GREEN BOOK 4 Alkyl Benzoates CIR EXPERT PANEL MEETING AUGUST 30-31, 2010 July 30, 2010 MEMORANDUM To: CIR Expert Panel and Liaisons From: Lillian C. Becker, M.S. Scientific Analyst and Writer Subject: Draft Report for C12-15 Alkyl Benzoate and related Alkyl Benzoates The Cosmetic Ingredient Review (CIR) announced the Scientific Literature Review (SLR) for alkyl benzoates in June, 2010. C12-15 alkyl benzoate is the lead ingredient of this safety assessment. Related alkyl benzoate ingredients are included. CIR has been informed that a comprehensive dossier on the C12-15 alkyl benzoates being prepared for the European REACH program will be completed and provided to CIR in late September or early October. The Panel should review the Draft Report and decide: 1) if it is reasonable to include the other listed ingredients with C12-15 alkyl benzoate in this report and 2) whether any additional data are needed in order to reach a safety conclusion for C12-15 alkyl benzoates and the related ingredients. If no additional data are required, then the Panel may issue a Tentative Report. Alternatively, the Panel may choose to table the report to await the receipt of the dossier mentioned above. CIR Panel Book Page 1 CIR Panel Book Page 2 History of Alkyl Benzoates June, 2010 – SLR issued. August, 2010 - CIR Panel Book Page 3 Search Strategy for Benzoates EXPORATORY SEARCH: PUBMED: “alkyl benzoate” – 7 hits, 1 useful; CAS No. – 0 hits. Internet (Dogpile) – “alkyl benzoate” ‐ 1 MSDS FULL SEARCH: PUBMED: “lauryl alcohol” – 53 hits, 6 ordered. Learned that Valerie was doing this ingredient. “tridecyl alcohol” – 0 hits. CAS No. – 0 and 19 hits. 1 useful. “Amyl benzoate” ‐0 hits. CAS no – no hits. “benhyl benzoate” – 0 hits. CAS no – no hits. “Butyl Benzoate” – 9 hits, 1 useful. CAS no. – no hits. “Butyloctyl Benzoate” – 0 hits. No CAS no. “Ethyl Benzoate” – 44 hits, 4 useful. “Ethylhexyl Benzoate” – no hits. “Hexyldecyl Benzoate” – no hits. “Isobutyl Benzoate” – not hits. CAS no. – no hits. “939‐48‐0” OR “34364‐24‐4” OR “Lauryl/Myristyl Benzoate” OR “112‐53‐8” OR “Octyldodecyl Benzoate” OR ”2315‐68‐6” OR “10578‐34‐4” – 224 hits, 19 useful TOXNET: 68411‐27‐8 – 0 hits; 112‐53‐8 – 253 hits, 47 useful; 112‐70‐9 – 33 hits, 2 useful; 26248‐42‐0 ‐ 10 hits, 4 useful; 629‐76‐5 – 15 hits, 1 useful (already have); 2049‐96‐9 – 6 hits, 0 useful; “amyl alcohol” ‐ 798 hits, 86 + 64 hits so far; 103403‐38‐9 – no hits; 136‐60‐7 ‐ Butyloctyl Benzoate – no hits; butyloctyl alcohol – no hits; C16‐17 Alkyl Benzoate – no hits; palmyl alcohol – no hits; heptadecyl alcohol – no hits; 93‐89‐0 – 56 hits, 64‐17‐5 alcohol – 50000 hits, did not explore yet; Hexyldecyl Benzoate – no hits; Hexyldecyl Benzoate – No hits; 120‐50‐3 – 3 hits, 0 useful; 939‐48‐0 – 2 hits, 0 useful; 34364‐24‐4 – no hits, Isopropyl Benzoate – No hits; Isostearyl Benzoate – no hits; Lauryl/Myristyl Benzoate ‐ no hits; 112‐ 53‐8 [print toxnet] – 248 hits, 112‐53‐8 – 248 hits, 61 useful; 93‐58‐3 – 135 hits, 14 useful; Octyldodecyl Benzoate – no hits; Octyldodecyl Alcohol – no hits; 2315‐68‐6 – 7 hits, 2 useful; 10578‐34‐4 – no hits. EPA – HPV – One relevant report that included methyl benzoate. Data added to report under original citations. CIR Panel Book Page 4 Report Draft Report Alkyl Benzoates as used in Cosmetics August 30, 2010 The 2010 Cosmetic Ingredient Review Expert Panel members are: Chairman, Wilma F. Bergfeld, M.D., F.A.C.P.; Donald V. Belsito, M.D.; Curtis D. Klaassen, Ph.D.; Daniel C. Liebler, Ph.D.; Ronald A Hill, Ph.D. James G. Marks, Jr., M.D.; Ronald C. Shank, Ph.D.; Thomas J. Slaga, Ph.D.; and Paul W. Snyder, D.V.M., Ph.D. The CIR Director is F. Alan Andersen, Ph.D. This report was prepared by Lillian C. Becker, Scientific Analyst/Writer. © Cosmetic Ingredient Review 1101 17th Street, NW, Suite 412 " Washington, DC 20036-4702 " ph 202.331.0651 " fax 202.331.0088 " [email protected] CIR Panel Book Page 5 TABLE OF CONTENTS TABLE OF CONTENTS........................................................................................................................................................... iii INTRODUCTION ....................................................................................................................................................................... 1 CHEMISTRY .............................................................................................................................................................................. 1 Definition and Structure .......................................................................................................................................................... 1 Physical and Chemical Properties ........................................................................................................................................... 1 Manufacture and Production ................................................................................................................................................... 1 Impurities ................................................................................................................................................................................ 2 Analytical Methods ................................................................................................................................................................. 2 USE.............................................................................................................................................................................................. 2 Cosmetic .................................................................................................................................................................................. 2 Non-Cosmetic.......................................................................................................................................................................... 2 GENERAL BIOLOGY ................................................................................................................................................................ 2 Absorption, Distribution, Metabolism, and Excretion............................................................................................................. 2 Growth Inhibition .................................................................................................................................................................... 3 TOXICOLOGY ........................................................................................................................................................................... 3 Acute Toxicity ......................................................................................................................................................................... 3 Methyl Benzoate ................................................................................................................................................................. 3 Ethyl Benzoate .................................................................................................................................................................... 3 Isopropyl Benzoate ............................................................................................................................................................. 3 Isobutyl Benzoate................................................................................................................................................................ 3 Short-Term Toxicity ................................................................................................................................................................ 3 Benzoic Acid and Sodium Benzoate ................................................................................................................................... 3 Subchronic Toxicity ................................................................................................................................................................ 3 Benzoic Acid....................................................................................................................................................................... 3 Chronic Toxicity ..................................................................................................................................................................... 3 Sodium Benzoate ................................................................................................................................................................ 3 Ocular/Mucosal Irritation ........................................................................................................................................................ 3 Isostearyl Benzoate ............................................................................................................................................................. 3 Dermal Irritation ...................................................................................................................................................................... 3 Methyl Benzoate ................................................................................................................................................................. 3 Ethyl Benzoate .................................................................................................................................................................... 4 Propyl Benzoate .................................................................................................................................................................. 4 Butyl Benzoate .................................................................................................................................................................... 4 Dermal Sensitization ............................................................................................................................................................... 4 Reproductive and Developmental Toxicity ............................................................................................................................. 4 iii CIR Panel Book Page 6 Sodium Benzoate ................................................................................................................................................................ 4 Benzoic Acid....................................................................................................................................................................... 4 GENOTOXICITY ....................................................................................................................................................................... 4 Methyl Benzoate ................................................................................................................................................................. 4 Benzoic Acid and Sodium Benzoate ................................................................................................................................... 4 CARCINOGENICITY ................................................................................................................................................................ 5 Methyl Benzoate ................................................................................................................................................................. 5 Benzoic Acid....................................................................................................................................................................... 5 CLINICAL ASSESSMENT OF SAFETY .................................................................................................................................. 5 Absorption, Distribution, Metabolism, and Excretion............................................................................................................. 5 Toxicity ................................................................................................................................................................................... 5 Benzoic Acid....................................................................................................................................................................... 5 Dermal Irritation ...................................................................................................................................................................... 5 C12-15 Alkyl Benzoate....................................................................................................................................................... 5 Benzoic Acid....................................................................................................................................................................... 5 Dermal Sensitization ............................................................................................................................................................... 5 C12-15 Alkyl Benzoate....................................................................................................................................................... 5 Isostearyl Benzoate ............................................................................................................................................................. 5 Octyldodecyl Benzoate ....................................................................................................................................................... 5 Benzoic Acid....................................................................................................................................................................... 6 Phototoxicity ........................................................................................................................................................................... 6 Benzoic Acid....................................................................................................................................................................... 6 SUMMARY................................................................................................................................................................................. 6 TABLES AND FIGURES ........................................................................................................................................................... 7 REFERENCES .......................................................................................................................................................................... 