|Vol 1 Issue 1 No 1|
The Independent Watchdog
for Endangered & Vulnerable
Natural Aromatic Products used
in the Aroma (Perfumes,
Flavours, Aromatherapy, Cosmetics),
Herbal, Traditional Medicine & Phytochemical Industries.
China Consumes Threatened Species Update cover page
The Tea tree oil Business - What They Didn't Tell You pages 2 - 6
Palm oil Production Threatens Orang-utans. Pages 5 -6
Minor Essential Oils – Who Will Defend Them? Pages 6 - 7
So Then: Who’s Afraid of Citronella Oil? Pages 7 - 12
China Consumes Threatened Species Update.
Alongside the news revealed in the latest WWF / Traffic Press Release (Sept 2005) that China is intending to re-open business in tiger parts for use in Traditional Chinese Medicine "based on farm-bred, captive animals", international enforcement seems to be stepping up a pace via a number of police raids, the latest (at the time of writing) reported in London (5th October 2005).
Native South China tigers now number less than 30 according to Chinese state media and with the Environmental Investigation Agency (EIA) estimating that "at least" one tiger is killed daily for its use in Traditional Chinese Medicine, the situation is now moving on for a number of tiger sub-species from Critically Endangered towards Extinction.
Such is the demand for tiger meat that a restaurant situated near to China's largest tiger breeding centre, the Hengdaohezi Siberian Tiger park, recently advertised a new dish as "Endangered Siberian tiger meat/bone " for a princely sum. The restaurant was raided and the meat seized, with the owner then claiming that it was in fact donkey meat spiked with tiger urine. The restaurant was swiftly shut down.
Whether donkey or tiger, this single example shows that tiger meat is worth advertising whether it be tiger or not, and it also shows that the demand is still very much there. Further, the 'endangered' status label is now being used as a marketing term by entrepreneurs eager to cash in on the ever-increasing rarity of tiger as a sought-after ingredient. How soon China will fully instigate it's plans to produce tiger parts for domestic markets is unclear, but there has been a steady rise in commercial tiger breeding centres in the country in the past few years. Chinas wildlife trading fever in Endangered Species doesn't seem to stop there, since having recently received a number of large mammals from Zimbabwe as part of an exchange programme, the Chinese authorities intend to send four of the last remaining Siberian tigers to Zimbabwe in return. The fact that the rare Siberian tigers are not likely to be placed in the cold, snow-covered habitat they need for their survival / procreation, seems to have been overlooked. "Zimbabwe and China in tiger deal" BBC News 15th Sept 2005 In the vast forests of Siberia, there is evidence that if left alone, this sub-species is showing healthy signs of thriving. The most recent survey (Winter 2004) counted approximately 334 to 417 adult tigers and 97 to 112 cubs. Handwerk B. (2005) "2nd Siberian Tigers Stable, According to Landmark Survey" National Geographic News June 16, 2005. Cropwatch is currently looking at monitoring / protection arrangements for tigers in such areas, away from China / India and will report soon.
The Tea tree oil Business - What They Didn't Tell You
Failed or dubious investment plantation schemes in Australia have been the subject of previous Cropwatch reports - here is another instance. The Australian Securities and Investment website at http://www.asic.gov.au/asic/asic_pub.nsf/byheadline/05-279+Court+bans+former+Heydon+Park+directors runs a story (15 Sept 2005) on senior staff from the Heydon Park Company who have been banned from managing corporations by the Federal Court in Sydney. The Court declared that Heydon Park's representations in promotional documents for a managed investment scheme for growing ginseng in Tasmania were ‘misleading and deceptive’. Cropwatch understands that Heydon Park also ran a major tea tree plantation investment scheme.
