The ITA represents reputable small businesses throughout the U.S. that already adhere to the highest professional standards including good manufacturing practices. We embrace any label changes that will lead to a better understanding of the potential risks of overexposure and thereby enhance our customers’ safety. However we are concerned that the proposed requirements will burden our members with additional unnecessary governmental costs in an already difficult economic climate.
We are also concerned that in spite of the fact that the WHO/IARC study of 2009 has been widely discredited by reputable scientists, the FDA consistently references findings in this study as the driving force for reclassification. We look forward to presenting to the FDA an independent analysis of the study which clearly outlines the flaws.