The USA FDA Threatens to Ban Henna!

Henna has been used to adorn and bless women for 9000 years and in over 60 countries.  Christians, Jews, Muslims, Hindus, and Buddhists have used henna as part of their social and religious customs. It is unnecessary and unfortunate that the FDA is considering banning this natural plant powder crucial to the religious and folk life of countless citizens of the United States.

The FDA has declared 100% pure henna (Lawsonia Inermis) to have such a high level of safety that it is exempted from certification for use on hair and scalp. The FDA states that certification of this color additive for the prescribed use is unnecessary for the protection of the public health and therefore batches thereof are exempt from the certification requirements of section 721(c) of the act. 
 See: 
TITLE 21--FOOD AND DRUGS PART 73--LISTING OF COLOR ADDITIVES EXEMPT FROM CERTIFICATION 
            
http://frwebgate.access.gpo.gov/cgi-bin/get-cfr.cgi?TITLE=21&PART=73&SECTION=2190&YEAR=2000TYPE=TEXT 
 http://www.cfsan.fda.gov/~dms/cos-818.html 
 http://www.cfsan.fda.gov/~lrd/cf732190.html 
 http://vm.cfsan.fda.gov/~dms/cos-hdb4.html 

However, the FDA has recently reversed itself, banning the import of henna (Lawsonia Inermis), in response to reports of contact dermatitis associated with temporary tattoos.  These recent "black henna" injuries are NOT caused by henna (Lawsonia Inermis). They are caused by para-phenylenediamine used in place of henna, or mixed into henna, and applied directly to skin to create fast, black, temporary tattoos.  These are marketed as "black henna", and this misnomer has created confusion for the consumers and medical profession trying to diagnose the injuries. Henna does NOT stain skin black!  Para-phenylenediamine is known to cause injuries in many people even when used as permitted in hair dye.  

When para-phenylenediamine is used to make notorious "Black Henna" temporary tattoos, it becomes a serious health concern, because the application may last for hours, rather than minutes, as is recommended for hair dye. Medical tests have proven that para-phenylenediamine  is the source of the injuries, NOT  henna (Lawsonia Inermis).  

To view medical papers demonstrating that para-phenylenediamine, NOT HENNA, is the cause of the injuries:  
"Contact dermatitus after temporary henna tattoos: an increasing phenomenon" by Stephan Lautenschlager, published in Swiss Medical Weekly, 2001; 131: 199 - 202 
 http://www.smw.ch/pdf200x/2001/2001-13/2001-13-351.PDF 

 "Allergic reactions to decorative skin paintings",  Nikkels AF, Henry F, Pierard GE. 
 Department of Dermatopathology, University Medical Center of Liege, Belgium             
http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=PubMed&list_uids=11495521&dopt=Abstract 

Not one medical test has shown 100% pure henna  (Lawsonia Inermis) to be the cause of any of the "temporary  tattoo" injuries. Patch tests in these cases have shown that adulterants such as para-phenylenediamine to have caused ALL injuries.  

Dermatologists agree that pure henna, even when applied to skin for body art has an extremely low incidence of sensitization, and reactions are very minor at worst, and conclude that the injuries are NOT being caused by henna!  
"Sting in the tail: 'henna' tattoo of a scorpion causes eczema", BUPA medical team - 21 December 2000 http://www.bupa.co.uk/health_news/211200henna.html states: 
 "Dermatologists know that henna - a vegetable dye commonly used in Muslim and Hindu body art - causes minor skin irritation at worst. In these more severe cases it was unlikely to be the culprit. Suspicions turned instead to other possible ingredients of the body paint. Four patients were tested with other common dye chemicals, by placing them on small patches of skin and checking for reactions. All of the results were positive for an allergy to chemicals used in hair dye, especially p-phenylenediamine." 

Natural henna is characterized as "a rare and weak skin sensitizer" in "Allergic contact dermatitis caused by skin painting  (pseudotattooing) with black henna, a mixture of henna and p-phenylenediamine and its derivatives." by Le Coz CJ,  Lefebvre C, Keller F, Grosshans E..  The article also states that the contact dermatitis associated with "black henna" is due to inappropriate use of  p-phenylenediamine. See:            
http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=PubMed&list_uids=11115163&dopt=Abstract 

Therefore the  "black henna" temporary tattoos injuries should not impact the import of pure henna (Lawsonia Inermis). 