13 iv CIR Panel Book Page 7 INTRODUCTION This is a safety assessment of alkyl benzoate esters that are used in cosmetics. The ingredients included in this literature review are: methyl benzoate, ethyl benzoate, propyl benzoate, butyl benzoate, amyl benzoate, lauryl/myristyl benzoate, C12-15 alkyl benzoate, C16-17 alkyl benzoate, stearyl benzoate, behenyl benzoate, isopropyl benzoate, isobutyl benzoate, isostearyl benzoate, ethylhexyl benzoate, butyloctyl benzoate, hexyldecyl benzoate, and octyldodecyl benzoate. The alkyl benzoate ingredients are esters of benzoic acid and a corresponding alcohol, with the shorter chain alkyl benzoates (methyl, ethyl, propyl, isopropyl, butyl, isobutyl and amyl benzoate) ranging in MW from 136 to 192 and the longer chain alkyl acetates (lauryl/myristyl, C12-15 alkyl, C16-17 alkyl, stearyl, isostearyl, behenyl, ethylhexyl, butyloctyl, hexyldecyl, and octyldodecyl benzoate) ranging in MW from 234 to 431. It is unclear as to whether the alkyl benzoates in this report penetrate the skin. If they do, these compounds may be metabolized in the skin into benzoic acid and the parent alcohol. The conclusions from prior assessments of benzoic acid, sodium benzoate, and the parent alcohols (methyl alcohol, ethyl alcohol, butyl alcohol, myristyl alcohol, behenyl alcohol, isostearyl alcohol) by the Cosmetic Ingredient Review (CIR) Expert Panel are listed below. These conclusions may be relevant to this report if significant penetration and metabolism do occur. Benzoic acid and sodium benzoate - “…safe for use in cosmetic formulations at concentrations up to 5%. The available data are insufficient to support the safety of [benzoic acid and sodium benzoate] in cosmetic products in which a primary route of exposure is inhalation”.1 Methyl alcohol - safe for use as a denaturant in ethyl alcohol for cosmetic products, with qualifications. The Panel has not stated that methyl alcohol is safe or unsafe as a solvent.2 Ethyl alcohol – (as “Alcohol Denat.” with methyl alcohol) - safe in the present practices of use and concentration.3 Butyl alcohol - safe as a cosmetic ingredient in the present practices of use.4 In 2005, the panel looked at new data and the safety conclusion in the report was confirmed. Myristyl alcohol - safe as a cosmetic ingredient in the present practices of use.5 Cetyl alcohol - safe as a cosmetic ingredient in the present practices of use.6 In 2005, the panel looked at new data and the conclusion in the report was confirmed. Stearyl alcohol - safe as currently used in cosmetics.7 In 2006, the panel looked at new data and the conclusion in the report was confirmed. Isostearyl alcohol - safe as cosmetic ingredients in the present practices of use. 6 In 2005, the panel looked at new data and the conclusion in the report was confirmed. Behenyl alcohol - safe as a cosmetic ingredient in the present practices of use.5 In 2005, the panel looked at new data and the conclusion in the current report was confirmed. Propyl alcohol and isopropyl alcohol are concurrently under review by the CIR expert Panel in the report titled Methyl Acetate. Summaries of the data from the benzoic acid and sodium benzoate safety assessment are included in this safety assessment. The potential metabolites of ethylhexyl benzoate, butyloctyl benzoate, hexyldecyl benzoate, isobutyl benzoate, amyl benzoate, pentadecyl benzoate, heptadecyl benzoate, and octyldecyl benzoate are not current cosmetic ingredients in the dictionary, thus have not been reviewed by CIR. CHEMISTRY Definition and Structure Alkyl benzoates are mostly used as skin-conditioning agents, preservatives, solvents, and plasticizers. The CAS numbers, definitions, functions, as well as technical and trade names of the ingredients under review are presented in Table 1. Structures and potential metabolic pathways of these ingredients are presented in Figures 1 and 2. Physical and Chemical Properties The shorter chain alkyl benzoate esters are colorless liquids. Viscosity generally increases as the molecular mass (chain length) increases.8 The physical and chemical properties of the benzoates are shown in Table 2. At room temperature and pressure, methyl benzoate, ethyl benzoate, butyl benzoate, and isobutyl benzoate are fragrant, colorless oils, and are insoluble in water.9 Manufacture and Production In general, the alkyl benzoates can be produced industrially via esterification of benzoic acid.8 The manufacture of butyl benzoate, for example, is traditionally accomplished via an acid catalyzed (e.g., sulfuric acid) reactive distillation process between benzoic acid and butyl alcohol (Figure 3).10 Methanol and ethanol are normally obtained via fermentation of natural sources. However, some alcohols with chains longer than ethanol are often produced synthetically. An important process for producing C3- C22 industrial alcohols involves a process known as oxo-synthesis (a process for the production of aldehydes which occurs by the reaction of olefins (which can be natural or petroleum sourced) with carbon monoxide, hydrogen and a catalyst [typically cobalt based]), followed by hydrogenation of the aldehyde products, to form the alcohols.11 Recently, a biocatalytic process developed 1 CIR Panel Book Page 8 specifically for the manufacture of esters for use in the formulation of cosmetic and personal care ingredients (i.e. for producing cosmetic grade esters) was developed.12 Impurities The manufacturing processes of the benzoic esters are typically high yielding (>90%) and easily purified (e.g., by distillation). Therefore, the starting materials and water, at least, may be expected to be present in preparations of these esters as the major impurities.8 For example, methyl benzoate is available with a minimum of 99.2% purity, wherein the major contaminants are water (<0.1%) and benzoic acid (<0.02%).13 Analytical Methods The benzoic esters can be analyzed using gas chromatography/mass spectroscopy (GCMS), nuclear magnetic resonance (NMR) spectroscopy, ultraviolet (UV) spectroscopy and infrared (IR) spectroscopy.8,11,14 USE Cosmetic According to the Voluntary Cosmetic Registration Program (VCRP) administered by the Food and Drug Administration (FDA), the total number of uses of C12-15 alkyl benzoate was 971 (858 leave-on and 113 rinse-off products).15 A survey conducted by the Personal Care Products Council (Council) found that C12-15 alkyl benzoate was used at 0.0008% - 35% (tonics, dressings, and other hair grooming aids) in leave-on products and 0.0008% - 50% (paste masks [mud packs]) in rinse-off products.16 There were 2 uses reported of C16-17 alkyl benzoates at 0.7% (bath soaps and detergents). Stearyl benzoate at 2% was reported to have 3 uses (face and neck creams, lotions, and powders). While there were no uses reported by VCRP, the Council reported behenyl benzoate use at 0.04% (lipstick), ethyl benzoate use at 0.0008% - 0.01% (foot powders and sprays), isobutyl benzoate use at 0.01% (perfumes), isostearyl benzoate use at 1% (body and hand creams, lotions, and powders), methyl benzoate use at 0.0005% – 0.3% (perfumes), and octyldodecyl benzoate at 3% - 4% (shaving cream) The uses and concentrations are provided in Table 3. No uses or concentrations of use were reported for propyl benzoate, butyl benzoate, amyl benzoate, lauryl/myristyl benzoate, isopropyl benzoate, ethylhexyl benzoate, butyloctyl benzoate, and hexyldecyl benzoate. These ingredients are used in aerosol/spray products, and effects on the lungs that may be induced by aerosolized products containing these ingredients may be of concern when these ingredients are vaporized. In the EU, methyl benzoate, ethyl benzoate, propyl benzoate and butyl benzoate may be used as preservatives in cosmetics up to 0.5% (acid).17 Non-Cosmetic Alkyl benzoate esters are typically used as solvents in paints, lacquers and coatings, and as intermediates in various chemistry processes.8 Methyl benzoate is used in flavoring and perfumery, and as a solvent in resins.9 Ethyl benzoate is used in flavoring and perfumery, and as a solvent in lacquers and resins.9 Butyl benzoate is used as a solvent for cellulose ether, as a plasticizer, perfume ingredient and for dyeing of textiles.9 Isobutyl benzoate is used in flavoring and perfumery.9 GENERAL BIOLOGY Benzoate esters are metabolized into benzoic acid (and the corresponding alcohols) and further metabolized to benzyl glucuronide and benzoyl CoA.18 Benzoyl CoA metabolizes into hippuric acid, the principal metabolite excreted in the urine. Dermally applied benzoic acid is excreted in the urine within 24 h. Absorption, Distribution, Metabolism, and Excretion There are limited data found on the absorption, distribution, metabolism, and excretion of any of the alkyl benzoates in this safety assessment. However, data on benzyl alcohol show that it is broken down into benzoic acid by simple oxidation.1 Orally consumed benzoic acid is absorbed from the gastrointestinal tract and conjugated with glycine in the liver. The resulting hippuric acid is excreted in the urine (75% - 100% within 6 h). Dermally applied benzoic acid is also excreted in the urine within 24 h. Benzoate esters are metabolized into benzoic acid (and the corresponding alcohols) and further metabolized to benzyl glucuronide and benzoyl CoA.18 The benzoyl CoA metabolizes into hippuric acid, the principal metabolite excreted in the urine. In general, esters can be hydrolyzed to the parent alcohol and acid.8 The rate of this reaction can be increased by raising the temperature and decreased by lowering pH. Secondary and tertiary esters are hydrolyzed more slowly than primary esters. Enzymatic hydrolysis occurs via enzymes called esterases. These enzymes are present in the respiratory tract, skin, blood and gastrointestinal tract.19,20 In general, alcohols can be metabolized by alcohol dehydrogenases to aldehydes or ketones. The aldehydes may be further metabolized by aldehyde dehydrogenases to the corresponding acids. Low molecular weight alkyl esters readily penetrate the skin and mucous membranes. However, benzoic esters are not absorbed through the skin as rapidly as alkyl esters.21 If alkyl benzoates are absorbed and metabolized, the resulting alcohols can be oxidized via alcohol dehydrogenases to produce the corresponding aldehyde or ketone. As noted above, these aldehydes can then be further oxidized via aldehyde dehydrogenases to the corresponding acids. 2 CIR Panel Book Page 9 Growth Inhibition In a protein count assay of methyl benzoate, the EC50 (50% of the concentration of maximum effect) was 1506.58 (C.I. 1349.27 - 168.22) mM, the NI50 (the concentration that reduced the uptake of neutral red by 50%) was 683.30 (466.46 – 1000.91) mM in a neutral red uptake assay, and the (the concentration that inhibited growth by 50%) ID50 was 987.19 (605.15-1610.43) mM in a growth inhibition assay using HeLa cells.22 Methyl benzoate (2.5 and 5.0 mg/ml) inhibited mycelia growth and aflatoxin release by Aspergillis flavus and A. parasiticus.23 TOXICOLOGY Acute Toxicity The oral LD50 of methyl benzoate was 2170 mg/kg for rabbits, 4100 mg/kg for guinea pigs, 1350-3500 for rats, and 3000-3330 mg/kg for mice. The oral LD50 of ethyl benzoate was 2630 mg/kg for rabbits and 2100-6480 mg/kg for rats. The oral LD50 of isopropyl benzoate was 3730 mg/kg and 3685 mg/kg for isobutyl benzoate for rats. The dermal LD50 of methyl benzoate was ≥ 2000 mg/kg for rabbits. Methyl Benzoate The reported oral LD50 of methyl benzoate was 2170 mg/kg for rabbits, 4100 mg/kg for guinea pigs, 1350-3500 for rats, and 3000-3330 mg/kg for mice.24-27 The dermal LD50 of methyl benzoate was ≥ 2000 mg/kg for New Zealand white rabbits (n = 5).28 There was fecal staining for 3 days after treatment. Irritation was observed at the application site. There was weight loss for 1 – 7 days after treatment. There were no gross findings at necropsy. There were no mortalities. Ethyl Benzoate The reported oral LD50 of ethyl benzoate was 2630 mg/kg for rabbits and 2100-6480 mg/kg for rats.24,27 Isopropyl Benzoate The reported oral LD50 of isopropyl benzoate was 3730 mg/kg for rats.29 Isobutyl Benzoate The reported oral LD50 of isobutyl benzoate was 3685 mg/kg for rats.18 Short-Term Toxicity Benzoic acid and sodium benzoate were toxic to rats and mice at oral doses > 1%. Benzoic Acid and Sodium Benzoate In multiple-dose oral toxicity studies on rats and mice, decreased feed consumption, depressed growth, and toxic effects were observed at doses > 1% benzoic acid or sodium benzoate.1 A neurobiological study on rats and mice was negative. Subchronic Toxicity Benzoic acid was toxic to mice at oral doses of 80 mg/kg/d. Benzoic Acid Cross bred white mice (n = 100) were orally administered benzoic acid at 80 mg/kg/d for 3 months.30 The treated group had decreased weight gain. Mortality was increased (68% vs. 60 % in the control group). Chronic Toxicity Sodium benzoate at 880 mg/kg/d incorporated into the feed of rats for 18 – 24 months was not toxic. Sodium Benzoate Sodium benzoate (0, 1%, or 2%; 735 or 880 mg/kg/d) was incorporated into the feed of Fischer 344 rats (n = 102; 50 males, 52 females) for 18 – 24 months.31 There were no differences in mortality between groups. Necropsies were unremarkable. Ocular/Mucosal Irritation Isostearyl benzoate was rated as a slight ocular irritant in two in vitro tests. Isostearyl Benzoate In an ocular irritation assessment of a body lotion containing isostearyl benzoate (0.95%) using neutral red release (NRR) assay, the hen’s egg test on the chorio-allantoic membrane (HET-CAM) assay, and the reconstituted human epithelial culture (REC) assay, the authors rated the lotion as slightly irritating.32 Dermal Irritation Methyl benzoate, ethyl benzoate, propyl benzoate, and butyl benzoate at 100% are dermally irritating to rabbits. Methyl Benzoate Methyl benzoate was applied to the clipped dorsum (100%; 0.5 ml) and external surface of the outer ear (0.2 ml) daily for 6 days to male New Zealand albino rabbits (n = 14).33 On the dorsum, there were marked cellular reactions and dermal edema beginning on day 2 followed by dermal hemorrhages, desquamated crust, and thickening of the malpighian stratum beginning on day 5. On the inner ear, there was slight hyperkeratosis at day 6. 3 CIR Panel Book Page 10 Ethyl Benzoate Ethyl benzoate was applied to the clipped dorsum (0.5 ml) and external surface of the outer ear (0.2 ml) daily for 6 days to male New Zealand albino rabbits (n = 14).33 On the dorsum, there was marked cellular changes, edema, desquamated crusts, and thickening of the malpighian stratum beginning on day 1. On the inner ear, there were slight cellular reaction, no edema or hemorrhages, no necrosis, slight to marked desquamated crusts, marked thickening of malpighian stratum, hyperkeratosis, and slight hyperplasia of sebaceous glands beginning day 1. Propyl Benzoate Propyl benzoate was applied to the clipped dorsum (0.5 ml) and external surface of the outer ear (0.2 ml) daily for 6 days to male New Zealand albino rabbits (n = 14).33 On the dorsum, there were marked cellular reactions, necrosis, thickening of the malpighian stratum beginning on day 1 followed by dermal hemorrhages, desquamated crusts beginning on days 3 or 4.. On the inner ear, there were slight cellular reactions, necrosis, and moderate thickening of the malpighian stratum beginning on day 1 or 3. Butyl Benzoate Butyl benzoate was applied to the clipped dorsum (0.5 ml) and external surface of the outer ear (0.2 ml) daily for 6 days to male New Zealand albino rabbits (n = 14).33 On the dorsum, there were marked cellular reaction, necrosis, and slight detachment of the dermo-epidermis beginning on day 1 followed by desquamated crusts and thickening of the malpighian stratum beginning on day 3. On the inner ear, there were slight cellular reaction, necrosis beginning on day 1 and moderate desquamed crusts and hyperplasia sebaceous glands on day 2 or 3. Dermal Sensitization There were no animal dermal sensitization data discovered on alkyl benzoates in this safety assessment. Reproductive and Developmental Toxicity Studies on sodium benzoate and benzoic acid did not show reproductive or developmental toxicity. Where effects of the fetus were noted, they occurred at maternally toxic concentrations (> 4% sodium benzoate in rats). Sodium Benzoate Sodium benzoate (0, 1%, 2%, 4%, or 8%; 0, 667, 1333, 1600, or 710 [sic] mg/kg/d) was orally administered in the feed of female Wistar rats (n = 27-30) during gestation.34 On day 20, 20-25 of each group were killed and necropsied. The rest were allowed to live through pregnancy and nurse for 3 or 8 weeks and then killed. Half of the pups were then killed at each of these times and necropsied. The 2 highest dose groups had an increase in the number of dead fetuses and resorbed embryos. The body weights of the viable pups were decreased, there was mild systemic edema observed. The number of fetal abnormalities was increased in a dose-dependent manner. The number of pups born was decreased, the number of perinatal deaths increased to 100%, lactation rate decreased, and survival rate decreased to 0 in the 2 highest dose groups. The effects on the fetus occurred only at maternally toxic concentrations of ≥ 4% sodium benzoate. Sodium benzoate (up to 5mg/egg) was injected twice into the air sac of fertilized chicken eggs at 0 and 96 h and incubated to hatching.35 Surviving chicks were killed and necropsied. There were no teratogenic effects reported. The LD50 was 4.74 mg/egg. Female Wistar rats (n = 20) were orally administered sodium benzoate (0, 1.75, 8.0, or 175 mg/kg/d) during days 6 – 15 of gestation.36 On day 20 of gestation, the pups were delivered by Caesarean section. There were no differences in the types or amounts of abnormalities observed in any of the treatment groups compared to the control. The fetal and maternal NOAEL was 175 mg/kg. The study above was repeated with mice (n = 20), hamsters (n = 21, 22; gestation days 6 - 10), and rabbits (n = 10). Similar results were reported. Benzoic Acid In oral teratogencity studies, benzoic acid increased the number of resorptions at ≥ 30 mg/kg/d and increased the number of fetal malformations at > 600 mg/kg/d results in hamsters. Results were negative in 2 rat studies up to 500 mg/kg/d.1 Cross bred white mice (n = 25 males, 25 females) were orally administered benzoic acid (40 mg/kg/d) for 8 months before breeding.30 This was continued for 5 generations. The parental and F1 cohorts had increased mortality compared to controls after a 5-day 100% food restriction test. Otherwise, there were no effects on reproduction. GENOTOXICITY In an Ames test, methyl benzoate was not genotoxic to S. typhimurium or E. coli. Benzoic acid and sodium benzoate were not genotoxic in several assays. Methyl Benzoate In an Ames test using S. typhimurium (TA97, TA98, TA100, TA1535, and TA1537), methyl benzoate (6666 µg/plate) was not mutagenic with or without metabolic activation.37 Methyl benzoate (dose not reported) was not found to be mutagenic using E. coli (Sd-4-73).38 Benzoic Acid and Sodium Benzoate Benzoic acid was negative in several Ames tests using Salmonella typhimurium (including TA98, TA100, TA1535, 4 CIR Panel Book Page 11 TA1537 and TA 1538) with and without metabolic activation.39-43 In one Ames test using S. typhimurium (TA98 and TA100), benzoic acid (0.1 mg/plate) and sodium benzoate (0.1 mg/plate) were genotoxic with activation.42 In a reverse mutation test, benzoic acid (5 mg/disc) was positive for genotoxicity. In a sister chromatid exchange assay using human lymphocytes, benzoic acid (0 – 2.0 mM) was not genotoxic with metabolic