QRA Implementation

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Timetable for 40 th Amendment and Beyond
QRA Implementation Workshop
January 23, 2007
William Troy, Ph.D.
Chairman
IFRA Scientific Com.

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Pre-40th
• Historically, IFRA established an
effective date for new Amendments that
was
Immediate, for new creations
12 months for existing fragrances
• Based on the date of issuance of the
Amendment
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• As various elements of the process
were changed (e.g., customer
consultation, publication on website),
the effective dates became one month
and 13 months, following the
announcement, for new and existing
fragrances
• With the advent of the 40 th Amendment
it was clear that this timing would not be
practical
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Timing for 40th
• Product categories expanded from 2 to
more than 20 (with sub-categories)
• Company computer systems must be
modified
• Reporting formats must be modified
• Personnel training needs
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• Scientific Committee decided that an
exceptional period of
- 13 months for new creations, and
- 25 months for existing fragrances
would be adopted for this Amendment
• Therefore, the 4 materials with new
IFRA restrictions could continue to be
used in new creations for 13 months,
and in existing fragrances for 25 mo.
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42 nd Amendment
• Now that QRA has been implemented,
what about currently restricted
materials?
Currently, 50+ materials restricted
because of skin allergy
Additional materials, not currently
IFRA restricted
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• About half of 50+ have sufficient data to
perform the QRA assessment
• Taken together with the non-restricted
materials that have been assessed via
QRA, there is a total of 40-45 45 materials
awaiting IFRA action
• The approach to be taken has been
discussed, in depth, at the SC and at
the IFRA Joint Advisory Group (JAG)
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• The opinion is unanimous to include
these materials in the 42 nd Amendment,
to avoid dragging out product
reformulations over several years
• Because of the very large number of
materials, another exception will be
made for implementation timing
13 months new creations
25 months existing fragrances
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The Future
• The increased complexity of the IFRA
process, resulting from the QRA, and
the sharply increased numbers of
materials being restricted, have
prompted the question:
Shouldn’t t we make a permanent
change in the implementation time for
new Amendments?
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• A task force of the IFRA JAG studied
this question, and the IFRA Board was
also consulted
• It was recognized that, until all currently
restricted materials are subjected to the
QRA, Amendments will contain more
materials than usual
• Once these are dealt with, however, the
situation should return to normal
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• From a public credibility point of view,
the Board felt strongly that we cannot
afford to permanently lengthen the
amount of time allotted for product
reformulations, following the publication
of a new Amendment
• They did approve, however, the
extraordinary use of an extended time
period, when necessary
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• Therefore, the use of the 13/25 month
implementation periods will be retained
for most IFRA Amendments, with
exceptions being allowed on a case by
case basis
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