 Adulterants such as para-phenylenediamine have been introduced into henna, or used in place of henna by greedy, ignorant and unscrupulous people. Adulterated henna is illegal, and FDA regulations regarding use of para-phenylenediamine should be upheld!   Pure henna (Lawsonia Inermis) should remain exempt from certification. The European Union has issued a statement declaring PPD and similar chemicals should not be used in skin stains (temporary tattoos). See: "Position Statement concerning para-Phenylenediamine and similar Substances and their use in Skin Stains (Temporary Tattoos) adopted by the SCCNFP during the 16th Plenary Meeting of 13 March 2001" 
 http://europa.eu.int/comm/food/fs/sc/sccp/out140_en.html 

Para-phenylenediamine should NEVER be used in, or in place of henna (Lawsonia Inermis) for temporary body art, as per FDA regulation.  

The FDA is correct to insist that henna (Lawsonia Inermis) NOT be adulterated with unlisted and/or unsafe ingredients.  These products should be seized in the interest of public safety.  However, 100% pure henna has such a high level of safety  that it should remain exempt from certification, and its import should be permitted.

Henna is only the only safe hair dye for people who have become sensitized to para-Phenylenediamine.  The import of 100% pure henna should be permitted for these people, as using commercial synthetic hair dye would imperil their health. 

100% pure henna is the ONLY hair dye permitted to Orthodox Jews and Conservative Muslims.  Henna should be a permitted import for these people, who, by their religious conscience, cannot use any commercial hair dye. 

Not only is henna (Lawsonia Inermis) NOT causing "black henna" injuries, and permitted by FDA regulation as hair colorant, henna is part of the religious practice of many citizens of the United States. 

The 1st Amendment of the US Constitution protects the rights of citizens to practice customs in accordance with their religion.  Henna is associated with the practice of several religions.  Blocking importation of, or banning henna use, conflicts with the Constitution of the United States of America. 

 A devout Muslim who has made his pilgrimage to Mecca is permitted to dye his beard with henna, to honor the Prophet Mohammed, who also dyed his beard with henna.  Henna (Lawsonia Inermis) should be a permitted import for these men who wish to express their piety and devotion to their religion. 
 For references to the Muslim use of henna, see:  http://www.islamicvoice.com/november.99/tibb.htm#HEN 

 Henna (Lawsonia Inermis) is also the only color an Orthodox Jewish woman or a conservative Muslim woman may use on her fingernails.  No other nail polish is permitted, as their religion declares that with those paints, the fingernails cannot be properly cleaned before prayer.  100% pure henna must be allowed for these women, so they can pray. 

 Devotees of Hinduism feel that offerings are most acceptable to their deities when presented by hennaed hands.  Henna should be allowed to pious Hindus who feel that their prayers and offerings may be shunned for lack of henna.  

Women from all of the countries in North Africa, the Middle East, and South Asia have "The Night of the Henna" traditions as part of their weddings.  The wedding tradition of hennaeing a woman's hands dates to 7000 BCE.   A government official’s misinformed and poorly reasoned ruling should NOT interrupt a beloved ritual that has endured for 9000 years and stretched over 60 countries! Jews adopted "The Night of the Henna" as a part of their wedding around 1000 BCE, and Sephardic Jews continue this to this day. Armenian Christians, and Coptic Christians also celebrate "The Night of the Henna".  The Prophet Mohammed's own mother was hennaed at her wedding, and "The Night of the Henna" is one of the most important nights in any Muslim woman's life!  For the Hindu, "The Night of the Henna" is a spectacular family party, the night every girl dreams of, when she will look like, and be treated as, a princess! 
Some of these "Night of the Henna" traditions are described at: 
http://www.veleisures.com/matrimonials/HinduWedding.asp 
http://www.veleisures.com/matrimonials/SikhWedding.asp 
http://www.veleisures.com/matrimonials/MuslimWedding.asp 
http://www.sfusd.k12.ca.us/schwww/sch618/islam/nbLinks/Islam_Women_Marriage.html 

Hindu, Muslim, Sephardic Jewish, Rom, B'hai, Parsee, Zoasterian, Sikh, Coptic Christian, and Armenian Christian brides all celebrate "The Night of the Henna" before their weddings.  These religions make up, at last census, 10,000,000 citizens of the USA.  It would be tragic, as well as unconstitutional, to prevent these people's joy in celebrating and preserving their wedding traditions!  
The census figures on USA citizens who have henna traditions are at: 
http://www.adherents.com/rel_USA.html 
http://www.religioustolerance.org/us_rel.htm 

Brides who feel henna is a part of their religious, social, and ethnic traditions MUST be allowed to use henna. The 1st Amendment of the US Constitution protects the rights of citizens to practice customs in accordance with their religion.  

