ACCEPTANCE OF HONORARY MEMBERSHIP 319 ment to the Food and Drugs Act passed in May, 1939. War and postwar preoccupations of the Government, however, delayed the "proclamation" of the cosmetic sections until 3 years or so ago. At that time cosmetics were brought into the fold, so to speak, and were subject to the general provisions of the Act, as distinct from what- ever specific requirements might be laid down later by regulation. The proposed regulations are now in final draft form and I have a copy with me which I propose to run over very quickly, omitting legal phraseology. (The speaker dealt briefly but completely on the pro- posed regulations.--EDiTO R.) You will see that these require- ments differ hardly at all from your own, so we need not spend further time on them. Where our ideas differ is of more importance to you, but I shall come to that in a mo- ment. I should like to mention first the rather curious device by which cosmetics were brought under the Act. They were defined legally and technically as "drugs," although it must have been obvious that many of the drug provisions could not possibly apply to cosmetics. It showed I think, something of a lack of appreciation of the position and function of cosmetics which no longer obtains, although of course the definition remains until the Food and Drugs Act itself can be amended.* Owing to the good sense of our * The amendment has already been read in Parlia ment and is now in Committee. regional staffs, and our closer con- tact with them in recent years, we have not had a great deal of trouble but there have been some amusing incidents--amusing to me, I mean. Our regulations quite reasonably forbid the sending out of unsolicited samples of drugs to the public. In one of our larger cities where we have a regional laboratory a cos- metic manufacturer mailed samples of one of his products (a hand lotion as a matter of fact) to a list of people no doubt taken from a directory or similar publication. As it happened by ill-luck, his list included some of our regional laboratory staff. Some- body at the "lab" that morning must have been feeling out of sorts, for his thoughts ran this way: "free sample of hand lotion--a cos- meticmbut a cosmetic is a drug-- the distribution of free samples of drugs is contrary to regulations-- this must be stopped!" Well, we straightened that one out in Ottawa. A more recent case concerned a hair preparation alleged to grow hair. We have no desire to take the romance out of cosmetics, and we are fairly lenient with cosmetic claims, but we do not allow the un- qualified statement that a prepara- tion will cause lost hair to grow again. Our inspector instead of taking the correct attitude that the preparation was a cosmetic making a false claim, accepted the claim, and proceeding logically enough from that, ruled that since the growing of hair was a modification of organic function, the prepara- tion was a drug, and most declare

320 JOURNAL OF THE SOCIETY OF COSMETIC CHEMISTS the active ingredient! Personally, if I knew of such a substance, I should go into business tomorrow! I come now to what I think is the only matter in which we dif- fer materially from you, that is concerning cosmetic preparations containing estrogenic hormones. Companies exporting such prepa- rations to Canada should note the labelling requirements laid down in Part C Division I of the Act and regulations, which deal with the labelling of drugs. It should also be mentioned that although no dosage is laid down either in the drug or cosmetic regulations the Department is likely to take ex- ception to the higher dosage prep- arations now appearing in this country. One word more I have attended meetings of many societies of one kind or another, but this SoCIRTY OF COSMETIC CHEMISTS is the most live and most vigorous in my ex- perience. I am delighted to be one of you. f•.=.. • ...:•-v •::' • :• - ß 7. ,. COURTESY-AMERICAN PERFUMER Presentation of honorary membership. J. L. Thomson receives award from President Sol D. Gershon