On a different tack, Cropwatch understands that Main Camp, one of the principle players in the Australian tea tree oil business, is to be sold to a forestry/agricultural organisation, which is thought unlikely to continue tea tree oil production. Movement of key Main Camp staff to Unifect International. Pty Ltd. probably means that Unifect will be hoping to capture much of Main Camp's former tea tree oil business. Meanwhile, the UK regulatory authorities continue their red-taped vendetta against small companies in Europe producing and using botanically-derived natural products across several fronts. The Biocides newsletter No. 24 at http://www.hse.gov.uk/biocides/factsheets/biofact24.pdf includes details of the impossibly high fees (£84,000 to £89,000 upfront) charged by the British Pesticides Unit for new active ingredients and reviews in the UK. The result of this "rich mans club" policy, of course, will be to drive small companies using these items to the wall, allowing larger Corporate companies to move in on their existing hard work and intellectual property rights. Cropwatch is already aware of cases where this has happened, and it is incredibly socially divisive for government institutions to discriminate against small companies with the imposition of fees of this magnitude. To return to the subject of tea tree oil, the deadline for Control of Pesticides Regulations Specific Information (COPR), 2nd and 3rd review regulations against COPR substances which have only been so far been identified, includes the following active substances below that are essential oils. Litsea cubeba oil, cedar oil (origin not specified), eucalyptus oil, rue oil, tea tree oil, palmarosa oil, cedarwood oil (sp. not specified), lavender oil, pennyroyal oil, citronella oil (type not specified), lemongrass oil (species not differentiated), neem, turpentine oil. Approval for these substances as biocides will expire on 31st Aug 2006.
Tea tree: Description & Definition. The term "Tea Tree" includes species of the genus Leptospermum and Melaleuca, the latter genus covering more than 200 species of the family Myrtaceae (Byrnes 1986). The most common and economically important member of the Melaleuca group is the fast-growing semi-tropical Melaleuca alternifolia (Maid. and Bet.) Cheel. Tea tree oil (TTO) refers to the volatile oil obtained by steam distillation of the leaves and growing tips of this tree (and, formerly, other spp. of Melaleuca). It is believed that annual production of tea tree oil approaches 1000 tons, although the total demand for the commodity may be five times in excess of this, according to one Chinese trader (Feng 2005). However other production estimates have been far more conservative, at 300-400 tons/annum (Davis 2003) and 300 tons/annum (Sanganeria 2005) respectively.
Australia – a selective TTO history. Its native habitat is restricted to the swamps and watercourses of the subtropical coastal region of S, growing best in° and 27°New South Wales in Australia between 32 high-rainfall areas, or low rainfall areas with irrigation. It is a small tree 5-7m, naturally forming impenetrable thickets, and being coppiced easily. As one travels from South to North of its natural habitat, so the leaf oil composition changes, being 1,8-cineole rich in the South, and high terpinen-4-ol, low 1,8-cineole in the North. Leaf oil content can range from 0.5 to 3.0%, but yield from traditional design water-distillation is 1%, unless a more modern still design is used. Tea trees grow extensively in the swamplands of New South Wales and Queensland. In these swampy areas, sprouting saplings are harvested 12-15 months from their tree stump sites following initial felling of the trees. The abandoning of Australian tea tree plantations after World War II was reversed by a healthy world demand for natural botanically active materials. In the 'Nineties when the growth of the Australian tea tree oil (TTO) industry was exceptional, from 1-2 tons per annum in 1980, to 8 tons in 1990, and to above 400 tons at the peak in 1998, and at an FOB price of A$ 40/Kg, this represented some A$16 mio. Further, at that time in the mid-late 'Nineties, annual outputs of over 1000 tons or more of TTO looked realisable. Plantations were funded on a prospectus investment basis – with potential investment sums dwarfing the A$16 mio turnover figure above, but the trading was to be marred by the effects of human greed and deception.