activation.40 In a chromosomal aberration test using Chinese hamster fibroblasts, benzoic acid (1.5 mg/ml) and sodium benzoate (2.0 mg/ml) had positive results without metabolic activation.46 Sodium benzoate was positive without metabolic activation and negative with metabolic activation in a reverse mutation assay using Bacillus subtilis.41 Benzoic acid (1.5 mg/ml) was positive in a chromosomal aberration test without metabolic activation. In a sister chromatid exchange assay using hamster lung fibroblasts, sodium benzoate was not clastogenic without metabolic activation.44 CARCINOGENICITY Orally administered methyl benzoate (80 mg/kg/d) to mice increased tumor growth compared to controls. Benzoic acid was negative for carcinogenicity when dermally applied to mice at 0.016% in a non-oxidative hair dye. Methyl Benzoate In a 1970 review, it was reported that cross bred white mice (n = 100) orally administered methyl benzoate (80 mg/kg/d) had increased tumor growth compared to controls.30 Benzoic Acid Benzoic acid was negative for carcinogenicity when dermally applied to mice at 0.016% in a non-oxidative hair dye.1 CLINICAL ASSESSMENT OF SAFETY Absorption, Distribution, Metabolism, and Excretion There were no human absorption, distribution, metabolism, and excretion data discovered for alkyl benzoates. Toxicity Benzoic Acid In clinical studies, toxic symptoms (metabolic acidosis, central neural depression, respiratory distress progressing to gasping respiration, hypotension, renal failure, and occasional seizures and intracranial hemorrhages) were observed following doses far exceeding the acceptable daily intake (ADI) established by the World Health Organization.1 Dermal Irritation C12-15 Alkyl benzoate was not irritating at 100%. In multiple clinical studies, the benzoates were recognized to produce non-immunologic contact uriticaria or non-immunologic immediate contact reactions, but it was not clear whether the reactions are histamine or prostaglandin mediated. C12-15 Alkyl Benzoate In an irritation study, C12-15 alkyl benzoate (0, 3%, 10%, 30, and 100% in vegetable oil) was applied to the backs of subjects (n = 21) under occlusion for 48 h.45 No signs of irritation were observed at 48 and 72 h. Benzoic Acid In multiple clinical studies, the benzoates were recognized to produce non-immunologic contact uriticaria or nonimmunologic immediate contact reactions, but it was not clear whether the reactions are histamine or prostaglandin mediated.1 Dermal Sensitization In HIRPTs, C12-15 alkyl benzoate at 100%, isostearyl benzoate at 0.95%, and octyldodecyl benzoate at 0.4% were not sensitizing. In 4 studies, test for the sensitization of benzoic acid were negative. C12-15 Alkyl Benzoate A human repeated insult patch test (HRIPT; n = 101) was conducted on C12-15 alkyl benzoate (100%).46 There were no visible reactions to the test substance observed. Isostearyl Benzoate A HRIPT (n = 107) was conducted on a body lotion product containing isostearyl benzoate (0.95%) under semiocclusion.47 Except for one subject, who also reacted to several other test substances on the shared panel, there were no visible reactions to the product containing isostearyl benzoate at 0.95%. Octyldodecyl Benzoate An HRIPT (n = 105) was conducted on a shaving cream product containing octyldodecyl benzoate (4%) under semiocclusion.48 The product was diluted to a 10% aqueous solution. There were no visible reactions to the product containing octyldodecyl benzoate at 0.4%. 5 CIR Panel Book Page 12 Benzoic Acid In 4 studies, tests for the sensitization of benzoic acid were negative.1 Phototoxicity Benzoic Acid In several studies, phototoxicity and photosensitivity tests of benzoic acid were negative up to 0.2%.1 SUMMARY This is a safety assessment of alkyl benzoates that are used in cosmetics. Alkyl benzoates are mostly used as skinconditioning agents, preservatives, solvents, and plasticizers. In general, the alkyl benzoates can be produced industrially via esterification of benzoic acid. The manufacturing processes of the benzoic esters are typically high yielding (>90%) and easily purified (e.g., by distillation). The esters, acids and alcohols can be analyzed using gas chromatography/mass spectroscopy (GCMS), nuclear magnetic resonance (NMR) spectroscopy, ultraviolet (UV) spectroscopy and infrared (IR) spectroscopy. The total number of uses of C12-15 alkyl benzoate was 971 (858 leave-on and 113 rinse-off products) at concentrations up to 35% and 50% in leave-on and rinse-off products, respectively. The highest concentrations of use for C16-17 alkyl benzoates, stearyl benzoate, behenyl benzoate, ethyl benzoate, isobutyl benzoate, isostearyl benzoate, methyl benzoate, and octyldodecyl benzoate were reported to be from 0.01% to 4%. No uses or concentrations of use were reported for propyl benzoate, butyl benzoate, amyl benzoate, lauryl/myristyl benzoate, isopropyl benzoate, ethylhexyl benzoate, butyloctyl benzoate, and hexyldecyl benzoate. Benzoate esters are metabolized into benzoic acid (and the corresponding alcohols) and further metabolized to benzoyl glucuronide and benzoyl CoA.18 The benzoyl CoA metabolizes into hippuric acid, the principal metabolite excreted in the urine. Dermally applied benzoic acid is also excreted in the urine within 24 h. There were no human absorption, distribution, metabolism, and excretion data discovered for alkyl benzoates. The oral LD50 of methyl benzoate was 2170 mg/kg for rabbits, 4100 mg/kg for guinea pigs, 1350-3500 for rats, and 3000-3330 mg/kg for mice. The oral LD50 of ethyl benzoate was 2630 mg/kg for rabbits and 2100-6480 mg/kg for rats. The oral LD50 of isopropyl benzoate was 3730 mg/kg and 3685 mg/kg for isobutyl benzoate for rats. The dermal LD50 of methyl benzoate was ≥ 2000 mg/kg for rabbits. Benzoic acid and sodium benzoate were toxic to rats and mice at doses > 1% in short-tem oral studies . Benzoic acid was toxic to mice at 80 mg/kg/d in chronic oral studies. Sodium benzoate at 880 mg/kg/d incorporated into the feed of rats for 18 – 24 months was not toxic. Isostearyl benzoate was rated as a slight ocular irritant in two in vitro tests. Methyl benzoate, ethyl benzoate, propyl benzoate, and butyl benzoate at 100% are dermally irritating to rabbits.There were no animal dermal sensitization data discovered on alkyl benzoates in this safety assessment. Studies of sodium benzoic acid and sodium benzoate showed no reproductive or developmental toxicity. Effects noted were at a maternally toxic concentration of > 4% sodium benzoate. Methyl benzoate was not genotoxic to S. typhimurium or E. coli. Benzoic acid and sodium benzoate were not genotoxic in several assays. Orally administered methyl benzoate (80 mg/kg/d) to mice increased tumor growth compared to controls. Benzoic acid was negative for carcinogenicity when dermally applied to mice at 0.016% in a non-oxidative hair dye. In humans, C12-15 Alkyl benzoate was not irritating at 100%. In multiple clinical studies, the benzoates were recognized to produce non-immunologic contact uriticaria or non-immunologic immediate contact reactions, but it was not clear whether the reactions are histamine or prostaglandin mediated. In HIRPTs, C12-15 alkyl benzoate at 100%, isostearyl benzoate at 0.95%, and octyldodecyl benzoate at 0.4% were not sensitizing. In 4 studies, tests for the sensitization of benzoic acid were negative. 6 CIR Panel Book Page 13 TABLES AND FIGURES Ingredient Alkyl Benzoates Methyl Benzoate Table 1. Definitions, functions and structures of alkyl benzoate and alcohol ingredients in this safety assessment. CAS No. Definition Function(s) Technical names Trade names 93-58-3 Methyl benzoate is the ester of methyl alcohol and benzoic acid that conforms to the formula in Figure 1. Ethyl benzoate is the ester of ethyl alcohol and benzoic acid. Propyl benzoate is the ester of n-propyl alcohol and benzoic acid. Butyl benzoate is the ester of butyl alcohol and benzoic acid. Amyl benzoate is the ester of amyl alcohol and benzoic acid that conforms to the formula in Figure 1. Lauryl/Myristyl benzoate is the organic compound that conforms to the formula in Figure 1. Benzoic Acid, Methyl Ester; Methyl Benzenecarboxylate Methyl benzoate (RIFM) Benzoic Acid, Ethyl Ester; Ethyl benzoate (RIFM) Benzoic Acid, n-Propyl Ester; Propyl benzoate (RIFM) Benzoic Acid, n-Butyl Ester; Butyl benzoate (RIFM) Benzoic Acid, Pentyl Ester; Pentyl Benzoate Pentyl benzoate (RIFM) Morflex Methyl Benzoate Skin-conditioning agentmiscellaneous - Corum 5014 AEC C12-15 Alkyl Benzoate; Botanester AB; Cetiol AB; Corum 5012; Crodamol AB; Crodamol AB; Dub B1215; Finsolv TN; Hest 25B; Liponate NEB; OriStar AKB; Saboderm AB; Sterol B 125; Tegosoft TN; Tegosoft TN 2 Finsolv G-2 Fragrance ingredient, skinconditioning agentemollient, solvent Fragrance - Ethyl Benzoate 93-89-0 Propyl Benzoate 2315-68-6 Butyl Benzoate 136-60-7 Amyl Benzoate 2049-96-9 Lauryl/ Myristyl Benzoate No CAS No. C12-15 Alkyl Benzoate 68411-27-8 C12-15 alkyl benzoate is the mixture of esters of benzoic acid and C12-15 alcohols. Skin-conditioning agents - emollient Alkyl (C12-C15) Benzoate; Benzoic Acid, C12-15 Alkyl Esters; C12-15 Alcohols Benzoate C16-17 Alkyl Benzoate 669700-05-2 Skin-conditioning agents-emollient, solvent - Stearyl Benzoate 10578-34-4 Skin-conditioning agent-emollient, solvent 103403-38-9 Benzoic Acid, Octadecyl Ester; Benzoic Acid, Stearyl Ester; Octadecyl Benzoate Benzoic Acid, Docosyl Ester Dub PG; Finsolv 116 Behenyl Benzoate C16-17 alkyl benzoate is a mixture of esters of C16-17 alcohols and benzoic acid that conforms generally to the formula in Figure 1. Stearyl benzoate is the ester of stearyl alcohol and benzoic acid that conforms to the formula in Figure 1. Behenyl benzoate is the ester of behenyl alcohol and benzoic acid that conforms to the formula in Figure 1. Isopropyl benzoate is the ester of isopropyl alcohol and benzoic acid. Fragrance ingredient Benzoic Acid, Isopropyl Ester; Benzoic Acid, 1Methylethyl Ester; Isopropyl benzoate (RIFM); 1-Methylethyl Benzoate - Branched Alkyl Benzoates Isopropyl 939-48-0 Benzoate Fragrance ingredient, preservative Fragrance ingredient, preservative Fragrance ingredient Skin-conditioning agent – emollient 7 CIR Panel Book Page 14 - Finsolv 137 Ingredient Isobutyl Benzoate Isostearyl Benzoate Ethylhexyl Benzoate Butyloctyl Benzoate Hexyldecyl Benzoate Octyldodecyl Benzoate Table 1. Definitions, functions and structures of alkyl benzoate and alcohol ingredients in this safety assessment. CAS No. Definition Function(s) Technical names Trade names Fragrance Benzoic Acid, Isobutyl 120-50-3 Isobutyl benzoate is the ingredient, solvent Ester; ester of isobutyl alcohol Benzoic Acid, 2and benzoic acid. Methylpropyl Ester; Isobutyl benzoate (RIFM); 2-Methylpropyl Benzoate Finsolv SB 34364-24-4 Isostearyl benzoate is the Skin-conditioning Benzoic Acid, ester of isostearyl alcohol agent-emollient Isooctadecyl Ester; and benzoic acid. Benzoic Acid, Isostearyl Ester Bernel Ester OB; Benzoic Acid, 2Skin-conditioning 5444-75-7 Ethylhexyl benzoate is Finsolv EB Ethylhexyl Ester; agent-emollient, the ester of 22-Ethylhexyl Benzoate solvent ethylhexanol and benzoic Octyl Benzoate acid. Benzoic Acid, 21888038-97-3 Butyloctyl benzoate is the Plasticizer; skinconditioning agentButyloctyl Ester organic compound that emollient, solvent conforms to the formula in Figure 2. Plasticizer, skin163883-40-7 Hexyldecyl benzoate is Benzoic Acid, 2conditioning agentthe organic compound Hexyldecyl Ester emollient, solvent that conforms to the formula in Figure 2. Skin-conditioning 108347-89-3 Octyldodecyl benzoate is Benzoic Acid, 2Finsolv BOD agent-emollient the ester of Octyldodecyl Ester octyldodecanol and benzoic acid. 8 CIR Panel Book Page 15 Methyl Benzoate Table 2. Physical and Chemical properties of the acetate ingredients.9,9,11,49,49 Butyl Benzoate Amyl Benzoate Ethyl Propyl Benzoate Benzoate Lauryl/Myristal Benzoate CAS No. 93-58-3 93-89-0 2315-68-6 136-60-7 2049-96-9 - Molecular Weight (g/mol) Boiling Point (°C) Density (g/cm3) 136.15 150.17 164.20 178.23 192.25 290.44/318.49 198.6 212.9 230.0 247.3 248 225 (Lauryl at 20 mmHg) 1.09 1.04 1.04 1.00 0.95 0.93(Lauryl) Vapor pressure (mm Hg @ 20°C) Solubility (g/1000g water @ 20°C) Log Kow 0.38 0.267 0.136 0.01 0.009 - 2.1 0.72 0.351 0.059 0.028 - 2.12 2.64 3.01 3.84 4.16 (est.) 7.23 (est. Lauryl) C12-15 Alkyl Benzoate C16-17 Alkyl Benzoate Stearyl Benzoate Behenyl Benzoate Isopropyl Benzoate Isobutyl Benzoate 68411-27-8 667900-05-2 10578-34-4 103403-38-9 939-48-0 120-50-3 Molecular Weight (g/mol) Boiling Point (°C) Density (g/cm3) 290.44-332.52 346.55-360.57 374.60 430.71 164.20 178.23 363 (est.) - 433 (est.) 518.3 266 237 - - - 0.908 - 1.02 Vapor pressure (mm Hg @ 20°C) Solubility (g/1000g water @ 20°C) Log Kow 0.00001 (est.) - 0.00000006 (est.) 0.00000000007 0.161 (est.) 0.0417 (est.) 0.000009 (est.) - 0.000009 (est.) 0.0000007 0.126 (est.) 0.098 (est.) 7.23 (est.) - 10.18 (est.) 13.35 3.18 3.23 (est.) Isostearyl Benzoate Ethylhexyl Benzoate Butyloctyl Benzoate Hexyldecyl Benzoate Octyldodecyl Benzoate 34364-24-4 5444-75-7 188038-97-3 163883-40-7 108347-89-3 374.60 234.33 290.44 346.55 402.65 426 (est.) 169-170 (at 20 mmHg) 376.9 434.8 449 (est.) - 0.91 0.939 0.923 - CAS No. CAS No. Molecular Weight (g/mol) Boiling Point (°C) Density (g/cm3) Vapor pressure 0.0000001 0.0005 (est.) 0.000007 0.00000009 0.00000002 (est.) (mm Hg @ 20°C) 0.00058 0.000015 0.000001 (est.) 0.00001 0.0011 Solubility (g/1000g water @ 25°C) Log Kow 10.10 (est.) 5.7 (est.) 7.857 9.982 11.09 (est.) est.= Values were estimated using the EPI Suite, Version 4.0 program or Advanced Chemistry Development (ACD/Labs) Software V11.02. - Not found 9 CIR Panel Book Page 16 Table 3. Frequency of use according to duration and exposure.15,16 Use type Total/range Duration of use Leave-on Rinse-off Exposure type Eye area Possible ingestion Inhalation Dermal Deodorant (underarm) Hair – noncoloring Hair – coloring Nail Mucous Membrane Bath products Infant Total/range Duration of use Leave-on Rinse-off Exposure type Eye area Possible ingestion Inhalation Dermal Deodorant (underarm) Hair – noncoloring Hair – coloring Nail Mucous Membrane Bath products Infant Total uses/use type 36,808 Concentration Uses (%) C12-15 Alkyl benzoate 971 0.0008-50 Concentration Uses (%) C16-17 Alkyl benzoate 2 0.7 Concentration Uses (%) Ethyl benzoate 0.0008-0.01 Concentration Uses (%) Isobutyl benzoate 0.01 23,788 13,020 858 113 0.0008-35 0.3-50 2 0.7 - 0.0008-0.01 - - 0.01 - 3663 69 0.0008-11 - - - - - - 872 66 3-16 - - - - - - 3447 26,863 25 870 0.3-12 0.0008-50 2 0.7 - 0.003-0.01 0.0008-0.01 - 0.01 0.01 623 6 0.004 - - - - - - 5687 98 0.3-35 - - - - - - 2808 674 2 0.5-2 0.008-10 - - - - - - 3732 12 0.01-0.04 2 0.7 - - - - 745 357 9 10 - - - - - - 36,808 Isostearyl benzoate 1 1 - Methyl benzoate 0.0005-0.3 23,788 13,020 1 - - - 0.007-0.3 - 3-4 3 - 2 - 3663 - - - 0.0005-0.3 - - - - 872 - - - - - - - - 3447 26,863 1 1 - - 0.3 0.0005-0.3 - 3-4 1 2 623 - - - 0.004 - - - - 5687 - - - - - - - - 2808 674 - - - - - - - - 3732 - - - - - 3 - - 745 357 - - - - - 2 - 10 CIR Panel Book Page 17 Octyldodecyl benzoate 3-4 Stearyl benzoate 3 2 Figure 1. Straight chain alkyl benzoates: structures, esterase metabolism, and metabolites. 11 CIR Panel Book Page 18 Figure 2. Branched-chain alkyl benzoates: structures, esterase metabolism, and metabolites. Legend Ingredients which are part of this review Safe as used * Not in ICI Dictionary and Handbook, 13th Ed. **under Ingredients which are concurrently review in another report Result of Esterase metabolism O Benzoic acid ** OH **Isopropyl alcohol Isopropyl benzoate O CH3 HO CH3 CH3 O Isobutyl alcohol HO CH3 O * Isobutyl benzoate CH3 O CH3 CH3 CH3 Isostearyl benzoate O (one example of the mixture of branched chains) CH3 O CH3 Isostearyl alcohol CH3 HO CH3 O Ethylhexyl alcohol * HO Ethylhexyl benzoate O CH3 CH3 O Butyloctyl alcohol Butyloctyl benzoate CH3 O * HO CH3 CH3 CH3 CH3 CH3 O Hexyldecyl alcohol * HO Hexyldecyl benzoate CH3 O CH3 CH3 CH3 O Octyldodecyl alcohol * HO Octyldodecyl benzoate CH3 O CH3 CH3 CH3 Figure 3. The synthesis of butyl benzoate. O O OH HO CH3 H2SO4 Δ 12 CIR Panel Book Page 19 O CH3 REFERENCES 1. Andersen FA. Final report on the safety assessment of benzyl alcohol, benzoic acid, and sodium benzoate. International Journal of Toxicology. 2001;20(Suppl 3):23-50. 2. Andersen, F. A. Final Report on the Safety Assessment of Methyl Alcohol. International Journal of Toxicology. 2001;20((Suppl. 1)):57-85. 3. Andersen, F. A. Alcohol Denat., including SD Alcohol 3-A, SD Alcohol 30, SD Alcohol 39, SD Alcohol 39-B, SD Alcohol 39-C, SD Alcohol 40, SD Alcohl 40-B, and SD Alcohol 40-C, and the Denatonium Bezoate, Quassin, and Brucine Sulfate/Brucine. 2008 CIR Compedium. 2005;9-12. 4. Andersen, F. A. n-Butyl Alcohol Amended Report. 2008 CIR Compedium. 2005;49-51. 5. Elder RL. Final report on the safety assessment of cetearyl alcohol, cetyl alcohol, isostearyl alcohol, myristyl alcohol, and behenyl alcohol. Journal of the American College of Toxicology. 1988;7(3):359-413. 6. Elder, R. L. Final Report on the Safety Assessment of Cetearyl Alcohol, Cetyl Alcohol, Isostearyl Alcohol, Myristyl Alcohol, and Behenyl Alcohol. Journal of the American College of Toxicology. 