NRU in vitro
Phototoxicity Test) and that a
draft OECD Guidelines for
Testing of Chemicals in vitro
3T3 NRU phototoxicity test is
being circulated since 19 march
1998.
Depending on the
validity of the results
obtained in this Special Study
on the UV Filters (Phase III)
and on the availability of all
data, the SWP is of the opinion
that it should be possible to
conclude on this area during
1999.
For another field of
Phototoxicity, namely the
Photomutagenicity, the SCCNFP
Notes of Guidance revised in
1990 indicated two in vitro
methodologies for testing the
photomutagenic potential of the
UV-filters.
Since 1990 cosmetic
industries have been applying
these two methods for the
evaluation of new UV-filters
under evaluation by the SCCNFP.
In all cases the opinion has
been positive, thus
demonstrating that a
co-operation between the
European Commission and the
Cosmetic Industry has proved
the safety of cosmetics.
Percutaneous absorption
The evaluation of the
percutaneous absorption of
cosmetic ingredients represents
a parameter of great relevance
for the safety assessor, when
requested to express his
opinion on the systemic
exposure dose of various
consumers to different cosmetic
ingredients. This value
provides an objective criteria
for defining the safety margin.
At present there are two
draft guidelines at the OECD
level since 1996: an in vivo
methodology, on animal models,
and an in vitro methodology, on
a tissue model. There are no
agreements at the international
level on those two draft
guidelines for the complexity
and difficulty of the
procedure, and on the lack of a
scientifically valid database.
COLIPA has presented to
the SWP all scientific and
technical information based on
the results of their continuous
experience on the use of in
vitro approach for evaluating
percutaneous absorption of
cosmetic ingredients, such as
UV-filters, Hair Dyes and
Preservatives: many of these
studies developed by Cosmetic
Industries have already been
evaluated in the last 5 years
by the SCCNFP when analysing
the toxicological dossiers
presented to the Commission.
At present COLIPA is
selecting and organizing the
scientific data to support a
series of few protocols already
developed for different
cosmetic ingredients: the data
will be presented later on this
year for a final discussion on
this area.
ECAVM has also developed
a Workshop on the percutaneous
absorption and is participating
in the present activity of
comparing in vitro vs. in vivo
results.
The SWP intends to
continue to develop contact
with the scientific and
technical experts from Cosmetic
Industry to define a common
basis of acceptance of a new in
vitro methodology. It is a
general opinion that at the end
of 1998 or at the beginning of
1999, it should be possible to
conclude on some in vitro
methodology(ies), as suitable
and adequate procedures for
defining the level of
percutaneous absorption of
cosmetic ingredients.
Human testing
The SCCNFP has already
declared since 1997 that the
purpose of experiments on
humans is to confirm findings
on safety and to verify the
acceptability and the efficacy
of cosmetic products
(XXIV/1814/97: XXIV/1878/97).
At present, there is no
Commission position on human
testing (XXIV/1285/98);
however, it is under
development an OECD Test
Guideline for use in tests with
Human Volunteers
(ENY/MC/CHEM/RD(98)1) which is
based on the Helsinki
Declaration. This states that
human testing conducted for
chemicals and consumer
products, must be associated
with minimal risk, as it is
conducted:
a) to confirm
non-clinical information;
b) to confirm that
exposure will not cause
significant harm;
c) in a controlled
fashion, that minimises subject
risk.
COLIPA has published a
Test Guideline for Assessment
of Skin Compatibility of
Cosmetic Finished products in
Man (Food and Chemical
Toxicology 34 (1996), 651-660)
and a Test Guideline for the
Assessment of Skin Tolerance of
Potentially Irritant Cosmetic
Ingredients in Man (Food and
Chemical Toxicology 35 (1997)
1099-1106).
ECVAM has organised a
Skin Irritation Task Force
which has published its first
Report in 1998 (ATLA 26, 1-17,
1998).
At present, there are no
validated alternative
methodologies for testing skin
irritation potential on an in
vitro or computer model
procedure.
The SWP has discussed
the scientific problems related
to the testing for skin
irritation by different methods
with some scientific experts
from Cosmetic Industries, and
has already planned a series of
presentation by experts on
Structure Activity Relationship
(SAR) and on Human Testing.
The SWP has already
prepared a draft "Guidelines on
the use of human volunteers in
the testing of potentially
cutaneous irritant cosmetic
ingredients" and a final draft
will be submitted to the
plenary of September 1998, for
its adoption.
It is clear that SWP
indicates that "the human
testing is only for
confirmation of situations
where no irreversible damaging
effects are to be expected for
the volunteers and where the
study goal is reasonably
achievable with a study
population of limited size.
This is true for the
confirmation of skin
tollerability (absence of
irritation) but not for eye
irritation, sensitization and
other toxicological events.
The SWP is ready, if
requested specifically by the
Commission, to work on a
Guideline of Human testing for
Skin Irritation for the
Evaluation of Finished Cosmetic
Products. The SWP has requested
an external /Pexpert (Dr.
P.MASSON) to prepare a report
on the EU Member Countries
legislation concerning the
ethical procedures for cosmetic
products and their ingredients
safety testing.
Revision and updating of
notes of guidance
(XXIV/1878/97)
Annex 7 (Microbiological
Quality of the Finished
Cosmetic Products) has been
submitted to an extensive
scientific and technical
revision, by discussing the
subject with experts from
COLIPA and Cosmetic Industries.
In particular, the
Microbiological Quality has
been analysed in relation to
the two specific categories of
cosmetics, namely: (a) Products
specifically intended for
children under 3 years of age,
eye area and mucous membranes,
and (b) Other Products.
The microbial
contamination limits have been
revised, in relation to the
number and the species of
contaminants.
The second area of
revision has interested the
challenge testing.
A draft document will be
submitted to the plenary of
September 1998, for its final
adoption.
Before concluding this
Report, the SWP "Alternatives
and Dossier" wishes to draw the
attention of the DGXXIV on the
difficulties of communication
between the SWP itself and
other Parties, especially the
ECVAM's Scientific Staff. The
SWP considers relevant the
confrontation and discussion
with other Commission Offices,
to speed up the timing of
knowledge and decision, to
avoid equivocal
misunderstanding, to improve
our scientific meetings, to
better serving the Commission
Services.
In the meantime, the SWP
requests the DGXXIV to improve
its relationship with other
Services of the Commission
interested in different actions
concerning the cosmetics, such
as legislation, efficacy
testing, safety testing,
training on safety evaluation,
in order to provide the SCCNFP
with all types of information
and co-operation programs which
may be of interest for its
activity in the field of
Alternative
Methods.