For those that may be unaware, it is worth reproducing some description of the previous near-collapse of the Australian TTO industry here-
The Great Tea Tree Oil Crash. O'Brien (2000) describes the encouraging of farmers in North Queensland to grow tea trees via government restructuring packages for other crops, after the collapse of the tobacco growing industry there. For established farmers with large plantations, the profitability might have looked reasonable, but as for establishing tea tree plantations on virgin land and maintaining it thereafter in a situation of increased TTO availability, it made little sense. Nevertheless, according to O'Brien, big corporate farms were established (TB: Main Camp, Bronson & Jacobs, G.R. Davis, Good Oil Plantations, Chapman, Thursday Plantations etc.) to take advantage of tax breaks - investors getting an immediate tax credit equal to the value of the investment. However over-production flooded the market with TTO and eventually forced a situation of selling forward product at below the actual production cost, leading to a crash amongst producers in 1998.
[Photo courtesy of Ian Southwell].
We can well remember these times, with oil salesmen cutting each others throats, and their own, in the process. One leading plantation (Oil Fields Ltd) which was ultimately aiming at developing clonal plants via a grant from Australian Tea Tree Management Ltd, aimed to give in excess of 400Kg oil/hectare/annum from planting up to 25,000 plants/hectare with terpinen-4-ol levels in the oil of >40% and a 1,8-cineole level of 0.5%. It had 22 million Melaleuca alternifolia clones in the ground at Pt. Macquarie, at the time of its going into receivership in October 1999 (see Burfield & Sheppard-Hanger 2000). According to another report (Anon 2000) the tax-driven research scheme for the promotion of tea tree applications [Budplan 1-7] attracted some $600 million of investors money over 4 years, but it was wrecked when the research institute carrying the research work, the Australian Tea Tree Research Institute, was liquidated owing a $137 million tax bill it could not pay. A full descriptive account of $340 million in research fees paid to the Institute for research in specific areas of tea tree applications (deodorants, hair care, skincare) is available in the article – these costs for basic products were well hyped-up and the residual money disappeared off-shore. AAP General News (2002) reported that the Australian Tax Office disallowed tax deductions of the 40,000 people who invested in Budplan (the scheme involved the potential manufacture and sale of tea tree oil products for acne, oral hygiene and antiseptics) and other such schemes, saying some arrangements did not satisfy the tests of the general deduction provisions and also fell foul of the anti-avoidance provisions of the Tax Act. The London papers subsequently described the incident as the biggest share scandal ever And yet, somewhat incredulously, the essential oils company owner John Fergeus chose to write an article "talking the market up" in the trade journal Perfumer and Flavourist shortly afterwards, entitled "What will be the next big oil from Australia?" Elapsed time since the tea tree crash has shown that, arguably, there hasn't actually been one – in spite of extensive marketing campaigns by Australian oil producers. Items such as Rosalina oil (Melaleuca ericifolia Smith) once billed as a more pleasantly-odoured successor to tea tree oil, the pleasantly citrus smelling Backhousia citriodora oil, and the 'oil' (read: extract) of Australian Sandalwood Santulum spicatum have all largely failed to find their own significant market niche, in the same way that tea tree oil previously caught the imagination of the natural medicines market.
China. China has been producing tea tree oil for several years from imported Australian plants. Chunmao (2005) reports on the developing tea tree oil industry in Guangxi Province in the South of China which is largely due to the efforts of the Guangxi Forestry Research Institute (GFRI) in selecting and breeding suitable tea tree plant clones, and confirms that the annual production of TTO in Guangxi is now in the order of 60-80 tons per annum, of which 40-50 tons is high quality oil (40-50% terpinen-4-ol; < 3% 1,8-cineol). Chunmao states that 200-300 ha of land are under reforestation in Guangxi, and predicts that China will capture a sizeable share of the market from Australia, through lower selling costs. The above article includes interesting plant detail for the distillation of tea tree oil including multiple stages for the re-distillation of the condensate, to strip it more thoroughly of dissolved aqueous components (such as small amounts of terpinen-4-ol). This ensures that the final effluent discharged to the environment is very low in dissolved components, thereby reducing pollution.