1988;7(3):359-413. 7. Elder, R. L. and El. Final Report on the Safety Assessment of Stearyl Alcohol, Oleyl Alcohol, and Octyl Dodecanol. Journal of the American College of Toxicology. 1985;4(5):1-29. 8. Riemenschneider, W. Organic Esters. 2002. 6th:(12): pp.305-328. New York: Wiley-VCH. 9. Richard J Lewis Sr. Hawley's Condensed Chemical Dictionary. 2007. 10. Robert S.Huss, Fengrong Chen, Michael F.Malone, and Michael F.Doherty. Reactive Distillation for Methyl Acetate Production. Computers and Chemical Engineering. 2003;271855-1866. 11. Falbe, J., Bahrmann, H., Lipps, W., and Mayer, D. Aliphatic Alcohols. 2002. 6:(2): pp.19-46. New York: Wiley-VCH. 12. T.Veit. Biocatalysis for the Production of Cosmetic Ingredients. Engineering in Life Sciences. 11-2-2004. 4:(6): pp.508-511. 13. Sales specification sheet. Vertellus Specialties. 2010. 14. International Programme on Chemical Safety.Butyl Acetates. http://www.inchem.org/documents/cicads/cicads/cicad64.htm. Accessed 1120-2009. 15. Food and Drug Administration (FDA). Frequency of use of cosmetic ingredients. FDA Database. 2010. Washington, DC: FDA. 16. Personal Care Products Council. 7-8-2010. Concentration of use C12-15 alkyl benzoate, amyl benzoate, behenyl benzoate, butyl benzoate, butyloctyl benzoate, C16-17 benzoate, ethyl benzoate, ethylhexyl benzoate, hexydecyl benzoate, isobutyl benzoate, isopropyl benzoate, isostearyl benzoate, lauryl/myristyl benzoate, methyl benzoate, octyldodecyl benzoate, propyl benzoate and stearylbenzoate. 17. Commission of the European Comunities. COMMISSION DIRECTIVE 2007/17/EC of 22 March 2007 amending Council Directive 76/768/EEC, concerning cosmetic products, for the purposes of adapting Annexes III and VI thereto to technical progress . 2007. Commision Directive 2007/17/EC: 18. Adams TB, Cohen SM, Doull J, Feron VJ, Goodman JI, Marnett LJ, Munro IC, Portoghese PS, Smith RL, Waddell WJ, and Wagner BM. The FEMA GRAS assessment of benzyl derivatives used as flavor ingredients. Food and Chemical Toxicology. 2005;431207-1240. 19. Dahl, A. R., Miller, S. C., and Petridou-Fischer, J. Carboxylesterases in the respiratory tracts of rabbits, rats and Syrian hamsters. Toxicol Lett. 1987;36(2):129-136. 20. Longland, R. C., Shilling, W. H., and Gangolli, S. D. The hydrolysis of flavouring esters by artificial gastrointestinal juices and rat tissue preparations. Toxicology. 1977;8(2):197-204. 21. Kirk-Othmer Concise Encyclopedia of Chemical Technology. 4 ed. New York, NY: Wiley, 2001. 22. Shen, Y. and West, C. Toxicity of aromatic aerobic biotransformation products of toluene to hela cells. Bulletin.of Environmental.Contamination.and Toxicology. 1998;60(2):177-184. 23. Chipley, J. R. and Uraih, N. Inhibition of Aspergillus growth and aflatoxin release by derivatives of benzoic acid. Appl.Environ.Microbiol.%1980., Aug. 40(2):352-7.(2:352-7):Applied. 24. Graham BE and Kuizenga MH. Toxicity studies on benzyl benzoate and related benzyl compounds. Journal of Pharmacology and Experimental Therapeutics. 1945;84358-362. 13 CIR Panel Book Page 20 25. Jenner PM, Hagan EC, Taylor JM, Cook EL, and Fitzhugh OG. Food flavorings and compounds of related structure I. Acute oral toxicity. Food Cosmet.Toxicol. 1964;2327-343. 26. Kravets-Bekker AA and Ivanova OP. Sanitary-toxicological characteristics of methyl benzoate and potassium benzoate. Farmacevtski Vestnik. 1970;2125-129. 27. Smyth Jr.HF, Carpenter CP, and Weil CS. Range finding toxicity data: List V. Archives of Industrial Hygiene and Occupational Medicine. 1954;4119-122. 28. Merriman TN. An acute dermal toxicity study in rabbits with methyl benzoate (C-2000) Final report. Springborn Laboratories, Inc. 1995. Report No. 3206.347. 29. Smyth Jr.HF, Carpenter CP, and Weil CS. Range finding toxicity data: List IV. Archives of Industrial Hygiene and Occupational Medicine. 1951;4119-122. 30. Shtenberg AJ and Ignat'ev AD. Toxicological evaluation of some combinations of food preservatives. Food Cosmet.Toxicol. 1970;8369-380. 31. Sodemoto Y and Enomoto M. Report of carcinogenesis bioassay of sodium benzoate in rats: absence of carcinogenicity of sodium benzoate in rats. Journal of Environmental Pathology and Toxicology. 1980;487-95. 32. Skin Research Dpt. 2005. Assessment of the eye irritating potential of a cosmetic product (body lotion containing 0.95% isostearyl benzoate) through alternative methods to the Draize test. 33. Branca, M., Garcovich, A., Linfante, L. D., Macrì, A, Mantovani, A., Olivetti, G., and Salvatore, G. Macro- and microscopic alterations in 2 rabbit skin regions following topically repeated applications of benzoic acid n-alkyl esters. Contact Dermatitis.%1988., Nov. 1988;19(5):320-34.(5:320-34):Contact. 34. Onodera H, Ogiu T, Matsuoka C, Furuta K, Takeuchi M, Oono Y Kubota T, Miyahara M, Maekawa A, and Odashima S. Studies on effects of sodium benzoate on fetuses and offspring of Wistar rats. Bull Nat Inst Hyg Sci. 1978;9647-55. 35. Verrett MJ, Scott WF, Reynaldo EF, Alterman EK, and Thomas CA. Toxicity and teratogencity of food additive chemicals in the developing chicken embryo. Toxicol Appl Pharmacol. 1980;56265-273. 36. Morgareidge K. Teratologic evaluation of FDA 71-37 (sodium benzoate). U.S. Food and Drug Administration. 1972. Report No. PB-221 777. 37. Zeiger, E., Anderson, B., Haworth, S., Lawlor, T., and Mortelmans, K. Salmonella mutagenicity tests: V. Results from the testing of 311 chemicals. Environ.Mol.Mutagen.%1992.;19.Suppl 21:2-141. 1992. 38. Szybalski W. Special microbial systems. II. Observations on chemical mutagenesis in microorganisms. Annals of the New York Academy of Sciences. 1958;475-489. 39. Andersen FA. Final report on the safety assessment of benzyl alcohol, banzoic acid, and sodium benzoate. International Journal of Toxicology. 2001;20(Suppl. 3):23-50. 40. Jansson T, Curvall M, Hedin A, and Enzell CR. In vitro studies of biological effects of cigarette smake condensate. II. Induction of sisterchromatid exchanges in human lymphocytes by weakly acidic, semivolatile constituents. Mutation Research. 1986;169129-139. 41. Results of recent studies on the relevance of various short-term screening tests in carcinogenicity evaluation. 1980. The Predictive Value of Short-Term Screening Tests in Carcinogencity Evaluation. Williams GM, Kroes R, Waaijers HW, and van de Pol KW. 42. Kuboyama N and Fujii A. Mutagenicity of analgesics, their derivatives, and anti-inflammatory drugs with S-9 mix of several animal species. J Nihon Univ Sch Dent. 1992;34(3):183-195. 43. McCAnn J, Choi E, Yamasaki E, and Ames BN. Detection of carcinogens as mutagens in the Salmonella/microsome test: Assay of 300 chemicals. Proceedings of the National Academy of Sciences USA. 1975;72(12):5135-5139. 44. Cooperative programe on short-term assays for carcinogencity in Japan. 1980. Molecular and Cellular Aspect of Carcinogen Screening Tests. Montesano R, Bartsch H, and Tomatis L. Lyon, France: International Agency for Research on Cancer Scientific Publications. 45. Consumer Product Testing Co. 48 Hour patch test of C-SAT 020093 (C12-15 Alkyl benzoate). 2003. Report No. C02-1224.01.04. pp. 1-10. 46. Consumer Product Testing Co. Repeated insult patch test of C-SAT 020093 (C12-15 alkyl benzoate). 2003. Report No. C02-1224.01.04. pp. 1-14. 47. Consumer Product Testing Co. 2005. Repeated insult patch test of a body lotion containing 0.95% isostearyl benzoate. Experiment reference number C05-0728.01. 14 CIR Panel Book Page 21 48. Personal Care Products Council. 2010. Summary of an HRIPT of a Shaving Cream Product containig 4% octyldodecyl benzoate. 49. The Merck Index. http://themerckindex.cambridgesoft.com/TheMerckIndex/index.asp. Accessed 10-20-2009. 15 CIR Panel Book Page 22 Data Personal Care Products Council Committed to Safety, Quality & Innovation Memorandum TO: F. Alan Andersen, Ph.D. Director COSMETIC INGREDIENT REVIEW (CIR) - FROM: John Bailey, Ph.D. Industry Liaison to the Cifi Expert Panel DATE: July 9, 2010 SUBJECT: Summary of an HRIPT of a Shaving Cream Product containing 4% Octyldodecyl Benzoate A shaving cream product, containing 4% Octyldodecyl Benzoate, was tested in an NRIPT by a 3rd party testing facility. The test included 105 panelists, was semi-occlusive, and the product was diluted to a 10% aqueous solution before application. The results of HR]PT “did not demonstrate a potential for eliciting dermal irritation or sensitization.” More specifically, for all 105 panelist no visible skin reaction was observed over the testing period. 11011 7th Street, N.W., Suite 300 Washington, D.C. 20036-4702 202.331.1770 CIR Panel Book Page 23 202.331.1969 (fax) www.personalcarecouncil.org Personal Care Products Council Committed to Safety, ua ty nnovation Memorandum TO: F. Alan Andersen, Ph.D. Director COSMETIC INGREDIENT REVIEW (CIR) - -‘FROM: ‘JohnBai1ey,Ph.D Industry Liaison to the CIR Expert Panel DATE: July9, 2010 SIJEJECT: Studies of C 12-15 Alkyl Benzoate Cognis. 2007. Cetiol AB (C 12-15 Alkyl Benzoate) data sheet. Cognis. 2002. UV absorption spectrum of Cetiol AB (C 12-15 Alkyl Benzoate). Consumer Product Testing Co. 2003. 48 Hour patch test of C-SAT 020093 (C 12-15 Alkyl Benzoate). Experiment Reference Number C02- 1224.01.04. Consumer Product Testing Co. 2003. Repeated insult patch test of C-SAT 020093 (C 12-15 Alkyl Benzoate). Experiment Reference Number C02- 1225.01. 11011 7th Street, N.W., Suite 3O0 Washington, D.C. 20036-4702 202.331.1770 CIR Panel Book Page 24 202.331.1969 (fax) www.personalcarecouncil.org cgnisUom caIs CETIOL® AB Labeling information INCI name(s) Cl 2-15 Alkyl Benzoate (EU 200612571EC) Cl 2-15 Alkyl Benzoate (CTFA) Registrations Ingredient CASR-No. 6841.1 -27-8 EINECS/ELINCS-No. 270-112-4 Officially listed in I Quality conforms to JCIC: 012-15 Alkyl Benzoate (Ingredient Code 512004) Product properties Appearance Cetiol® AB is a clear, almost colourless, almost odourless oil. Example of use Cetiol® AB is a traditional emollient for modern skin care applications. Particularly suitable for suncare formulations due to its outstanding solubilizing capacities for crystalline UV filters as well as dispersing properties for pigments. Characteristic values The specifications stated in the paragraphs ‘Quality control data and Additional product descriptive data’ finally and conclusively describe the properties of the Product. Provisional quality control data (Data which is used for quality release and is certified for each batch.) Appearance conforms to standard Odour conforms to standard Acid value max. 0.5 mg KOH/g ISO 660 Saponification value 172- 182 mg KOH/g ISO 3657 Colour value (APHA) max. 50 ISO 6271 Density (20°C) 0.920 0.940 g/ml ISO 2811-3 Refractive index (20°C) 1.4830 1.4870 ISO 6320 Water (Karl Fischer) max. 0.3 ISO 4317 - - Provisional additional product descriptive data (Data which is proven statistically but not determined regularly.) Viscosity (20°C) max. 30 mPas Cloud point max. 5°C - ISO 12058-1 ISO 3015 Revision-No. 2-08.2007 All products in the text marked with an ® are trademarks of the Cognis group. The information on product specifications provided herein is only binding to the extent confirmed by Cognis in a written Sales Agreement. COGNIS EXPRESSLY DISCLAIMS ANY RESPONSIBILITY FOR THE SUITABILITY OF THE PRODUCTS FOR ANY SPECIFIC OR PARTICULAR PURPOSES INTENDED BY THE USER. Suggestions for the use and application of the products and guide formulations are given for information purposes only and without commitment. Such suggestions do not release cognis’ customers from testing the products as to their suitability for the customer’s intended processes and purposes. Cognis does not assume any liability or risk involved in the use of its products as the conditions of use are beyond its control. The user of the products is solely responsible for compliance with all laws and regulations applying to the use of the products, including intellectual property rights of third parties. IB.08.2008 CETIOLrABE CIR Panel Book Page 25 25 30 35 40 45 50,0 ABS 20 Is 10 5 200,0 250 300 - S 350 I 450 NM I 500 —— Cog-02-07141, Cetiol AB 400 _ C 1 __ 550 650 A I k yI iS 600 2 — e 700,0 CIR Panel Book Page 26 Consumer Product Testing Co. L&E I)75 FINAL REPORT COLQOO —‘p’ CLIENT: Cognis Deutsehiand GmbH & Co. KG. Henkelstr. 67 D-4055 1 Duesseldorf, Germany ATTENTION: Mr. Peter Wierich TEST: 48 Hour Patch Test Protocol No.: CZKH-OOl TEST MATERIALS: .01 .02 .03 .04 C-SAT C-SAT C-SAT C-SAT 020093 (diluted 3% in vegetable oil) 020093 (diluted 10% in vegetable oil) 020093 (diluted 30% in vegetable oil) 020093 j t3e,.oci+C 1 /.Ik EXPERIMENT REFERENCE NUMBER: C02-1224.01-.04 Richard R. Eisenberg, Board Certified Dermatologist - Robert W. Shanahan, Ph.D. Principal Investigator 4yFfank, R.N. ‘study Director This report is submitted for the exclusive use at the person, partnership, or corporation to whom it is addressed, and neither the report nor tie name of these Laboratories nor any member of its staff. may be used in connection with the advertising or sale of any product or process without written authorization. 7() Ntv 1)uth I,rlll(’ • IfirfiC1(I. Ncv ,Jcrsc\’ 07004-2514 • CIR Panel Book Page 27 (973) 808-7111 • 1x (973) 808-7234 Consumer Product Testing Co. [Si. 75 QUALITY ASSURANCE UNIT STATEMENT Study No.: C02-1224.0l-.04 The objective of the Quality Assurance Unit (QAU) is to monitor the conduct and reporting of clinical laboratory studies. These studies have been performed with adherence to ICH Guideline E6 for Good Clinical Practice and requirements provided for in 21 CFR parts 50 and 56 and in accordance to standard operating procedures and applicable protocols. The QAU maintains copies of study protocols and standard operating procedures and has inspected this study on the date(s) listed below. The findings of these inspections have been reported to management and the Study Director. All materials and data pertinent to this study will be stored in the Archive Facility at 70 New Dutch Lane, Fairfield, New Jersey, 07004, unless specified otherwise, in writing by the Sponsor. January 14, 2003 Date(s) of inspection: Senior personnel involved: Laura A. Artiles, M.A. - Manager, Quality Assurance Marie Terlizzese, M.S. Quality Assurance Associate The representative signature of the Quality Assurance Unit signifies that this study has been performed in accordance with standard operating procedures and study protocol as well as government regulations regarding such procedures and protocols. 7() New Dutch Lane • Fairfield. New Jersey 07004-2514 • (973) 808-71 1 I • Fax 197:3) 808-7234 • Toxicology • Analytical Chemistry • Microbiology Clinical CIR Panel Book Page 28 Cognis Deutscbland GmbH & Co. KG. C02-1224.0l-.04 Page 3 Objective: To determine by epidermal contact the primary irritation potential of a test material. Participants: Twenty-two (22) subjects, male and female, ranging in age from 20 to 73 years, who qualified were selected for this evaluation. Twenty-one (21) subjects completed this study. The remaining subject discontinued her participation for personal reasons unrelated to the use of the test materials. Inclusion Criteria: a. Male and female subjects, age a and over. b. Absence of any visible skin disease which might be confused with a skin reaction from the test materials. c. Prohibition of use of topical or systemic steroids andlor antihistamines for at least seven days prior to study initiation. d. Completion of a Medical History form and the understanding and signing of an Informed Consent form. e. Considered reliable and capable of following directions. Exclusion Criteria: a. Ill health. b. Under a doctor’s care or taking medication(s) which could influence the outcome of the study. c. Females who are pregnant or nursing. d. A history of adverse reactions to cosmetics or other personal care products. Test Materials: .01 .02 .03 .04 Study Schedule: Panel # Initiation Date Completion Date 20020613 December 31, 2002 January 3, 2003 C-SAT 020093 (diluted 3% in vegetable oil) C-SAT 020093 (diluted 10% in vegetable oil) C-SAT 020093 (diluted 30% in vegetable oil) C-SAT 020093 aWjth parental or guardian consent CIR Panel Book Page 29 Cognis Deutschland GmbH & Co. KG. C02-1224.0l-.04 Page 4 Methodology: Prior to the initiation of this study, the test material was prepared as 3%, 10%, and 30% dilutions, using vegetable oil. The upper back between the scapulae served as the treatment area. Approximately 0.2 ml of the diluted, as well as an undiluted sample of the test material, or an amount sufficient to cover the contact surface, was applied to the 3/4” x 3/4” absorbent pad portion of adhesive dressings*. When secured to the appropriate treatment site, these dressings formed occlusive patches. The test materials remained in contact with the skin for a total of fortyeight hours. These sites were then evaluated for gross changes. Absence of any visible skin change was assigned a zero value. The test sites were re-evaluated at seventy-two hours. Evaluation Key: 0 = + = 1 2 3 4 Results: = = = = No visible skin reaction Barely perceptible or spotty erythema Mild erythema covering most of the test site Moderate