The Association Enters a New Era
In March 1967, James H. Merritt, Stephen Mayham's successor, began his 16-year tenure as TGA president. At the time of the Mayham-Merritt transition, the Association moved its headquarters from New York City to Washington, D.C. to increase its effectiveness in influencing legislation.
Two years after the move, the Association formed a Public Relations Committee to "discuss industry-wide public relations activities." Later that year, the Committee made a "thorough study of the need for a name change for the Association."
In September 1970, after considering several alternatives, the Board approved the Association's current name, The Cosmetic, Toiletry, and Fragrance Association (CTFA), subject to membership approval.
Self-Regulatory Programs Established
As the Association entered the 1970s, consumer and environmental concerns captured the attention of legislators and the media.
CTFA found itself in a decade-long struggle to convince regulatory agencies and consumer groups that the industry's commitment to product safety and self-regulation precluded the need to introduce new legislation.
In 1970, President Nixon's Special Assistant for Consumer Affairs Virginia Knauer urged the cosmetic industry to support a voluntary reporting program. The call for such a program emerged at a time when ingredient labeling of finished products was not yet required and when both consumers and FDA voiced concern over the industry's lack of disclosure of ingredients, registration of manufacturers and reports of adverse reactions to products.
At a December 1970 meeting with CTFA, FDA staff stated that if the industry agreed to voluntarily provide this data, the agency would not seek to legislate such a program.
In 1971, the Association proposed this first-of-its-kind program. At that time, CTFA President Jim Merritt described the program as a "desirable and innovative example of industry cooperation with government to better consumer protection."
In light of the prevailing regulatory climate, CTFA's system of voluntary regulation was designed to demonstrate the industry's willingness to supply information to FDA and to discourage Congressional legislation.
Under the program, both member and nonmember companies voluntarily provide FDA with information concerning their operations. The program entails: (1) registration of manufacturing establishments; (2) submission of data on composition of finished products; and (3) annual filing of consumer product experiences, detailing the number of complaints received by participating companies.
Following closely on the heels of the Voluntary Reporting Program was the publication of the first edition of the Cosmetic Ingredient Dictionary in 1973. The Dictionary was the first authoritative source for commonly accepted names of cosmetic ingredients.
The Dictionary evolved out of an Association effort in 1970 to compile a list of chemicals used in cosmetics and toiletries. Working with representatives from FDA and the medical community, the CTFA Cosmetic Ingredient Nomenclature Committee researched existing nomenclature systems and developed comprehensive guidelines for consistency in name assignment.
The first edition of the Dictionary contained a listing of 5,000 trade and chemical names together with their CTFA adopted names, definitions, structures, Chemical Abstract Service Registry (CAS) Numbers and other information.
The work leading up to the first edition of the Cosmetic Ingredient Dictionary greatly facilitated the industry's compliance with ingredient labeling standards adopted by FDA under the Fair Packaging and Labeling Act in 1975.
FDA soon recognized the Cosmetic Ingredient Dictionary as the source for proper nomenclature for cosmetic ingredient labeling. Each successive edition of the Dictionary reflected the increasingly high demand for more sophisticated information.
In 1994, fifth edition contained more than 6,000 chemical names and was called the International Cosmetic Ingredient Dictionary. The Dictionary is recognized and sold all over the world, providing uniform names required for ingredient labeling in the United States, the European Union and many other countries.
The Eagleton Bill
In 1973, Missouri Senator Thomas F. Eagleton introduced a landmark bill that proposed sweeping changes to the federal oversight of the cosmetics industry. Eagleton's bill became the focus of CTFA activity for the next four years.
Specifically, the bill mandated: (1) pre-market clearance of cosmetics by FDA and the establishment of specific tests that the industry would be required to perform prior to marketing a product; (2) deletion of both the soap and hair dye exemptions of the 1938 Food, Drug, and Cosmetic Act; (3) mandatory registration of cosmetic products; (4) detailed ingredient labeling requirements; (5) compiling and maintaining consumer complaints; and (6) expanding FDA access to company records.
CTFA strongly opposed this attempt to remove the self-regulatory status of the cosmetic industry.
During hearings held by Senator Edward Kennedy of the Subcommittee on Health, CTFA Chairman Dick Edmondson testified that the bill would cause "a serious misallocation of the nation's scientific resources and disrupt congressionally established priorities for protecting public health—with unusually severe impact on small manu-facturers."
The convergence of the Eagleton legislation with the FDA's petition to require cosmetic labeling under the Fair Packaging and Labeling Act presented a dilemma for CTFA.
Not wanting to appear to oppose both the consumer's right to know with regard to ingredient labeling and the perceived pro-consumer provisions of the Eagleton bill, CTFA decided to work with FDA to develop a regulation on ingredient labeling that both sides could agree upon.
The regulation, issued in November 1975, included a provision requiring manufacturers to either substantiate the safety of their product or include a warning statement that the product's safety had not been determined.
Although the Eagleton bill ultimately passed the Senate in 1976, a House version of the bill was not considered.
The Origin of CIR
During the time of the Eagleton bill, the industry planned -another landmark self-regulatory program — the Cosmetic Ingredient Review (CIR).
CIR's origins can be traced to a proposed FDA program for the specification and toxicological examination of cosmetic ingredients. After reviewing it, the CTFA Scientific Advisory Committee drafted its proposal for a CTFA sponsored "Reasonably Expected As Safe" (REAS) ingredient evaluation program. The CTFA Board approved the concept in 1975, and the following year the program was named the Cosmetic Ingredient Review.
CIR was launched with the goal of bringing together worldwide published and unpublished data on the safety of cosmetic ingredients for review by an independent expert panel. Within five years of its founding, CIR reviewed 216 commonly used ingredients.
An elaborate set of procedures to govern CIR was developed to satisfy CTFA members, FDA and Congress. To achieve credibiliy, it was designed to be an open program.
The seven member Expert Panel consists of distinguished scientists from the disciplines of dermatology, pharmacology, chemistry and toxicology. The members are selected by a steering committee and publicly nominated by government agencies, industry and consumers.
CIR continues to be one of CTFA's success stories, winning praise from regulators as well as consumer groups for its efforts to ensure product safety. The industry recognizes that by participating in CIR and pooling safety information on cosmetic raw materials, it can minimize the enormous expense and inefficiency of duplicate safety testing.
Copyright © 2003 The Cosmetic, Toiletry, and Fragrance Association
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