Burfield T. & Sheppard –Hanger S. (2000) “Super Clone 88: Melaleuca alternifolia: What is its Value?” Paper given at 1st International Phyto-Aromatic Conference, Nice, France (Mar 2000).
Byrnes N.B. (1986) “A revision of Melaleuca L. (Myrtaceae) in northern and eastern Australia. Part 1, 1, and 65-76; Part 2, 2, 131-146; Part 3, 3, 254-273.
Chunmao H. (2005) “The Developing Tea Tree Oil Industry in Guangxi Province, P.R. China.” Perf & Flav. 30(7), 14-19.
Davis R.L. (2003) “The Australian Tea Tree Industry” in The Proceedings of the IFEAT International Conference ‘Australia and New Zealand: Essential Oils and Aroma Chemicals – Production and Marke s’ Sydney, Australia Nov 2003 pp29-40. London IFEAT (2003).
Feng, Shi Bing (2005) Personal communication with the author.
Fergeus J. (2000) “What will be the next big oil from Australia?” Perf. & Flav. Vol 25 p8 -18.
O’Brien, K. (2000) “Why Did the Tea Tree Industry Bust?” ABC News transcript 13.6.2000.
Sanganeria S. (2005) “Vibrant India” Perf & Flav. 30(7), 14-19. ▌
Palm oil Production Threatens Orang-utans.
Palm oil from the pericarp of Elaeis guineensis Jacq. is used across many retailed products from soap to candles, but the term palm oil usually refers to the kernel oil which is used in cosmetics & foodstuffs (e.g. from lipstick to margarine). Palm oils from the pericarp contains mainly palmitic, oleic and linoeic esters, whereas palm kernel oil contains mainly myristic and lauric acid esters.
There can be few who missed the UK newspaper’s stories in early October 2005 reporting on a Friends of the Earth collaborative report (see “The Oil for Ape Scandal” www.palmoil.org.uk ) detailing that 1 in 10 supermarket products contain palm oil are sourced indiscriminately from destructive origins. As well as directly threatening Orang-utan populations, harvested palm oil also threatens over 1000 other rainforest species, and has involved human rights violations, according to the report, which is the result of collaboration between Orang-utan Conservation Groups and Friends of the Earth. The report indicates that tens of thousands of Orang-utan have been wiped out due to loss of habitat, and quotes Indonesian newspaper reports which describe a ‘palm-oil fence’ some 845 km. long which is being formed along the border between Indonesia and Malaysia in Borneo - crossing directly through the Orang-utan habitat. The report further indicates that the establishment of oil-palm plantations has been responsible for 87% of the deforestation in Malaysia between 1985 and 2000.
Given this background, it seems strange that the July 2005 Society of Cosmetics Scientists Singapore (SCSS) outing was - to where exactly? - err ….. to NatOleo: the Naturals Oleochemical Palm Oil plant in Johor, Malaysia. The visit which is featured in IFSCC Magazine: ‘the Global Publication of the International Federation of Cosmetic Scientists’, reportedly included a visit to a 1200 hectare Palm Oil Plantation and a crude Palm oil mill (Lumain 2005). The article also discusses plans for expansion of the business so that NatOleo may become the largest oleochemical producer in Malaysia. Friends of the Earth in a separate report (FoE 2005) reveals that a high number of environmental pollution (air/water) contraventions were made by 68 of the Palm oil mills in Johor.
Cropwatch invites the SCSS/IFSCC to comment on why they are apparently giving endorsement and what amounts to 2 pages of free promotional magazine space to an industry which collectively has a record of massive environmental damage to the Malaysian forests, or in contrast, to outline why NatOleo’s policies are being environmentally correct (sustainability issues are not mentioned in the article). Unilever have produced a guidance document on ‘Sustainable Palm oil – Good Agricultural Practice Guidelines’ at 184.108.40.206/docs/InteractivePalmOilSAP2.pdf which includes a sub-section on biodiversity policy thus: “Enhance the farm environment for locally important, rare or endangered species by providing appropriate habitats and adopting the right cultural practices.” Wakker et al. (2005) have already reported on UK Palm oil customers who turn ‘a blind eye’ to the situation outlined above. Hopefully this won’t turn out to include global cosmetic scientific societies too.