The preservation of long-standing valuable social customs is important to the life of a community. 100% pure henna, safe enough to be declared permanently exempted as a hair and scalp dye, is an important part of the religious and social life of over 10,000,000 Americans. Henna brings joy and beauty, and continues millennia-long tradition. 100% pure henna is used to celebrate life as Christmas Trees are used to celebrate Christmas.   There is NO need to block the importation of 100% pure henna (Lawsonia Inermis). 

The FDA is correct to insist that henna NOT be adulterated with unlisted and/or unsafe ingredients. 
These products should be seized in the interest of public safety.  However, 100% pure henna (Lawsonia Inermis) has such a high level of safety that it should not be prevented from importation. Para-phenylenediamine should NEVER be used in, or in 
place of henna, as per  FDA  regulation.  

FDA regulations prohibiting import of pure henna (Lawsonia Inermis) are vague, poorly reasoned and not enforceable. They should be re-written or dropped.  There is no compelling reason to seize 100% pure henna.  There are many reasons to permit its import. 
              
              
                                                                                               August 22, 2001 
                                                                                       Catherine Cartwright Jones 
                                       Researcher and specialist on Henna History, Traditions, Chemistry and Techniques 
                                                                   Sirius International Henna Conferences director
                                                                                  Kent State University faculty
                                                                                             info@mehandi.com
 

TAKE ACTION NOW!  PROTECT HENNA!
  
Contact the FDA, contact your congressman and contact lobby groups.

If you want to contact your USA congressman, to express your concern that the FDA is threatening rights to free expression of religion, or celebration of ethnic traditions, by interfering with the free import of 100% pure henna (as is deemed by the FDA itself as exempt from certification requirements) please: 
Find your congressman or local official here: 
http://www.info.gov/ 
http://www.firstgov.gov/top_nav/welcome1.html 
Write your own cover letter expressing your concerns. 

Letters to the EEOC, the body particularly concerned with these freedoms, may be helpful. 
Letters to Muslim and Hindu religious leaders in the US, and those who lobby for the interests of 
Middle Eastern, North African and South Asian countries and their citizens in the USA may be very helpful. 

You can contact the FDA and tell them if you feel that 100% pure henna should be imported for use on religious occasions, preserving ethnic traditions, and for educational and historic  study.  See: http://www.fda.gov/opacom/backgrounders/voice.html 

This site states: "FDA rules have considerable impact on the nation's health, industries and economy. These rules are not created arbitrarily or in a vacuum. They are formed with the public's help. 

So HELP them! 

You can petition the FDA.  For guidelines, see:  
http://www.fda.gov/opacom/backgrounders/voice.html 

You can write to the FDA. The address and instructions are at: 
http://www.fda.gov/opacom/backgrounders/voice.html 

You can send your E-Comments Directly to the FDA! 
You can submit your comments through the FDA Website on many of FDA's proposed regulations at: 
http://www.accessdata.fda.gov/scripts/oc/dockets/commentdocket.cfm 
               

India Together is a lobbying organization for USA residents of Indian heritage.  
The Indian-American community is the fastest growing minority in the USA.  If you are from India, and feel that the FDA's rulings on henna hinder YOUR rights to worship or maintain your ethnic traditions, please see:
http://www.indiatogether.org/us/lobby.htm  .  This group works to help Indian-Americans present their concerns to Congress! If you are not Indian-American, but wish to express your concerns that the FDA ruling against henna violates the rights and heritage of people from India, contact them! 
You can write to your congressman through them at: 
http://www.indiatogether.org/us/letters/letter.htm

If you are Muslim and are concerned that your henna heritage is endangered by the FDA's position 
on henna, you may wish to contact the lobbying organization for Muslims : http://www.islamiclobby.net/

Sephardic Jewish women have celebrated the Night of the Henna for over 2500 years.   Jewish women who wish to insure that their henna heritage is preserved in the USA may wish to contact: 
United Jewish Communities, http://www.uja.org/ 
Telephone: 212.284.6500 
Postal address: 
United Jewish Communities 
Suite 11E 
111 Eighth Ave. 
New York, NY 10011
 
 

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