erythema, possible presence of mild edema Marked erythema, possible edema Severe erythema, possible edema, vesiculation, bullae andlor ulceration The results of each participant are appended (Tables 1-4). Observations of all treated areas remained negative throughout the test interval. Summary: Under the conditions of this study, the test material, C-SAT 020093, applied neat and at 3%, 10%, and 30% dilutions in vegetable oil, did not indicate a potential for dermal irritation. *Manufactured by TruMed Technologies, Inc., Bumsville, MN CIR Panel Book Page 30 Cognis Deutschland GmbH & Co. KG. C02-1224.01-.04 Page 5 Table 1 Panel #20020613 Individual Results C-SAT 020093 (diluted 3% in vegetable oil) Subject Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 DNC = Observations 48 Hours 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Did not complete study CIR Panel Book Page 31 72 Hours 0 0 0 0 0 0 0 0 DNC 0 0 0 0 0 0 0 0 0 0 0 0 0 Cognis Deutschland GmbH & Co. KG. C02-1224.01-.04 Page 6 Table 2 Panel #20020613 Individual Results C-SAT 020093 (diluted 10% in vegetable oil) Subject Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 DNC = Observations 48 Hours 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Did not complete study CIR Panel Book Page 32 72 Hours 0 0 0 0 0 0 0 0 DNC 0 0 0 0 0 0 0 0 0 0 0 0 0 Cognis Deutsehiand GmbH & Co. KG. C02-1224.01-.04 Page 7 Table 3 Panel #20020613 Individual Results C-SAT 020093 (diluted 30% in vegetable oil) Subject Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 DNC = Observations 48 Hours 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Did not complete study CIR Panel Book Page 33 72 Hours 0 0 0 0 0 0 0 0 DNC 0 0 0 0 0 0 0 0 0 0 0 0 0 Cognis Deutschland GmbH & Co. KG. C02-1224.0l-.04 Page 8 Table 4 Panel #200206 13 Individual Results C-SAT 020093 Subject Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 DNC = Observations 48 Hours 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Did not complete study CIR Panel Book Page 34 72 Hours 0 0 0 0 0 0 0 0 DNC 0 0 0 0 0 0 0 0 0 0 0 0 0 Cognis Deutsohiand GmbH & Co. KG. C02-1224.01-.04 Page 9 Table 5 Panel #20020613 Subject Data Subject Number Initials Age Sex 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 RC BA JE AR WE CV DC LE CD CO AW PR LD EV TV KS SW PM KH BW LB CW 23 46 57 31 63 35 43 47 20 34 73 55 38 34 36 64 36 43 39 63 56 56 F F F M M F F F F F F M F F M F F M F F F F CIR Panel Book Page 35 Substanz-Verwaltung CRT aktuel?er User IS CNPeter Wierich/OU= DE/OUEMEAIO=Cognis C-SAT-Nr 020093 Chemische Bezeich nung Trivial Name S-GehaIt [%] Losungsmittel (Neben-) Komponenten Verunreinigungen C12/15 Alkylbenzoate Cetiol AB 100 Identiflzierung der Prufsubstanz Herstelldatum Verfallsdatum 01.09.2002 01.09.2003 Batch RIS S’s CAS CD22660003 51 Zi 200670000 lOslich in/suspendierbar n Farbe Aggregatzustand bel RT pH-Wert fluchtig bei RT ParaffinOl, native Ole 68411 -27-8 farbios Flussigkeit Lagerung CCC N.Mertscheit Auftraggeber ProduktbetreuerKleber Gefah renhinweise (z. B. qiftiqlreizend/tzend/entzundIichIexpIosiv) Weitere Informationen zur PrUfsubstanz CIR Panel Book Page 36 C (:92000 - Consumer Product Testing Co. EST, 1970 FINAL REPORT CLIENT: Cognis Deutschland GnibH & Co. KG. Henkelstr. 67 D-4055 I Duesseldorf, Germany ATTENTION: Mr. Peter Wierich TEST: Repeated Insult Patch Test Protocol No.: 1.01 TEST MATERIAL: C-SAT 020093 EXPERIMENT REFERENCE NUMBER: C02-1225.01 Richard R. Eisenberg, MIS. Board Certified Dermatologist Principal Investigator J/Frk, R.N. Study Director This report is submitted for the exclusive use of the person. partnership, or corporation to whom it is addressed, and neither the report nor the name of these Laboratories nor any member of its staff, may be used in connection with the advertising or sale of any product or process without written authorization. 70 New Dutch Lane • Fairfield, New Jersey 07004-2514 • (973) 808-71 11 CIR Panel Book Page 37 • Fax (973) 808-7234 QUALITY ASSURANCE UNIT STATEMENT Study No.: C02-1225.01 The objective of the Quality Assurance Unit (QAU) is to monitor the conduct and reporting of clinical laboratory studies. These studies have been performed with adherence to ICH Guideline E6 for Good Clinical Practice and requirements provided for in 21 CFR parts 50 and 56 and in accordance to standard operating procedures and applicable protocols. The QAU maintains copies of study protocols and standard operating procedures and has inspected this study on the date(s) listed below. The findings of these inspections have been reported to management and the Study Director. All materials and data pertinent to this study will be stored in the Archive Facility at 70 New Dutch Lane, Fairfield, New Jersey, 07004, unless specified otherwise, in writing by the Sponsor. Date(s) of inspection: January 20, 2003 February 26, 2003 February 14, 2003 March 10,2003 March 11, 2003 Senior personnel involved: Richard Hettenbach Senior Director, Regulatory Affairs and Quality Assurance Marie Terlizzese, M.S. Quality Assurance Associate The representative signature of the Quality Assurance Unit signifies that this study has been performed in accordance with standard operating procedures and study protocol as well as government regulations regarding such procedures and protocols. CIR Panel Book Page 38 CognisDeutschland GmbH & Co. KG. C02- 1225.01 Page 3 Objective: To determine by repetitive epidermal contact the potential of a test material to induce primary or cumulative irritation and/or allergic contact sensitization. Participants: One hundered and twelve (112) qualified subjects, male and female, ranging in age from 16 to 79 years, were selected for this evaluation. One hundered and one (101) subjects completed this study. The remaining subjects discontinued their participation for various reasons, none of which were related to the application of the test material. Inclusion Criteria: a. b. c. d. e. Exclusion Criteria: a. b. c. d. a Male and female subjects, age 16 and over. Absence of any visible skin disease which might be confused with a skin reaction from the test material. Prohibition of use of topical or systemic steroids and/or antihistamines for at least seven days prior to study initiation. Completion of a Medical History form and the understanding and signing of an Informed Consent form. Considered reliable and capable of following directions. Ill health. Under a doctor’s care or taldng medication(s) which could influence the outcome of the study. Females who are pregnant or nursing. A history of adverse reactions to cosmetics or other personal care products. Test Material: C-SAT 020093 Study Schedule: Panel # Initiation Date Completion Date 20030013 20030022 January 13, 2003 January 20, 2003 February 21, 2003 February 27, 2003 aWith parental or guardian consent CIR Panel Book Page 39 Cognis Deutschland GmbH & Co. KG. C02-1225.Ol Page 4 Methodology The upper back between the scapulae served as the treatment area. Approximately 0.2 ml of the test material, or an amount sufficient to cover the contact surface, was applied to the 3/4” x 3/4” absorbent pad portion of an adhesive dressing*. This was then applied to the appropriate treatment site to form an occluded patch. Induction Phase: Patches were applied three (3) times per week (e.g., Monday, Wednesday, and Friday) for a total of nine (9) applications. The site was marked to ensure the continuity of patch application. Following supervised removal and scoring of the first Induction patch, participants were instructed to remove all subsequent Induction patches at home, twenty-four hours after application. The evaluation of this site was made again just prior to re-application. If a participant was unable to report for an assigned test day, one (1) makeup day was permitted. This day was added to the Induction period. With the exception of the first supervised Induction Patch reading, if any test site exhibited a moderate (2-level) reaction during the Induction Phase, application was moved to an adjacent area. Applications are discontinued for the remainder of this test phase, if a moderate (2-level) reaction was observed on this new test site. Applications would also be discontinued if marked (3level) or severe (4-level) reactivity was noted. Rest periods consisted of twenty-four hours following each Tuesday and Thursday removal, and forty-eight hours following each Saturday removal. Challenge Phase: Approximately two (2) weeks after the final Induction patch application, a Challenge patch was applied to a virgin test site adjacent to the original Induction patch site, following the same procedure described for Induction. The patch was removed and the site scored at the clinic twenty-four and seventy-two hours post-application *Manufactured by TruMed Technologies, Inc., Burnsville, MN CIR Panel Book Page 40 Cognis Deutschland GmbH & Co. KG. C02-1225.Ol Page 5 Evaluation Key: 0 + 1 2 3 4 Results: = = = = No visible skin reaction Barely perceptible or spotty erythema Mild erythema covering most of the test site Moderate erythema, possible presence of mild edema Marked erythema, possible edema Severe erythema, possible edema, vesiculation, bullae and/or ulceration The results of each participant are appended (Table 1). Observations remained within normal limits throughout the test interval. Summary: Under the conditions of this study, test material, C-SAT 020093, did not indicate a potential for dermal irritation or allergic contact sensitization. CIR Panel Book Page 41 Cognis Deutsehiand GmbH & Co. KG. C02-1225.01 Page 6 Table 1 Panel #20030013 Individual Results C-SAT 020093 Subject Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 24 -* — 24*hr 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 = = 1 2 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 —----- 0 0 0 0. 0 0 0 0 0 0 0 Induction Phase 6 4 5 — 7 8 9 Virgin Challenge Site 24*hr 72br 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 -DID NOT COMPLETE STUDY. 0 0 0 0 0 0 -DID NOT COMPLETE STUDY. —-DID NOT COMPLETE STUDY 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 ----—-----—---DID NOT COMPLETE STUDY 0 0 0 0 0 0 0 0 0 0 0 0 Supervised removal of l Induction and Challenge Patch Subject unable to report as scheduled, instructed to remove patch and report on the next test day. CIR Panel Book Page 42 -* 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 --- 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Cognis Deutschland GmbH & Co. KG. C02-1225.01 Page 7 Table 1 (continued) Panel #200300 13 Individual Results C-SAT 020093 Subject Number 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 24* 1 2 ——---Induction Phase 3 4 6 5 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 24*hr — = 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 — 7 —-- 8 9 Virgin Challenge Site 24*hr 72 hr 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 -----DID NOT COMPLETE STUDY---0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0’ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 DID NOT COMPLETE STUDY 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o 0 o 0 0 0 0 0 0 0 0 0 0 0 0 0 DID NOT COMPLETE STUDY--0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Supervised removal of 1 Induction and Challenge Patch CIR Panel Book Page 43 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Cogiiis Deutsohiand GmbH C02-1225.01 Page 8 & Co. KG. Table 1 (continued) Panel #20030022 Individual Results C-SAT 020093 Subject Number - 0 0 0 0 0 24* * W 24*hr 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - —-—-—----— = = = 1 2 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 + 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Induction Phase--—--— 4 6 7 5 0 0 0 0 0 0 0 0 0 O 0 O o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 O 0 O O 0 0 0 0 0 0 0 0 0 0 0 0 o O 0 0 0 0 ——— —-—-- 8 Ow 9 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Ow 0 o 0 o 0 0 0 0 0 0 0 0 0 0 0 0 Ow 0 0 0 DID NOT COMPLETE STUDY 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 ow 0 o 0 Ow 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 ow t1nduction and Challenge Patch Supervised removal Subject not present for supervised patch removal Observation recorded 96 hours post challenge application. Subject unable to report as scheduled. Inclement weather. Subject unable to report as scheduled and was instructed to report on the next scheduled test day. CIR Panel Book Page 44 Virgin Challenge Site 24*1w 721w O 0 O O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0* 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o o o O 0 0 o 0 0 0 0 o o 0 Cognis Deutsehiand GinbH & Co. KG. C02-1 225.01 Page 9 Table 1 (continued) Panel #20030022 Individual Results C-SAT 020093 Virgin Challenge Subject Number 29 30 0 0 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 24* DNC W 24*hr 0 0 0 0 0 0 0 0 0 0 31 32 33 34 35 36 37 38 39 40 41 = = = 1 2 3 Induction Phase--—----— 7 6 5 4 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o o o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 —----—---—---—--— - o o o o o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o o ------ 0 0 0 + 0 — 8 —-- 9 0 0 0 0 0 Ow 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NOT COMPLETE STUDY DID 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 DID NOT COMPLETE STUDY--0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Supervised removal of l Induction and Challenge Patch Did not complete study Inclement weather. Subject unable to report as scheduled and was instructed to report on the next scheduled test day. CIR Panel Book Page 45 Site 24*hr 72 hr O 0 0 O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Cognis Deutschland GmbH & Co. KG. C02-1225.01 Page 10 Table 2 Panel #20030013 Subject Data Subject Number Initials Age Sex I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SC TJ JS WF AL DK DW CC WM CS TM AT NP RA LS MM SV EM SM MT FP ID CT DE PR PF TM AS 54 33 51 49 56 44 46 66 34 41 74 27 35 36 39 33 33 46 26 58 63 79 34 47 63 77 69 70 F M F F F F F F F F F F M F F M M F F F F F F F F F F F CIR Panel Book Page 46 Cognis Deutschland GmbH & Co. KG. C02-1225.01 Page 11 Table 2 (continued) Panel #20030013 Subiect Data Subject Number Initials Age Sex 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 ES SE NE PH MR DN RG AT QA RG GG MG AA DM MM KF KP PC DK DT SK SM YL KG JS JP BC JM ‘39 50 18 31 36 21 45 58 49 55 67 31 45 47 44 45 45 36 19 31 45 55 39 38 62 53 35 66 M F F F F F M M F F M F M F F F F F F F F F M F M M M M CIR Panel Book Page 47 Cognis Deutschland GmbH & Co. KG. C02-1225.01 Page 12 Table 2 (continued) Panel #20030022 Subject Data Subject Number Initials Age Sex 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TC KF AK EH KC AC DD FD BT LC GT MW LG JB JG BH PS MV JC JS PS DM DF SB VS JD LF IC 18 45 72 51 23 27 47 53 46 32 40 48 40 16 44 25 28 47 45 44 17 22 69 52 28 42 36 59 F F F M F M F M F F F F F F M M F F F F M M F F F M F F CIR Panel Book Page 48 Cognis Deutschland GmbH & Co. KG. C02-1225.0l Page 13 Table 2 (continued) Panel #20030022 Subject Data Subject Number Initials 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 PH RN 1V GD VA ES DS RC PS ML EA GA SM SS WB JC DR LR PD PL TB CA CS EH EA CC AS SW Age Sex 58 74 52 47 48 48 39 63 26 .67 41 27 40 51 39 74 36 69 63 73 53 37 31 68 63 55 34 52 M F F F M M F M F F F M F F F F F F F F M F F M F F F F CIR Panel Book Page 49 Substanz-Verwaltung CRT aktueller User CN=Peter Wierich!OU=DE/OU=EMEAIO=Cognis C-SAT-Nr 020093 Chemische Bezeichnung rrivial Name S-Ge halt [%) LOsungsmittel (Neben-) Komponenten Verunreinigungen C12115 Alkylbenzoate Cetiol AB 100 Identifizierung der Prufsubstanz Herstelldatum Verfallsdatum 01.09.2002 01.09.2003 Batch RIS sLs CAS CD22660003 51 ZI 200670000 lslich inlsuspendierbar in Farbe Aggregatzustand bei RT pH-Wert flochtig bei RT ParaffinOl, native Ole 68411 -27-8 farblos FlOssigkeit I Lagerung CCC N.Mertscheit Auftraggeber ProduktbetreuerKleber Gefahrenhinweise (z.B. giftig/reizend!Lzend/enUndIich/expIosiv) Weitere Informationen zur PrUfsubstanz CIR Panel Book Page 50 Personal Care Products Council Committed to Safety, Quality & Innovation Memorandum TO: F. Alan Andersen, Ph.D. Director COSMETIC INGREDIENT REVIEW (CW) - FROM: John Bailey, Ph.D. Industry Liaison to the CIR Expert Panel DATE: July 9, 2010 SUBJECT: Studies on a Body Lotion Containing 0.95% Isostearyl Benzoate Consumer Product Testing Co. 2005. Repeated insult patch test of a body lotion containing 0.95% Isostearyl Benzoate. Experiment Reference Number C05-0728 .01. Skin Research Dpt. 2005. Assessment of the eye irritating potential of a cosmetic product (body lotion containing 0.95% Isostearyl Benzoate) through alternative methods to the Draize test. Report reference: CTOXJO5 161. 