FoE (2005): see http://www.foe.co.uk/resource/reports/greasy_palms_impacts.pdf
Lumain M. “SCSS - Outing to a Palm Oil Plantation” IFSCC Magazine 8(3), 234-235.
Wakker E. (2005) [of AIDEnvironment, in collaboration with Sawit Watch Indonesia and Joanna de Rozario on behalf of Friends of the Earth England, Wales and Northern Ireland]. “Greasy Palms – the social and ecological impacts of large-scale palm oil plantation development in SE Asia.” pub. FoE Jan. 2005.
All Text, Articles ©
Cropwatch or authors name/s where stated.
Minor Essential Oils – Who Will Defend Them?
Legislators dealing with botanically-derived natural products are generally only concerned with their use as active ingredients in current use within disclosed product formulations. Defending natural ingredients on toxicological grounds, providing test data and information to educate legislators is an expensive business. We therefore are tending to end up with a selection of heavily used ingredients on positive lists, and all the more minor products are steadily having to be abandoned on economic grounds.
IFRA polls its membership from time to time on their use of individual fragrance ingredients. The membership of IFRA is inclined towards the heavyweights of the fragrance world, and many of these companies themselves have their own restrictive & limited lists of raw materials. And so it comes as no surprise that IFRA probably cannot afford to provide data to members & expert committees on toxicology etc. on all aromatic materials. The latest causality appears to be an IFRA ban through non-support for cotton lavender Santolina chamaecyparissus L. commonly known as Santolina oil.
You may be familiar with S chamaecyparissus var. nana which is commonly grown in gardens for its silver aromatic foliage and yellow button-like blooms. The steam distilled oil is been produced in France (Bérard 1989) & Spain – Lawrence (1997) estimated annual production of the oil at 300Kg/annum . The herbs’ uses for scenting clothes against moths and as an insect repellent etc. can be traced back to the Victorians. It has been investigated recently for its possible use in controlling candidasis: Suresh et al. (1997), but the oil has long been used warilly, not the least because of its artemisia ketone content (to 45%).
You can imagine what this situation of continuing and progressive natural ingredient restriction is doing to the craft of perfumery – the ‘craft’ as such really doesn’t exist any longer except as sophisticated imagery perfume advertisers hype. Perfumers themselves have long ceased to be influential in their own industry, having been elbowed out of the way by lawyers, accountants, commercial managers and salespeople, so that few perfumers now sit on the boards of the major aroma concerns, having been banished to the back rooms. Professional perfumer’s societies busy themselves with organising annual dinners & dances, and golf days, but don’t seem interested in taking to the streets to protest about what is happening to the basic ingredients of their trade. To protest and make a fuss might rebound on you professionally, and may possibly affect your pension, after all…
In contrast to the restrictions and the limited manoeuvring opportunities for creation in Corporate perfumery, many artisan perfumers and small cottage fragrance businesses are currently emerging, with their entrepreneurs having little knowledge of-, or really even very much interest in-, restrictive legislation. Hopefully this sector will continue to grow and develop, oblivious to these senseless restrictions. After all, a spell of anarchy and non-adherence to restrictive laws which are difficult to respect may be the only way that the former spirited craft of creative perfumery can be rekindled and continue to live on.
B. Demirci, T. Özek, K.H.C.Baser (1998) “The Chemical Composition of Santolina chamaecyparissus L. Essential Oil.” New Trends and Methods in Natural Products’ Research, Proceedings of XII. International Symposium on Plant Originated Crude Drugs, 20-22 May 1998, Ankara, Turkey, eds. I.Çalis, T.Ersöz, A.A.Basaran, p 84-87 (2000).
