Fragrance allergens can present different levels of risk - so there is a need to gather and assess data to define and characterize allergens of specific concern.

  1. TASK II.1

    What do we mean by allergens of specific concern?

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  2. TASK II.2

    What should be discussed and researched within the risk assessment process?

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  3. TASK II.3

    Consideration on the use of elicitation thresholds for risk assessment

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II.1 - What do we mean by allergens of specific concern?

The need is to agree on criteria for the identification of a (fragrance) allergen, which would define how to identify a ‘significant risk to the general population’.

Industry, the dermatological community, and regulators will work together to find a common ground and understanding on how to integrate clinical, cosmetovigilance and exposure data into the risk assessment in order to produce an accurate definition of “allergens of specific concern”. For instance, different levels of concern may be defined:

In this respect there is a need to address questions related to the above definitions such as what defines a substance for which a risk assessment technique such as the QRA (based on avoidance of induction) is considered sufficient versus what defines an allergen for which other more restrictive measures need to be considered necessary.

II.2 - What should be discussed and researched within the risk assessment process?

Several areas of the risk assessment process require further refinement and understanding to allow their integration into a common methodology.

This need is particularly true for the exploitation of data that underline the definitions of fragrance allergens and allergens of specific concerns:

Use of toxicological data

This generally addresses primary prevention by attempting to identify safe exposure levels, which avoid the induction of skin sensitization. The QRA approach is clearly defined and published and is the basis of the existing IFRA Ingredient Standards on sensitization. However, there are still areas for further research and potential improvement (e.g. consideration of aggregate exposure). This is part of the fourth task.

Use of clinical data

Data from dermatology clinics is at the forefront of the identification of substances that cause allergy in the general population. However, dermatologists are not routinely included in the discussion on risk assessment. In addition to the interpretation of data, including dermatologists in active consideration of approaches to risk assessment will provide for a collaborative approach to establishing safe use conditions. The following aspects need to be considered in incorporating correctly use clinical data in the risk assessment process:

Use of Cosmetovigilance data

Cosmetovigilance data is an important source of information that is mostly held within consumer product companies, but can be used to identify emerging issues or substances of concern. The availability and quality of this data needs to be further explored to understand the potential usefulness of such data within this process. Consumer product companies could consider sharing data perhaps through a third party (to protect confidentiality), to enable a broad on-going use of sensitization incidence information to drive prioritization and decision making.

II.3 - Consideration on the use of elicitation thresholds for risk assessment

Discussion is needed on reliable protocols/measures to determine those thresholds and how far elicitation thresholds could be a relevant and reliable model for use in risk assessment. One focus should be comparing thresholds from ingredients with different potency, particularly weak sensitizers, the category that contains the majority of fragrance sensitizers.

The Research Institute for Fragrance Materials (RIFM)* is actively engaged in an elicitation threshold study for Eugenol, which could further inform these discussions. Insights from the already initiated Repeated Open Application Test (ROAT) with Oakmoss (containing atranol and chloroatranol) could also prove helpful.

We recommend that the appropriate use of elicitation thresholds for risk assessment be discussed and protocols/measures be agreed to determine them. The organization of a workshop of experts seems to be the best option to address the questions outlined above.


* The Research Institute for Fragrance Materials (RIFM) is a non-profit scientific institute founded by the Fragrance Industry in 1966 for the purpose of generating and evaluating safety data on fragrance ingredients. The scientific foundation of RIFM is built around its independent Expert Panel (REXPAN).

It is comprised of internationally known academic dermatologists, pathologists, toxicologists and environmental scientists, none of whom has any other connection to the fragrance industry, and whose work involves the safety evaluation of fragrance ingredients under conditions of intended use.

Additional expertise is provided by adjunct groups with knowledge in genetic toxicity, respiratory science, reproductive effects, environmental fate and epidemiology. The results of their evaluations are published in peer-reviewed scientific journals, and their decisions regarding restrictions of use are promulgated through the IFRA Standards.