1101 17th Street, N.W., Suite 30O Washington, D.C. 20036-4702 202.331.1770 CIR Panel Book Page 51 I 202.331.1969 (fax) www.personakarecouncil.org Consumer Product Testing Co. I-sr FINAL RE PORT CLIENT: - ew Jersey 07950-2451 ATTENTION: James Flanagan Sr. Cherr4ist Microbiology TEST: Repeated Insult Patch Test ProtocoiNo.: 1.01 TEST MATERIAL: i Body Lotion TL45-.24-2 • EXPERIMENT REFERENCE NUMBER: 9ç irJ i3irnzc’c1-c C05-072.01 Richard R. Eisenberg, M.D. Board Cprtified Dermatologist P-ank, (‘xeLitive Vice President, Clinical Evaluations Report Date: ‘O// 472 This report is submitted Jor the exetusive use of the person, parfnershi4, or corporation to whom it ‘a addressed, and neither the report nor the nrrrne of these Laboratories 001 any membor of its staff, may be use in corinsciron with the edverltsin ot safe of any pcoduct or process wittiest written authorization () N(v IhItcIl Lant • Iiirfirki New ,Jers t45 14 t$73) O-7 II CIR Panel Book Page 52 Iax (97;lf 8O-7234 Consumer Product Testing Co. QUALITY ASSURANCE UNIT STATEMENT Study No.: C05-0729.01 The objective of the Quality Assurance Unit (QkU) is to monitor the conduct and reporting of clinical laboratory studies. These studies have been performed with adherence to the applicable ICH Guideline E6 for Good Clinical Practice and requiremenuts provided for in 21 CFR parts 50 and 56 and in accordance to standard operating procedures and applicable protocols. The QAU maintains copies of study protocols and standard operating procedures and has inspected this study. All data pertinent to this study will be stored in the Consumer Product Testing Company archive, unless speciiied otherwise, in writing by the Sponsor. Quality Assurance personnel involved: )cdkô Qu ty Assurance /o/i4 Date The representative signature of the Quality Assurance Unit signifies that this study has been performed in accordance with standard operating procedures and study protocol as well as government regulations regarding such procedures and protocols. 70 New Duth Lane FirfieIc1, New Jersw O704-2 14 973) 8Q-7 I 11 • Fax ($73) 8O87234 (linicI • Toxicology \fliI\tiCI Chcmiry Microbiology CIR Panel Book Page 53 Page 3 Objective: To determine by repetitive epidermal contact the potential of a test material to induce primary or cumulative irritation and!or allergic contact sensitization. Participants: One hundred fifteen (115) qualified subjects, male and female, ranging in age from 16 to 78 years. rere selected for this evaluation. One hundred seven (107) subjects completed this study. The remaining subjects discontinued their participation for various reasons, none of which were related to the application of the test material. Inclusion Criteria: a. b. d. e. Exclusion Criteria: a. b. c. d. a Male and female subjects, age 16 and over. Absence of any viibIe skin disease which might be confused with a skin reaction from the test material. Prohibition of use of topical or systemic steroids andlor antihistamines for at least seven dkys prior to study initiation. Completion of a Medical History form and the understanding and signing of an Informed Consent form. Considered reliable and capable of following directions. 01 health. Under a doctor’s care or taking medication(s) which could influence the outcome of the study. Females who are pregnant or nursing. A history of advçrse reactions to cosmetics or other personal care products. Test Material: Study Schethile: Body Lotion TL45-24-2 Panel # 1nitiaton Date Completion Date 20050393 20050401 Augut 15. 2005 August 17, 2005 September 23, 2005 September 29, 2005 ‘With parental or guardian consent CIR Panel Book Page 54 Page 4 Methodology: The upper back between the scapulae served as the treatment area. Approximately 0.2 nIl of the test material, or an amount sufficient to cover the contact surface, vas applied to the 1’ x I’ absorbent pad portion of a clear adhesive dressijg*. This was then applied to the appropriate treatment site to form a semi-o4elusive patch. Induction Phase: Patches were applied three (3) times per week (e.g., Monday, Wednesday, and Friday) for a totai of nine (9) applications. The site was marked to ensure the continuity of patch application. Following supervised removal and scoring of the first Induction patch, participants were instructed to remove all subsequent lnductioa patches at home, twenty-thur hours after application. The evaluation of this site was made again just prior to re-application. If a participant was unabl to report for an assigned test day, one (1) makeup day was permitted. This day was added to the Induction period. It was noted that due to a holiday weekend, which occurred during the Induction Phase, subjects who requited a makeup day experienced a delay between applications. With the exception of the first supervised Induction Patch reading, if any test site exhibited a moerate (2-level) reaction during the Induction Phase, application was moved to an adjacent area. Applications are discontinued for the remainder of this test phase, if a moderate (2-level) reaction was observed on this new test site. Applications would also be discontinued if marked (3level) or severe (4-level) reactivity was noted. Rest periods consisted of twenty-four hours following each Tuesday and Thursday removal, and forty-eight hours following each Saturday removal. Chaliene Phase: Approximately two (2) weeks after the final Induction patch application, a Challenge patch was. applied to a virgin test site adjacent to the original Induction patch site, following the same procedure described for Induction. The patch was removed and the site scored at the clinic twenty-four and seventy-two hours post-application. *Manufacred by TruMed Technologies, Inc., Burnsville, MN CIR Panel Book Page 55 Page 5 Evaluatkrn Key: 0 = + = = 2 3 4 Results: = = No visible skin eaction Barely perceptible or spotty eiythema Mild erythema covering most of the test site Moderate erythena, possible presence of mild edema Marked erythema, possible edema Severe erythemà, possible edema, vesiculation, bullae and/or ulceration The results of each participant are appended (Table 1). With one exception, observations remained negative throughout the test interval. it was noted that Subject #25, Panel #20050393, exhibited numerous reactions during the Induction Phase and moderate (2) to barely perceptible (+) responses post-challenge application. This subject also reacted to a number of test materials on this shared panel. Although his medical profile does not reflect a histoly of allergies, it is the Laboratory’s opinion that he is a reactive individual. He will be prohibited from participation in future patch tests. Suimuary: Under the conditions f this study, test material, Body Lotion TL45-24-2, did not irdicate a clinically significant potential for dermal irritation or allergic contact sensitization. CIR Panel Book Page 56 Page 6 Table 1 Panel #20050393 1ndiviIua1 Results 1. Subject Number 1 2 3 4 5 6 7 8 9 10 ii 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 24* 24*hr 0 (1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Body Lotion TL45-24-2 —-———-—------—-------hdueticPhase--—-—--—--—-—----—-—---1 2 3 4 5 6 7 8 9 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 Virgin Challenge Site 24*hr 72br 0 0 0 0 Q 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 q 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 O. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 ol o 0 0 0 0 0 0 0 0 0 0 0 0 --—-.-—4———DID NOT COMPLETE STUDY-------—----—— 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 + 1 ÷** 0 0 0 2 1 0 0’ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 4 Supervised removal of l Induction and Challenge Patch 96 hour follow-up evaluation CIR Panel Book Page 57 Page 7 Tb1e I (cotinued) Panel #20050393 individual Results ody Lotion TL45-24-2 Subject Number -----——---------——-------Inductiot Phase 24*hr L 4 6 1_ 3 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 24* 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 —-——----—-- 7 8 9 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 ol 0 0 0 0 0 0 Oj 0 0 0 0 0 0 0 0 0 01 0 0 o 0 0 0 01 0 0 0 0 0 0 0 ---—-—-—---P NOT COMPLETE STUDY0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01 0 0 0 0 0 0 0 0 o 0 0 0 0 0 ol 0 0 0 o 0 0 0 0 0 0 0 0 0 0 0 0 ol o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o 0 0 ol 0 0 OI o 0 0 0 0 0 01 0 0 0 0 Supervised removal of 1 Induction and Challenge Patch CIR Panel Book Page 58 Virgin Challenge Site 24*hr72 hr 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Page 8 Table I (continued) Panel #20050401 Individual Results Body Lotion TL45-24-2 Subiect Number 3 4 6 7 $ 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 26 27 28 29 24* 1 2 3 Induction Phase—----—--—-—-— 4 5 6 7 o 0 0 0 o o o o o o o o o o o o o o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 -— 24*hr o 0 0 0 0 o 0 o 0 o o o o o o o o o o o o o 1 0 0 0 0 0 o o o 0 0 0 — — Virgin Challenge Site 24*hr 72 hr 8 9 0 0 0 —DTD NOT COMPLETE STUDYo• o 0 0 0 o o 0 0 0 o o 0 0 0 o 0 o C) 0 o o C) 0 0 o o 0 0 0 o 0 o 0 0 o o 0 0 0 o o 0 0 0 o o 0 0 0 o o 0 0 0 o o 0 0 0 o o 0 0 0 -DID NOT COMPLETE STUDY •-DID NOT COMPLETE STUDYo 0 0 0 0 o 0 0 0 0 o 0 0 0 0 o O 0 0 0 o o 0 0 0 o 0 0 0 0 o 0 0 0 0 o O 0 0 0 o 0. 0 0 0 o 0 0 0 0 o 0 0 0 0 o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o o o o o o o o o o o o o o 0 0 0 0 0 0 0 0 0 0 0 0 o o o o o o o o — o e Supervised removal of 1 Induction and Challengq Patch CIR Panel Book Page 59 0 0 0 o 0 o o 0 0 o 0 0 o 0 o o 0 o 0 o () 0 o o o o 0 0 Page 9 Table 1 (cohtinued) Panel #20050401 Individual Results Body Lotion TL45-24-2 Subject Number 24*hr 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 24 -----——---------------------Inductio Phase— I 2 3 4 6 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 C) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 000 00 q 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o 0 0 0 0 0 0 o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o 0 0 0 0 0 0 Ô 01 01 01 0! o! 0 0 0 0! 01 0 0 o! 0! 0 0 0 0 0 0 —--—i 0 0 0 —-—— 7 8 9 Virgin Challenge Site 24*hr 72 hr 0 0 0 0 0 0 0 0 0 0 o 0 -1311) NOT COMPLETE TUDY 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o -DID NOT COMPLETE STUDY0 0 0 0 0 0 0 0 0 0 0 0 o o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o 0 0 0 0 0 0 0 0 0 0 0 0 0 o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 DID NOT COMPLETE STUDY-—-—-—— 0 0 0 0 0 0 Supervised removal of 1 Induction and Chal1eng Patch CIR Panel Book Page 60 Page 10 liable 2 Panel 20050393 Subject Data Subject Number Initials 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 LG AK RM VT KL ND BA SF MM EG AG VV HG MA VA GD CD JO MV JM CN AB 3M IV AD RD LZ FS AD 64 45 43 39 40 36 39 53 58 55 22 16 72 16 51 49 25 54 42 24 63 62 68 72 55 70 43 21 53 CIR Panel Book Page 61 M F F F F M F F M F M M M F M F F F F F F M F F M M F M F Coty, Inc. C05-0729.0 1 Page 11 Table 2 (coitinued) Panel #20050393 Subject Data Subject Number Initials 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 GS JD VD AD RW AL JM RC MG LS JD LV GN EM AM RF HP iF TM DC MC DC MC AC EF EV CW — 76 21 73 69 49 77 44 20 66 40 59 72 36 29 60 35 75 70 52 64 30 18 39 57 76 65 75 CIR Panel Book Page 62 F M F M M F M M F F F F F F F F F F F F F F F F F F F Page 12 ‘Fable 2 (continued) Panel #20050401 Subjct Data Subject Number I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Initials JV LP JP LM DD CM AS PR LM CD RT LS AP JH OS SB RB CL JC RV EM BL LD JA MA MP AL AO - Age Sex 66 38 34 48 49 53 58 66 35 65 21 42 57 47 26 30 57 54 31 66 42 43 35 37 52 51 42 46 46 F F F F F F F F F F F F F F F F F M F F F F F M M F F F F CIR Panel Book Page 63 Page 13 Täbie2 (continued) Panel #20050401 Subject Data Subject Number Initials Age Sex 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 AS JS RM SM YV RV CB RF JR RR VR PF DB TP MW JS FF ED AL LL DS AD BR JS JY YC HM JB GZ EH 57 55 35 65 51 26 21 40 30 55 60 37 28 64 71 54 51 45 78 76 67 41 34 39 47 41 77 36 41 58 M F F M F F F M F F M M F F F M M F M F F M F M M F F F F F CIR Panel Book Page 64 • Assessment of the Eye Irritating Potential of a Cosmetic Product through Alternative Methods to the Draize Test Test Product: Reference: TL45-24-2 Body Lotion 10 Report Date: 27 September 2005 Report Ref: CTOXJO5161 o S° S CONCLUSION: Taking into account the responses of the 3 alternative methods used we consider that the estimated Draize classification of the test product might be slightly irritant with Draize score which might range from 0 to 15 According to our experience and with respect to the type of product tested (skin care product), we consider that this product is as well tolerated as products belonging to the same category. According to the estimated Draize score, the following be proposed: warning may “No statement” Olivie OUCET Pharm. Toxicotog UROTOX) Head of Skin esearch Opt ., Skin Research Opt D. Cell Toxicology lab. CIR Panel Book Page 65 p. 1126 TABLE CONTENT 1- INTRODUCTION 2- TECHNICAL INFORMATIONS 21 Product characteristics 2-2 Testing facilities 2-3 Data storage 2-4 Authentication of the study 3- ALTERNATIVE METHODS USED 3-1 The Neutral Red Release (NRR) assay 3-2 The Hens Egg Test on the Chorio-Allantoic Membrane (HET-CAM) 3-3 The Reconstituted human Epithelial Culture (REC) assay 4- RESULTS AND CONCLUSIONS 4-1 NRR assay 4-2 HET-CAM 4-3 REC assay 5- FINAL ASSESSMENT 6- REFERENCES Skin Research Opt Cell Toxicology lab. CIR Panel Book Page 66 p. 21 26 1-INTRODUCTION There is a need to evaluate the eye irritation potential of cosmetic products for purposes of consumer safety and reguatory requirements. For the time being, the Draize rabbit eye test is practically the nly method for determining ocular irritation, which is acceptable to various regulatory groups. For the last few years, a clear desire, based on both ethical and scientific grounds. has been arising to replace the use of nimals, in cosmetic product testing. In that respect, a wide number of in vitro or ex vivo assays have been proposed worldwide as alternatives to the Draize test. Despite the tremendous efforts concentrated either by the Cosmetic Toiletries and Fragrances Association (CTFA) or the European Community (EC) and British Home Office (BHO), none of these alternative methods have been successfully validated. However, in some particular fields suct as eye irritation, it is clear that under the increasing pressure of consumer associations, regulatory agencies tend to be more and more favorable to the use of these methods for safety assessment. For instance, the French government recently registered the Hen’s Egg Test on Chorio-AllantoIc Membrane (HET-CAM) and the Neutral Red Release (NRR) assay as official test methods for determining the irritating potential of cosmetic products (Journal Officiel de Ia République Française, 26112196, Annexe IV; 30/12199, Annexe VI). The aim of this study was to predict the eye irritation potential of formulated products. For that purpose, we developed a particular in vitro>> approach, which combines several alternative methods. Indeed, many international studies have clearly demonstrated the interest of combining at least 2 or 3 alternative methods when assessing eye irritation through in vitro tests. Skin Research Dpi Cell Tox,cology lab. CIR Panel Book Page 67 P. 3/26 Taking into account both the results obtained during the last international validation studies (Balls et a!., 1995; Gettings et aL, 1990; Gettings et at. 1994; Gettings et aL, 1996) and the recent advances in te use of in vitro models we selected as (<relevant>) alternative methods the 3 following in vitro tests: - • - the Neutral Red Release (NRR) assay the Hens Egg Test on the ChorioAllaritoic Membrane (HET-CAM) the Reconstituted Human Epithelial Culture (REC) assay The combination of these different in vitro methods allows the assessment of different end-points and thus explores various types of mechanisms (cytotoxicity, acute vascular effect, toxicokinetic, transepithelial absorption,...) which are generally considered as taking part in the eye irritation phenomena (Rougier et al., 1994). The conclusion of the study results from a global assessment, systematically based on the responses of the 3 methods used, since none single alternative method can predict eye irritation with a sufficient level of safety. Skin Research Dpt — Cell Toxicology lab. CIR Panel Book Page 68 p4/26 2- TECHNICAL INFORMATIONS 2-1 Product characteristics The product Body Lotion, ref. TL45-24-2, was received from the sponsor Morris Plains (USA) on the 16 August 2005. The test product, identified as a skin care froduct, is a white milk, having a pH of 7.2 at 22.2°C. Upon receipt, it was stored at room temperature in the Cell Toxicology Laboratory. An aliquot of the test product was stored ml a specific room of the Skin Research Dpt. According to the internal Skin Research. procedures, it will be kept there for a minimum period of 3 years. 