Bérard D. “La Santoline: une nouvelle plante à parfum?” Parfums, Cosmétiques, Arômes No. 90 Dec 1989-Jan 1990 p83.
Lawrence B.M. (1993) “A planning scheme to evaluate new aromatic plants for the flavor and fragrance industries.” p. 620-627. In: J. Janick and J.E. Simon (eds.), New crops. Wiley, New York.
Suresh B., Sriram S., Dhanaraj SA., Elango K., Chinnaswamy K. (1997) “Anticandidal activity of Santolina chamaecyparissus volatile oil.” J Ethnopharmacol. 55(2),151-9.
So Then: Who’s Afraid of Citronella Oil?
UK: The Royal Commission on Environmental Pollution has expressed concern about possible dangers to the public from exposure to drift from crop spraying (Oct. 2005), asking for further research to be done and heavily criticised the Advisory Committee on Pesticides (ACP) who have consistently maintained that there is no risk attached to the public from crop spraying. The Commission recommend 5m. buffer zones between the spraying area and anyone who lived or worked nearby, which potentially represents some 1.5 million affected people (Vidal 2005). Downs (2005) of the UK Pesticides Campaign has written in the Guardian letters page telling of their attempts to provide evidence (of deleterious effects to human health from spraying) to the ACP but said that it is unclear what notice the regulators (: the Pesticides Safety Directorate) took of it, as they keep their advice to ministers secret following the 2003 DEFRA consultations on crop-spraying.
Canada: PMRA phases out citronella oil in insect repellents. Citronella oils are obtained from the steam distillation of fresh or partly dried grasses of Cymbopogon spp.: C. nardus (L.) Rendle (Sri Lankan type from Sri Lanka) and C. winterianus Jowitt (Java type from S.E. Asia, India, China, Central America & Indonesia). Total annual production of all citronella oils is in the order of 2000 tons/annum (Sanganeria 2005). Citronella oil has been, and still is, used extensively for perfuming soap, especially for Sunlight soap types for SE Asian and other markets, and formerly for green Palmolive types. It is still used in cheap perfumes for household products and especially finds employment in perfumes for washing up liquids, which many people will come in daily contact with. Its other main use is as a biocide for humans & pets, and in citronella candles etc. The more heavily traded Java type citronella oil is considered to have a more valuable odour profile than the Sri Lankan type. Citronella oil is used as a source for the isolation of natural citronellal and geraniol.
Both Sri Lankan and Java type citronella oils have geraniol, (4R)-(+)-b-citronellol and (mainly) (3R)-(+)-b-citronellal as major components, but the aldehydes (principally (3R)-(+)-b-citronellal) and the sesquiterpenes e.g. b-bourbonene, cubebene) are higher in the Java type, whereas the monterpenes are higher in the Sri Lanka type. For decades the more heavily traded Java-type oil has been sold commercially strictly to a 35-85 standard (see below), such as is mentioned in the older EOA standard No. 14 for Citronella oil Java type. A more modern universal standard for Java type citronella oil is ISO 3848 (1976), which also includes the determination of the ester number (after acetylisation) which must be 250 min. (corresponding to 85% acetylisable compounds calculated as geraniol) and the carbonyl content 127 min. (corresponding to 35% aldehydes calculated as citronellal).
Canada’s Pest Management Regulatory Agency (PMRA) in 1990 announced it would phase out citronella oil - based pesticides unless manufacturers provided more information about their products, and in 1995 announced a new initiative was introduced to re-evaluate all pesticides. The re-evaluation report of the PMRA PACR2004-36, available at http://www.pmra-arla.gc.ca/english/pdf/pacr/pacr2004-36-e.pdf was published in Sept 2004.