2-2 Testing facilities The test were performed in the Cell Toxicology Laboratory of Skin Research Dpt - 2-3 Data storage All the data relative to the study will be stored in the premises of the Skin Research Dpt for a period of 10 years. Skin Research Opt Cell Toxicølogy lab, CIR Panel Book Page 69 5 1 26 2-4 Authentication of the study I, the undersigned Olivier DOUCET, Director of the Study, certify that this study has been carried out in the oremises of the - — — standard protocol under the responsibility of Myléne LANVIN and Technical Investigators of the Cell Toxicology Laboratory. Olivie OUCET Pharim Toxicolog UROTOX) Head of Skin esearch Opt D. I, the undersigned Mylène LANVIN, Reponsible for the Study, certify that this study has been performed under my supervising in accordance with our internal standard protocol. R arch Assistant Head of Cell Toxcoiogy Dpt We, the undersigned Carine LINOSSIER, Connne THILLQU, Vincent COMTE and Boris MERLIN, Technical Investigators, certify that all the observations and numerical data presented in this document are an accurate reflection of the results obtained during this study. cr4ER Tèehfàal Investigator Cell Toxicology Dpt Vincent COMZ Technical Igvator Cell Skin Research Opt CorirN1OU Tec4&I)rrestigator C5.e1foIogy Dpi Boris MERLIN Technical Inve Cell Cell Toxicology lab. CIR Panel Book Page 70 tor p. 61 26 3- ALTERNATPIE METHODS USED 3-1 The Neutral Red Release (NRR) assay Principle of the method The NRR assay with rabbit cornea cells (SIRC) is a short-term monolayer culture test system in which cells are first exposed to Neutral Red dye (NR) then to the test material. According to the toxicity of the product, the cells are damaged and release their neutral red dye. The neutral red contained in surviving cells was extract with a revelation solution and spectrophotometrically measured. The test product concentration that gives rise to the release of 50% NR dye (NR ) is used as 50 endpoint to reflect the cytotoxicity of the test product. Two stages can be necessary to asses$ the NR 50 of a test product. The first Stage allows the estimation of the NR 50 wheéas the second stage permit to accurately assess the final score. Materials Chemicals: Sodium Dodecyl Sulfate (SDS) and Sodium Chloride (NaCI) were purchased from Sigma Chemical Co. (St Louis, MO, USA). Neutral red dye was supplied by Fluka AG (Buchs, CH). Modified Eagle’s Medium (MEM), fcetal calf serum, antibiotics (penicillin/streptomycin 5000Ul/5000jgIml and fungizon amphotericin B 250jglmI), MEM Non Essential Amino Acids (NEAA) and PhosphateBuffered Saline (PBS) were supplied by lnvitrogen (Cergy-Pontoise, France). Before using, ftal calf serum was maintained in a bain-marie at 56°C during 30 minutes in order to obtain a modified” fcatal calf serUm. Rabbit cornea SIRC cells: Rabbit cornea fibroblasts SIRC (ATCC n°CCL6O) were bought in the United States at ATCC (American Type Culture Collection Rockville, Maryland, USA) through a French supplier (CERDIC, Sophia Antipolis, France). Cells were cultured according to the internal procedures of our laboratory for freezing, unfreezing and subculturing. Briefly, cells were maintained in medium MEM supplemented with 2% antibiotics and 1% MEM Non Essential Amino Acids. This completed medium was extemporaneously supplemented with 10% of ‘rnodified” fcatal calf serum. Cells were incubated in humidified atmosphere at 37°C, 5% CO . 2 Experimental procedure Cell seeding: For treatment, cells were seeded in all the wells of 24-well plates. The plates were incubated for 24 hours at 37°C, 5% CO . 2 Skin Research Dpt Cell Toxicology b CIR Panel Book Page 71 p. 7126 Application of the neutral red dye: The NRR assay was carried out according to the principle of the colorimetric test described by Borenfreund and Puerner (1984, 1985). After incubation, I ml of neutral red solution test, centrifuged before using, was added to each well of the plates. The plates were incubated for 3 hours at 37°C, 5% . 2 Co Test product dilutions: According to the physico-chemical characteristics of the test product, the dilutions ware performed extemporaneously in an hydrophilic (wtv) or a lipophilic substance (w/w). During the first stage, the product was tested diluted at 0%; 5%; 15%; 25%; 35% and 50%. According to this preliminary results, some dilutions were selected for the second stage. The principle is given in the following Table 1. Table 1: Dilutions to be selected for the second stage 1 Stage n°1 NR5O (%) <4 4and6 0.1 1 >6and<13 — >17 and <23 23arid27 >27and<33 33and37 >37anci<46 46 and 50 > 50 Stagen°2 [iIutions to be tested 1 5 %) 5 10 . 5 10 15 5 20 20 25 25 30 30 35 4 10 351 15 25 — 30 35 —____ 50 40 50 60 Slight cytbtoxIcity I Unnecessary Stag2 - Test product application: After incubation for 3 hours, the neutral red solution was removed and I ml of complete culture medium was added in each well of the plate. The plate was maintained at room temperature for 30 minutes. Then each well was rinsed with 2 ml of PBS and 500 p1 of ech test product dilution were added in the same time in two wells of the plate. Aftera 55-second contact (or 25 seconds for the positive control), each well was rinsed with PBS. The plate was gently stirring throughout contact time. Skin Research Dpt Cell Toxicology lab. CIR Panel Book Page 72 p. 8126 Revelation of the cytotoxicity: An ethanol/acetic acid/distilled water solution was then added to each well. The plates were gently stirring during about 15 minutes until having an homogeneous coloration. 200 .iI of the resulting solutions were put, in dupilcate, in the wells of a 96-well plate. Reading: The optical densities (O.D.) were read at 540 nm by using a multi-well spectrophotometer. The ethanol/acetic acid/distilled water solution served as ‘blank’, Control solution application: The positive control (Sodium Dodecyl Sulfate = SDS) was tested diluted at 0%; 0.01%: 0.05%; 0.2% and 0.25%. The dilutions were performed in 0.9% sodium chloride sokition. The dilution 0% which represents the negative control was applied to the cells during 55 seconds whereas the dilutions 0.01%; 0.05%; 0.2% and 0.25% were applied during only 25 seconds. Test scoring: Data were expressed as a percentage of cytotoxicity, compared to the negative control (dilution 0%). The NR 50 was calculated by interpolation from the curve representing the percentage of viability versus the concentration of test product. The cytotoxicity of the product was obtained from the 50 NR according to the scale presented in Table 2. Table 2: Cytotoxicity scale from the NR endpoint % of death obSerVed at the dilution_50% 50 (%) NR > 20 50 > ‘ 25 and 20 and 50 25 Clssiflcation Negligible cytotoxicity (PNI) < 50 Not very important cytotoxicity (SI) COTY Conclusion Slightly cytotoxic (SI) Moderate cytotoxicity (MI) Moderately cytotoxic (MI) Important Cytotoxicity (I) Cytotoxic (I) The conforrrnty of the study was checked bY using a positive control. According to the internal procedure, this study complied if the NR 50 of the positive control ranged from 0.127% to 0.185%. Skin Research Opt Cell Toxicology lab. CIR Panel Book Page 73 p. 9126 3-2 The Hens Egg Test on the Chorio-Allantoic Membrane (HET-CAM) Principle of the method The Het-Cam is an in vitro method used to evaluate the irritant potential of a test material (J.O.R.F., 26/12196, Annexe IV). The test procedure is based on the assessment by a trained person of the immediate effects following application of test product to the chorioallantoic membraneof 10-day-old fertile eggs. The determination of the Net-Cam score, according to the scale described by Luepke (1985, 1986) allows the assessment of the irritating potential of the test product. Materials Chemicals: Sodium Dodecyl Sulfate (SDS) and Sodium Chloride (NaCl) were purchased from Sigma Chemical Co. :(St Louis, MO, USA). Sterilized water for injections (Wi) was purchased from Aguettant Laboratory (Lyon, France). Hen’s eggs: Fresh fertile White Legom hen’s eggs, weighing 50 -65 g, were supplied by INRA (Tours, France). Experimental procedure Upon their arrival, all the defective eggs and eggs which weight is not ranged from 50 to 65 g, were eliminated. The hen’s eggs were incubated at 15°C during at least 48 hours. Then, they were placed, on their long axis, in a rotating incubator under a temperature of 37.5°C ± 1°C; 60% ± 5% relative humidity (Union FrancoSuisse, Evreux, France) for 10 days. The eggshell was removed around the airspace. After a 5 ml saline solution (NaCl 0.9% with distilled water) application and the removal of the inner shell membrane, the vascular chorioallantoic membrane (CAM) was exposed to the air. Test product application: Four eggs are treated with 0.3 ml of the product, tested neat or diluted according to the type of product. Previously maintained at a temperature of 37.5°C, the test product was applied onto the surface of the CAM. After a 20-second contact, the membrane was gently rinsed off by using 5 ml (10 ml or more if necessary) of saline solution kept at 37.5°C. Investigator observations: Observations were achieved by using a specific lamp KL1 500 electronic (SCHOTT, France) emitting a cold and white light. Blood vessels and albumen were continuously observed by a trained person for a 5-minute period. Irritant effects, such as hyperhaemia, haemorrhage and coagulation (opacity and/or thrombosis), were scored according to their occurrence within the test period. Skin Research Dpi Cell Toxicology lab. CIR Panel Book Page 74 p. 10126 Control solutions application: Two eggs treated with a sodium dodecyl sulfate solution in sterilized water for injections (SDS solution) served as positive control while at least 2 eggs treated with saline solution were used as negative controL If the test product was diluted in mineral oil, 2 eggs were treated with this lipophilic diluant to check its Het-Cam score. The irritating effect of the test product (if any) was quantified according to the scoring system described in the French regulaticn (J.O.R.F., 26(12196, Annexe IV) presented in Table 3. Table 3: Hat-Cam scoring syøtem according to Luepke’s scale Vascular effect Q<t3O. Time (t) 30s.<t2min. 2min.<t5min Hyperhaemia 5 3 1 Haemorrhage 7 5 3 Coagulation 9 7 5 For each parameter (Hyperhaemia, Haemorrhage, Coagulation) the individual scores obtained from the 4 eggs were averaged. The sum of these 3 values gave the so called “Het-Cam score” of the test product on a scale ranging from 0 to 21. The magnitude of the eye irritating potential of the test product was then calculated according to the classification developed by Luepke (1985, 1986) and described in the French regulations (J.O.R.F., 26/12/90, Annexe IV), see Table 4. Table 4: Test product classification Hot-Cam score CIasslIcatIofl Score < 1 1 Score < 5 5 Score < 9 Score 9 Practicallynon irritant I SlIghtly imtant Moderately irritant Irritant . COW Conclusion Slightly irntant (SI) Moderately irritant (Ml) Irritant (I) The conformity of the study is checked by using controls. According to the internal procedure, the study complied if the Het-Cam score for the positive control ranged from 15 to 18 and the Hat-Cam score for the negative control ranged from 0 to 1. Skin Research Dpi Cell Toxology lab. CIR Panel Book Page 75 . 11/ 26 3-3 The Reconstituted human Epithellal Culture (REC) assay Principle of the method The REC assay is a cytotoxicity test based on a time course approach. The formulated product is applied onto three-dimensional reconstituted human epithelial cultures, having the feature of the epithelial part of the cornea. The quantification of the test product cytotoxicity is performed through a colorimetric assay: the MIT test (Mosmann, 1983). The determination of a simplified mean cytotoxicity index (SMCI) is used to quantify the time course toxicity for the applied substance, according to the procedure described by Doucet et al. (198). Materials Chemicals: Sodium Dodecyl Sulfate (SDS) and 3-(4, 5-dimethylthiazol-2-yl) 2, 5diphenyltetrazolium bromide (MiT) was purchased from Sigma Chemical Co. (St Louis, MO, USA). Isopropanol was supplied by Carlo Erba (Milan, Italy) and Phosphate—Buffered Saline (PBS) by Invitrogen (Cergy-Pontoise, France). Saline solution and modified culture medium (MCDB 153) were supplied by SkinEthic Laboratories (Nice, France). Reconstituted human Epithelial Cultures (REC): Reconstituted human epithelial cultures were supplied by SkinEthic Laboratories (Nice, France). They were obtained by culturing transformed human keratinocytes (TR146 cell line) derived from squamous carcinoma (Regnier at al., 1987; Rupniak et al., 1985). Experimental procedure Test product application: The product wa tested neat or diluted according to the type of product. Test sample was directly applied onto the apical surface of the epithelial culture. Product was gently spread with a brush. Cultures were treated with the test product in duplicate. The cultures were transferred to a 24-well culture dish, each well containing fresh medium MCDB 15, They were incubated at 37°C, 5%C0 2 / 95% air atmosphere for 1 hour, 3 hours and 24 hours. After each exposure time, cultures were washed with PBS, and the MiT assay (Mosmann, 1983) was performed. After incubation in MiT reagent, the formazari crystals were extracted by isopropariol. Optical densities were read at 540 nm, by using a spectrophotometer (isopropanol served as blank”). Skin Research Dpt - Cell Toxicology lab. CIR Panel Book Page 76 — p. 12126 Control solutions application: For each time, 2 cultures treated with a sodium dodecyl sulfate solution in saline (SDS solution) served as positive control while 2 cultures treated with saline solution were used as negative control. If the test product was diluted in mineral oil, 2 cultures treated with this lipophilic diluant were used also as negative control. The results were expressed as a percentage of cytotoxicity compared with the negative control. The time course of toxicity for the applied product was expressed as a cumulative simplified mean cytetoxicity index (SMCI) calculated over 24 hours, as follows: (%cyt. lh) SMCI + (%cyt. 3h/3) + (%cyt. 24hl24) = 3 with: %cyt. lh = % of cytDtoxicity of the test product after 1 hour. %cyt. 3h % of cytotoxicity of the test product after 3 hours. %cyt. 24h = % of cytotoxicity of the test product after 24 hours. The cytotoxicity of the product was determined according to the classification presented in Table 5. Table 5: Cytotoxicity scale from the SMCI endpoint The conformity of the study is checked y using a positive control, According to the internal procedure, the study compIle only when the SMCI of the positive control lies within the confidence internal range. The product classification in terms of eye irritation results from a global assessment based on the responses of the 3 in vitro itiethods used. The following Table 6 reflects this multi-technical approach and gives information about the proposed safety classification of the test product. This latter is extrapolated from the results of the 3 alternative methods and presented as an estimated Draize classification. Based on this, an attempt is made for issuing somespecific US warnings, Skin Research Dpt Cell Tocology lab. CIR Panel Book Page 77 p. 13/26 CIR Panel Book Page 78 8 ox 3 REC Assay Hot-Cam NRR Assay Score < 24.5 Score >= 9 Score <= 25 Score >= 24.5 Score > 9 Score <= 25 < REC Assay Hot-Cam NRR Assay 15 NRR Assay <= Score < 15 Score < 9 25< Score <= 50 REC Assay Hot-Cam 7.5 Score <7.5 Score <9 Score >50 REC Assay Hot-Cam NRR Assay -____________ In Vitro Threshold Test Method - 50) Strongly Irritant (Draize score : 50.1 110) Irritant (Draize score : 30.1 - Moderately Irritant (Draize score: 15.1 30) Avoid contact with eyes. If contact occurs, flush with water. No statement US Warning Determination of appropriate warning statements. Suitability to market the product has to be considered. This product may cause irritation. Avoid contact with eyes. If contact occurs, flush with plenty of water. It irritation persists, consult a physician. —.-----__-—.------_---------—--—- Slightly lrritant (Draize score :0- 15) Estimated European Draize Classification Table 6 : Table of concordance between the In vitro scores and the estimated Draize classification for skin care products, sun care products, alcoholic products and make-up products. 4- RESULTS AND CONCLUSIONØ 4-1 NRR assay 4-1-1 Summary The Neutral Red Release (NRR) assab’ conducted on rabbit cornea fibrobiasts SiRC is an in vitro method currently used to assess the cytotoxicfty of a test product after a short contact time of the test sibstance with the cells by measuring the neutral red release from pre-loaded cells (Brantom at aL, 1997; Reader et aL, 1989). The cytotocity is revealed by the cncentration of test product (NR) which inhibited of 50% the cell survival and grov.th. n this study, the procedure used was adpted from the protocol described in French regulation as official method for the ssessment of the irritating potential of formulated cosmetic products (JO.RR. 30112199, Annexe VI). Under the experimental conditions used,an NR 5 supehor to 50% was obtained fo the product Body Lotion, ref. TL45-24-2. From this result. the test product was considered slightly cytotoic. 4-1-2 Results Stage 1 Th firct f thic iirv wc inititd in the oremises of the 19 September 2005 and was completed on the 20 Septernber2uu. The test product Body Lotiorli was tested diluted at 0%: 5%: 5%: 25%: 35% and 50% in saline solution. The optical densities and the percentags of viability obtained for the test product and the positive control are presented in Tables 7 and 8 respectie’. The graphic assessment of the NR for the test product and the positive control were presented in Fig. 1 and 2 respectively. Skin Research Dp Cell Toxipoogy lab. CIR Panel Book Page 79 p. 15126 Table 7: Optical densities (O.D.) and cytotoxicity (%) obtained for the test product and the negative control (representing the 0% dilution) during the stage n°1 (O.D.) and cytotoxicity (%) obtained for the test product and the negative control — Product dilution (%) 0 5 15 25 35 50 Well 1 0.951 0.962 0.964 0.962 0,913 0.744 Well 2 0.944 0.99 1.012 0.992 0.931 0.743 We113 Well 4 0.951 - - - - 0.962 Mean SD 0.952 0.007 Cytotoxicity (%) 0.00 - I - - - - - 0,97 0.021 0.988 0.034 0.977 0.021 0.922 0.744 0.013 0.001 0.00 0.00 0.00 3.15 21.90 - 100 80 >60, :x 40: > C.) 20 0 10 - •‘._ . 0 20 30 Product dilutions 40 50 (%) Fig. 1: Assessment of the NR 50 for the test product NR>50% Skin Research Dpt Cell Toxicology lab. CIR Panel Book Page 80 p. 16/26 Table 8: Optical densities (O.D.) and cytotoxicity (%) obtained for the positive control 1 9 and the negative control (representing the 0% dilution) during the stage n (O.D.) and cytotoxicity (%) obtained for the positive control and the negative control (%) 0 O.01 0.05 0.2 0.25 Well 1 Wel12 We113 Well 4 Mean SD 1.058 1.075 1.059 1.052 1.061 0.010 i.083 1.082 0.861 0.770 0.449 0.246 0.229 - - - - - - - 1.083 0.001 0.816 0.064 0.430 0.028 0.238 0.012 Cytotoxicity (%) 0.00 0.00 23.14 59.52 77.62 Product dilution 100 0.410 1 80 i 60 C.) x 0 40 0 20 0 0 0.05 0.1 0.15 Product dilutions 0,2 0.25 (%) Fig. 2: Assessment of the NR 50 for the positive control I NRO.160% Skin Research Opt Cell Toxicology lab. CIR Panel Book Page 81 p. 17/26 Stage 2 According to table 2 and to the results obtained during the first stage of this study, it was not necessary to perform the stage 2 4-1-3 Conclusion Under the experimental conditions use, the NR 50 of the product Body Lotion was superior to 50%. Frm this result, the test product may be considered slightly cytotoxic. According to our experience and with respect to the type of product tested (skin care product), we consider that this product is as well tolerated as products belonging to the same category. Skin Research Dpi cell Toxióology lab. CIR Panel Book Page 82 p. 18126 4-2 HET-CAM 4-2-1 Summary The Hen’s Egg Test-Chorioallantoic Melnbrane (Het-Cam) is an in vitro method currently used to assess the eye irritating potential of a test product (Balls et aL, 1995; Gettings et al., 1994). The test procedure is based on the evaluation of immediate effects following application of:the test substance onto the surface of the chorloallantoic membrane of 10-day-old feitile hen’s eggs. In this study, the protocol used was adapted from Luepke (Luepke, 1985; Luepke and Kemper, 1986) and was performed according to the method described by the French regulation (JD.R.F., 26112196, Annexe IV). The Het-Cam score of the product Body Lotion, ref. TL45-24-2, was determined after application to the chorioallantoic membrane of 0.3 ml of neat test material. Under the experimental conditions used, the Het-Cam score of the test product was 7.0. Consequently, this product may be classified as moderately irritant when applied neat to the hen’s egg chorioallantoIc membrane. 4-2-2 Results This study was initiated in the oremises of the completed on the 13 September 2005. Date of arrival of the eggs: Date of incubation at 15°C: Date of incubation at 37,5°C: 30 August 2005 30 August 2005 01-02 September 2005 The individual results obtained for the test product, tested neat, the positive and the negative controls are respectively presented in Tables 9, 10 and 11. Skin Research Opt Cet TxcØlogy lab, CIR Panel Book Page 83 p 19126 Body Lotion ref. TL4S-24-2 Test product: Table 9: Individual egg scores obtained for the test product 0 0 o 0 Mean Score = Classification: Moderate’y irritant 7.0 Remarks: A very slight haemorrhage re ction was observed to tre second treated egg whereas slight ones were observed t the others treated eggs Table 10: Individual egg Mean Score = obtained for the positive control 16.0 Negative cor,troi: saline solution Table 11: Individual egg score obtained for the negative control Mean Mean Score 0 0 a 0 Skin Research Opt Cell To cology lab, CIR Panel Book Page 84 p. 20126 4-23 Conclusion Under the experimental conditions usd, the Het-Cam score of the product Body Lotion was 7.0. Frcn this result, the test product may be considered moderately irritant when app!ied neat to the hen’s egg CAM. According to our experience and with respect to the type of product tested (skin care product), we consider that this product is as well tolerated as products belonging to the same category. Skin Research Opt C&I Thxiogy lab CIR Panel Book Page 85 p21/26 4-3 REC assay 4-3-1 Summary The Reconstituted human Epitheliat Culture (REC) assay is an in vitro method used to assess the cytotoxicity of a test product through a three-dimensional epithelial modal. After application of the test product, the cytotoxicity is evaluated by a rapid colorimetric test: the MU test, according to the protocol described by Mosmann (1983). In this study, the protocol used was adapted from the test procedure described by Doucet at al. (1998). The time course of toxicity for the applied product, expressed as a cumulative simplified mean cytotoxicity index (SMCI) was used as endpoint. Under the experimental conditions used, a SMCI of 1.87 was calculated. From this result, the product ody Lotion. ref. TL45-24-2, was considered slightly cytotoxic when applied neat onto the reconstituted epithelial cultures. 4-3-2 Results This study w inititd in th nrmiscs nf the I on the 15 September 2005. Cell cultures Date of arrival: Batch n°: 14 September 2005 05022B0902 Date of expiry: Age of the culture: 23 September 2005 7 days The REC score, expressed as a simplified mean cytotoxicity index (SMCI), obtained for the product, tested neat is presented irilTable 12. Table 12: REC score (SMCI) and cytotoxic potential obtained for the test product CIR Panel Book Page 86 4-33 Conclusion Under the experimental conditions used, he SMCI of the test product Body Lotion was 1.87. From this result, the test product may be considered slightly cytotoxic when applied neat onto reconstiti ted human epithelial cultures. According to our experience and with respect to the type of product tested (skin care product), we consider that this product is as well tolerated as products belonging to the same category. Skin Research Opt Cell ToxiIogy lab. CIR Panel Book Page 87 p. 231 2 5- FINAL ASSESSMENT The aim of this study was to predict the ee irritation potential of formulated products by using a particular <<in vitro>> approach, which combines several alternative methods: - the Neutral Red Release (NRR) assay the Hen’s Egg Test on the Chorio.AUantoic Membrane (HET-CAM) the Reconstituted Human Epithelial Culture (REC) assay For the tested product, and classifications were obtained: NRR assay: HET-CAM: REC assay: Body Lotion, ref. TL45-24-2, the following results 50% Score = 7.0 SMCI 1.87 50 NR > slightly cytotoxic moderately irritant slightly cytotoxic Taking into account the responses of these 3 methods, we consider that the estimated Draize classification of the test product might be slightly irritant with Draize score, which might range from 0 to 15. According to our experience and with respect to the type of product tested (skin care product), we consider that this product is as well tolerated as products belonging to the same category. According to the estimated Draize score, the following proposed: No sta1ement” Skin Research Dpt CeKThxicØogy lab. CIR Panel Book Page 88 iS warning may be 6- REFERENCES BALLS, M, BOTHAM, P.A., BRUNER, L.H, and SPIELMANN, H. (1995). The ECIHO International Validation Study on Alternatives to the Draize Eye Irritation Test. Toxicology In Vitro. 9, 871-929. - BORENFRE1JND, E. and PUERNER, J.A. (1984). A simple quantitative procedure using monolayer cultures for cytotoxicity assays (HTD/NR-90). J. Tissue Cult. Methods. 9, 7-9. - BORENFREUND, E. and PUERNER, J.A. (1985). Toxicity determined in vitro by morphological alteration and neutral red absorption. Toxicol Letters. 24, 119-124. - BRANTOM P.G., BRUNER L.H., CH4\MBERLAIN M. et a), (1997). A summary report of the COLIPA international validation study on alternatives to the Draize rabbit eye irritation test (1997). Toxicology in vilo 11, 141-179. - DOUCET, 0., LANVIN, M. and ZASIROW, L. (1998). A new in vitro human epithelial model for assessing the eye. irritating potential of formulated cosmetic products. In Vitro & Molecular Toxicology 11, 273-283. - GETTINGS, S. D, DIPASQUALE, L. C., BAGLEY, 0. M., et al. (1990). The CTFA evaluation of alternatives program: an evaluation of in vitro alternatives to the Draize primary eye irritation test (phase I) hdro-alcoholic formulations: a preliminary communication. In Vitro Toxicology. 3, 293-302. - GETTINGS, S. D., DIPASQUALE, L. Ci., BAGLEY, D. M., et al. (1994). The CTFA evaluation of alternatives program: an evaluation of in vitro alternatives to the Draize primary eye irritation test (phase II) p11/water emulsions. Food and Chemical Toxicology. 32, 943-976 - GETTINGS, S. D., LORDO R. A., HINTZE K. L., et al. (1996). The CTFA evaluation of alternatives program: an evaluation df in vitro alternatives to the Draize primary eye irritation test (phase ill) surfactant-based formulations. Food and Chemical Toxicology. 34, 79-117. - Skin Research Dpt Cell Thxiology lab. * CIR Panel Book Page 89 p. 25! 26 JOURNAL OFFICIEL DE LA REPUBLIQUE FRANcAISE. Arrêté du 29 Novembre 1996, J.O. du 26 Décembre 1996. Annexe IV. Méthode Officielle d’Evaluation dii Potential Irritant par Application sur Ia Membrane Chorio-AllantoIdienne de l’oeuf de poule. - JOURNAL OFFICIEL DE LA REPUBL1UE FRANçAIsE. Arrêté dii 27 Décembre 1999. J.O.R.F. du 30 Décembre 1999. Annexe VI. Méthode officielle devaluation dii potentiel irritant par application directe sur monocouche do fibroblastes de cornée de lapin par Ia méthode do relargage dii rouge neutre. - LUEPKE, NP. (1985). Hen’s egg chorioallantoic membrane test for irritation potential. Food and Chemical Toxicology 23, 287-291. - LUEPKE, N.P. and KEMPER, RH. (1986). Het-Cam test: an alternative to the Draize eye test. Food and Chemical Toxicology. 24, 495-496. - MOSMANN, T. (1983). Rapid colorirnetric assay for cellular growth survival: Application to proliferation and cytotoxicity assays. J. Immunol. Methods. 65, 55-63. - READER S.J., BLACKWELL V., OHARA R., CLOTHIER R., GRIFFIN G. and BALLS M. (1989). A vital dye release method for assaying the short-term cytotoxic effects of chemicals and formulations. ATLA 17. 28-33. - REGNIER, M., DESBAS, C., BAILLY, C., and DARMON, M. (1987). Differentiation of normal and tumoral human keratinocytes cultured on dermis. Reconstruction of either normal or tumoral architecture. In Vitro Cell Dev, Bio. 24, 625-632. - ROUGIER, A., COTTIN, M., DE SILVA, 0., et al. (1994). The use of in vitro methods in the ocular irritation assessment of cosmetic products. Toxicology In Vitro. 8, 893-905. - RUPNIAK, H.T., ROWLATT, C., LANE, E.B., et at. (1985). Characteristics of four new human cell lines derived from squamous cell carcinomas of the head and neck. J. NatI. Cancer Inst. 75, 621-635. - Skin Research Dpt Cell Toxicology lab, CIR Panel Book Page 90 p. 26)26 VCRP Data for Alkyl Benzoates Ingredient C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE C12-15 ALKYL BENZOATE Use Category 01B - Baby Lotions, Oils, Powders, and Creams 03A - Eyebrow Pencil 03C - Eye Shadow 03D - Eye Lotion 03E - Eye Makeup Remover 03F - Mascara 03G - Other Eye Makeup Preparations 04B - Perfumes 04E - Other Fragrance Preparation 05A - Hair Conditioner 05B - Hair Spray (aerosol fixatives) 05C - Hair Straighteners 05F - Shampoos (non-coloring) 05G - Tonics, Dressings, and Other Hair Grooming Aids 05I - Other Hair Preparations 07A - Blushers (all types) 07B - Face Powders 07C - Foundations 07D - Leg and Body Paints 07E - Lipstick 07F - Makeup Bases 07G - Rouges 07I - Other Makeup Preparations 08B - Cuticle Cuticle Softeners Softeners 08C - Nail Creams and Lotions 10A - Bath Soaps and Detergents 10B - Deodorants (underarm) 10E - Other Personal Cleanliness Products 11A - Aftershave Lotion 11D - Preshave Lotions (all types) 11E - Shaving Cream 11G - Other Shaving Preparation Products 12A - Cleansing 12C - Face and Neck (exc shave) 12D - Body and Hand (exc shave) 12E - Foot Powders and Sprays 12F - Moisturizing 12G - Night 12H - Paste Masks (mud packs) 12I - Skin Fresheners 12J - Other Skin Care Preps 13A - Suntan Gels, Creams, and Liquids 13B - Indoor Tanning Preparations 13C - Other Suntan Preparations CIR Panel Book Page 91 No. of Uses 9 1 28 20 1 1 18 1 13 12 6 3 2 42 33 16 26 42 1 66 7 1 17 1 1 11 6 1 15 1 5 3 30 91 102 5 174 35 11 3 48 17 36 9 C16-17 ALKYL BENZOATE 10A - Bath Soaps and Detergents 2 ISOSTEARYL BENZOATE 12C - Face and Neck (exc shave) 1 STEARYL BENZOATE STEARYL BENZOATE 01B - Baby Lotions, Oils, Powders, and Creams 07C - Foundations 2 1 CIR Panel Book Page 92 Personal Care’ Products Council Committed to Safety, Quality & Innovation Memorandum TO: F. Alan Andersen, Ph.D. Director COSMETIC INGREDIENT REVIEW (CIR) - FROM: John Bailey, Ph.D. Industry Liaison to the CIR Expert Panel DATE: July 26, 2010 SUBJECT: Comments on the Scientific Literature Review on Alkyl Benzoates The following 10 substances were included in an HPV submission to EPA.. It is not clear if this submission (found at http ://www .epa. gov!chemrtklpubs/summaries/benzylde/c 1 3450tc.htm) was reviewed for relevant information. Benzaldehyde p-Methoxybenzaldehyde m-Methoxy-p-hydroxybenzaldehyde Benzyl acetate Benzyl benzoate Methyl benzoate Methyl p-methylbenzoate Methyl 2-hydroxybenzoate Pentyl 2-hydroxybenzoate Benzyl 2-hydroxybenzoate p.2 As reference 12 was published in 2004, the meaning of “began a couple of years ago” is not clear, and will become less clear after the CIR report is published. p.2 It would be helpful if the product categories in which use was reported in the Council survey were also included in the text. Rather than stating that no uses were reported for the rest of the ingredients, it would be helpful if the names of the ingredients for which no uses were reported were stated. p.2 The statement about the permitted uses of methanol in the EU suggests that the EU regulations were checked for all the ingredients in the report. Please see EU Annex VI entry la for permitted uses of Methyl Benzoate, Ethyl Benzoate, Propyl Benzoate and Butyl Benzoate as preservatives. p.2 As the alcohols are not included in the report. The information about alcohols can be deleted from the Non-Cosmetic Use section. If this information is left in the report, a reference should be added for the use of isopropyl alcohol as a topical antimicrobial. p.3 It is not clear why the discussion regarding metabolism of acetates is included in this report on benzoates. - - - - - 11011 7th Street, N.W., Suite 3O0 Washington, D.C. 20036-4702 202.331.1770 CIR Panel Book Page 93 202.331.1969 (fax) www.personalcarecouncil.org p.3 If Kirk-Othmer (reference 23) cited any primary references regarding the dermal penetration of benzoic esters, the primary references should be obtained and cited. p.3 Please define NI . 50 p.3 How many rabbits were used in the dermal LD 50 study of Methyl Benzoate. p.3 Please provide the species used in the Benzoic Acid and Sodium Benzoate studies. p.3 How many rats were used in the chronic study of Methyl Benzoate. Although this study is under the Methyl Benzoate subheading, and the text says “Methyl benzoate”, the title of the study (reference 33) in the reference section indicates the study was about Sodium Benzoate. Please state whether or not histopathological examinations of major organs were completed in this study. p.4 What was the concentration of Methyl Benzoate used in the dermal irritation study in rabbits. p.4 Please correct the spelling of “strume”, “hyperkeatosis”, “straatmu”, “hyperkertosis” p.4 The information on Benzyl Benzoate, needs to be removed from this report and added to Benzoic Acid, Benzyl Benzoate et al. report. p.4 Did reference 35 report any maternal effects? p.4 Please provide the number of rats per treatment group used in reference 37. pA Please provide the number of mice, hamsters and rabbits per group used in reference 37. On what gestation days were these species treated? p.5 Please provide the gestation days on which the hamsters were treated with Benzoic Acid. p.5 It is not clear what 50.5% vs 12.5% represents, mortality of the parental and Fl cohorts combined of controls compared to treated mice? What is meant by a “100% food restriction test”? How long was this test? p.5 Reference 33 is a carcinogenesis bioassay. Please provide the results concerning carcinogenicity in the Carcinogenicity section. p.S Please define ADI. What is the value of the ADI for Benzoic Acid? p.S Were the studies of Benzoic Acid really clinical studies, or were they case reports? p.5 What concentrations of Benzoic Acid were negative for sensitization, phototoxicity and photosensitivity? Where is the Summary for this report? - - - - - - - - - - - - - - - - 2 CIR Panel Book Page 94
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