Looking in detail at the PMRA Re-evaluation report PACR2004-36, it highlights the methyl eugenol content of citronella oil as being of particular toxicological worry, since methyl eugenol (ME) has been identified as a rodent carcinogen and possible human carcinogen (NTP 2002). This is not a reasonable view since many Java type citronella oils analysed by the author of this article over the last 20 years have contained no methyl eugenol content whatsoever (Burfield, unpublished data). Any toxicological threat from ME in citronella oil has been completely dismissed by Dionne (undated) at www.citronella.org/documents/safety_report.pdf who points out that the lowest dose at which methyl eugenol (ME) has posed a mutagenic threat to human health is at a relatively large (oral) dose of 30mg/Kg. Since citronella oils only contain a maximum concentration of 0.09% ME, and methyl eugenol has not been proven to be bio-available from topical application of citronella oil, Dionne argues topical use of citronella oil is safe in normal use. Further, the author points out that ME needs to be activated through the P450 cytochrome system in the liver to 1’-hydroxymethyleugenol to present any toxicological risk. Finally, citral (an intermediary metabolite of citronellal) is a potent phase II detoxification enzyme inducer and would quickly quell any carcinogenic risk from ME. Other components of citronella oil, citral and citronellol, have been tested for mutagenicity and were found not to be active (Gomes-Carneiro et al. 1998). Some citronella components such as citronellyl acetate have been checked for dermal penetration and found not to exhibit this phenomena (Ping undated).
The PMRA report also highlighted the fact that no reproductive & developmental toxicity studies for citronella oil were available which was an apparently an issue for them, apart from an inadequate study by Toaff (1979). The report goes on to deal with the toxicity of individual citronella oil components (often via studies of commercially available “identical” fragrance chemicals, which often contain impurities and non-nature identical isomers which give misleading results). However at very short notice Cropwatch found key documents not apparently covered by the PMRA report answering these points: a study by Hoberman (1989) on reproductive toxicology effects of citral, and a study on developmental toxicology effects for citral by Gaworski et al. (1992). More will be made of this in the detailed Cropwatch report on the PMRA assessment, which will also cover other aspects of citronella oil toxicology.
This re-evaluation report has been followed by a re-evaluation note in Sept. 2005, REV2005-05 available at http://www.pmra-arla.gc.ca/english/pdf/rev/rev2005-05-e.pdf which broadly maintains the PMRA’s previous position, & states that it had given industry until 21st Jan 2005 to provide further information (which it hasn’t – small companies don’t have the money for expensive toxicology studies: Cropwatch) but reading between the lines, the PMRA appears to acknowledge the fact that wearers apply citronella oil topically more frequently and other a wider area than they had previously realised - see:
http://www.pmra-arla./gc.ca/english/pdf/rev/rev2005-05-e.pdf. Elsewhere the PMRA claim that the average dose of citronella oil from insect repellents to the user is 4.61 g/person/day – a figure which sounds somewhat exaggerated, especially if the average retailed product contains 5-15% citronella oil (equivalent to approx 90 mls per day at the lowest citronella oil content!). Apart from this scarcely believable item, the upshot is that any new citronella-oil based products will not be approved for market use although existing products may continue to be retailed. The PMRA will also hold an independent review of the opinion expressed in the Re-evaluation report PACR2004-36, and Cropwatch has written to a spokesperson (Oct. 2005) for the PMRA to see if it can submit scientific evidence to the PMRA panel on this issue.
No risk-benefit analysis appears to have been carried out by the Canadian authorities regarding the consequences to the general well-being of communities by disallowing citronella-based products, yet we know that insect stings and bites can be life-threatening to some individuals (Elston 2005). Further, because of the life-style and beliefs of many people who are averse to the use of synthetic chemicals, regulatory decisions such as this banning potentially remove a measure of freedom from citizens who might want to use natural botanically-based products exclusively for this purpose. This is all the more urgent since we know that DEET easily passes through human skin and can pose a neuro-toxicity risk – Health Canada have therefore phased out by Dec 2004 those insect repellents containing more than 30% DEET for this very reason.
Further, Cropwatch cannot understand the endorsement of the neurotoxic synthetic insect repellent DEET, when, for example, nepetalactone, the relatively innocuous natural component in Catnip oil produced by the steam distillation of Nepeta cataria, has been shown to work as well, or better, at preventing mosquito landings on human skin per unit time (and catnip is actually grown on a commercial scale in Canada!). The championing of DEET by the corporate-friendly Canadian Health Authorities to an informed and sceptical public has produced a situation where many people are now more afraid of the effects of dangerous synthetic & neurotoxic pesticides, than they are of catching West Nile disease or malaria, a truly disastrous outcome for all concerned.
USA: In complete contrast to the Canadian PMRA position on Citronella oil, the EPA de-regulated pesticides containing citronella oil in 1996 when it was added to the FIFRA Section 25(b) list of minimum risk pesticides. A Registration Eligibility Decision (RED) had been released on registered citronella oil preparations since they contained inert substances not on List 4A. The RED found oil of citronella oil to be generally of low acute toxicity. Toxicologically tests including oral, dermal and eye irritation tests were conducted on laboratory animals (causing unfortunate and un-necessary suffering to animals - this information is already available within the public domain: Cropwatch) with most results defined as Category III, or slightly toxic, and some results defined as Category IV, practically non-toxic. An employee of EPA’s Biopesticides and Pollution Prevention Division reportedly indicated that the EPA planned to consider Canada’s recent action. [N.B. this information is largely gleaned from Pesticide & Toxic Chemical News 32(49) p5].
Cropwatch has been in contact with a spokesperson for the EPA (Oct 2005) who has confirmed that the EPA view presented at http://www.pmra-arla.gc.ca/english/pdf/pacr/pacr2004-36-e.pdf is current in that pesticides with citronella oil as an active are deemed to present no threat to humans, animals or the environment from the citronella oil content – completely at variance with the present PMRA position.
p-Mentha 3,8-diol is not Lemon Eucalyptus!
“…Oil of lemon eucalyptus [p-menthane 3,8-diol (PMD)], a plant based repellent, is also registered with EPA. In two recent scientific publications, when oil of lemon eucalyptus was tested against mosquitoes found in the US it provided protection similar to repellents with low concentrations of DEET… Oil of lemon eucalyptus has not been tested against mosquitoes that spread malaria and some other diseases which occur internationally…”.
Some References & Further
Citronella Oil Toxicity
Elson C.E., Underbakke G.L., Hanson P., Shrago E., Wainberg RH., Qureshi AA “Impact of Lemongrass on Serum Cholesterol” Lipids 24(8) 677-679.
Gaworski, C.L., Vollmuth, T.A., York, R.G., Heck, J.D. & Aranyi, C. (1992) “Developmental toxicity evaluation of inhaled citral in Sprague-Dawley rats.” Food Chem. Toxicol. 30, 269–275.
Gomes-Carneiro M.R., Felzenszwalb I., Paumgartten J.R. (1998) “Mutagenicity testing of (±)-camphor, 1,8-cineole, citral, citronellal, (-)-menthol and terpineol with the Salmonella/microsome assay.” Mutation Research/Genetic Toxicology & Environmental Mutagenesis 416(1-2), 129-36.
Kokate C.K., Rao R.E., Varma K.C. (1971) “Pharmacological investigations of essential oil of Cymbopogon nardus (L.) Rendle: studies on central nervous system.” Indian J Exp Biol. 9(4), 515-6.
Opddyke D.L.J. (1973) RIFM Monograph: “Citronella oil” (1973) FCT 11, 1067
Ping J.H. (undated) “Identification of new drug compounds active against Pediculus humanus capitis, and incorporation of the compounds into a safe and potentially effective drug product.” Available on UGA Electronic Theses & Dissertations Record: ping_jefferey_h_200105_phd_pdf.
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