LEDA at Harvard Law School LEDA at Harvard Law School
Prof. Peter Barton Hutt
April 2, 2002
Henna Tattooing: Cultural Tradition Meets Regulation
Standards of personal beauty have been set and pursued as part of all cultures.[1] The word “cosmetic” is derived from “kosmétikos,” meaning “skilled in adornment.”[2] Cosmetics have been developed and influenced by ethnic traditions and folklore, and they also have philosophical, historical, and cultural roots. What it means to be beautiful does not remain static, just as standards of beauty can be transported from one homeland to another.
In recent years, enhancing beauty has taken on more lasting dimensions. No longer are people content with simply applying eyeliner or blush to decorate the face. Rather, the body is more and more a canvas to be painted in new and innovative ways. In 1997, the body art industry was the nation’s sixth fastest-expanding business. The temporary body art business has grown into a $100 million annual “category,” with teens composing the largest demographic of supporters.[3]
There are increasing options within the world of body art. Individuals may choose to permanently decorate their bodies with a tattoo, or can resort to a shorter lasting design in the form of a temporary tattoo. As tattooing in either form becomes a more mainstream practice, the Food and Drug Administration (FDA) has realized that its involvement in the body art industry has urgency and significance. In tackling the problems posed by tattooing, the FDA has taken divergent approaches that might be classified as reacting at a level of misdirected narrowness and specificity. The most glaring example of the FDA’s difficulties in identifying an appropriate strategy is found in henna tattooing (mehndi). Before examining the case of henna tattoos and possible responses to their popularity and usage, it is necessary to take up the issue of temporary versus permanent tattooing, the regulation of henna, the history of mehndi, and the safety of the practice.
While the FDA has become interested recently in the materials and agents used in the practice of temporary tattooing, it has taken a less focused approach in dealing with permanent tattooing. This disparity in treatment raises some interesting questions about the relative dangers of each method, and whether the current regulatory scheme is responding commensurately.
In its treatment of permanent tattooing, the FDA takes a rather decentralized, laissez faire approach. Most of the regulatory policing is left to the individual states. Jurisdiction is shared with the Federal Trade Commission, which has control over the advertising or other promotional claims for dyes, pigments, and devices used in tattooing.[4]
An example of the FDA’s mixed sentiment on permanent versus temporary tattooing is found in its handling of tattooing equipment. The FDA does not “actively” regulate tattooing equipment. The agency declined to decide whether tattoo equipment should be regulated as a medical device. The FDA has chosen to treat tattooing much like it does such activities as ear piercing, and leave the regulatory authority to the states.[5]
However, the FDA considers the dyes and pigments used in the tattooing process to be color additives, as defined under section 201(t) of the Federal Food, Drug, and Cosmetic Act, and cosmetics, as defined under section 201(I) “since they are generally applied for the purpose of beautifying, promoting attractiveness, or altering the appearance.”[6] The dyes and inks used in tattooing are not “drugs” under section 201(g)(1).[7] However, the FDA considers the pigments used in tattoos to be “intradermally injected color additives. Although 21 CFR 70.5(b) requires specific listing of color additives used in injections, there are no color additives listed by the FDA for such use.”[8] Therefore, parties interested in seeing a pigment listed for injected cosmetic use are directed to submit color additive petitions (21 CFR 71).
CDRH expressed its official position on tattooing equipment and dyes in Advisory Opinion, Docket No. 81A-0315/AP (July 21, 1986). There, it stated that dyes and pigments used in this practice would be regulated as color additives as defined in section 201(t) of the Act, and further contended that there was no justification to determine the device status of the equipment used in tattooing.[9]
The inks used in tattoos ... and the pigments in these inks are subject to FDA regulation as cosmetics or color additives. However, FDA has not attempted to regulate the use of tattoo inks and the pigments used in them and does not control the actual practice of tattooing. Rather, such matters have been handled through local laws and by local jurisdiction.”[10]
However, as tattooing—both permanent and temporary—increases in popularity and usage, the FDA has become increasingly interested in this area. The FDA is particularly concerned with the “increasing variety of pigments and dilutents being used in tattooing—more than fifty different pigments and shades.”[11] Although several color additives are approved for use as cosmetics, none is approved for injection into the skin. If an unapproved color additive is used in tattoo ink, the FDA considers the ink to be adulterated. Many of the pigments used in tattoo inks are not even approved for contact with the skin. Several of these inks are “industrial grade colors that are suitable for printers’ ink or automobile paint.”[12]
The dilemma of regulating tattoo ink is further complicated by the distribution of these materials. The pigments are sold to tattoo parlors and not directly to consumers through retail channels.[13] Therefore, manufacturers are not required by current law to list the ingredients on the label. In some cases, manufacturers regard the grade/quality and identity of their pigments as proprietary, making it impossible for the tattooist or the consumer to obtain ingredient information.[14]
The U.S. Office of Safety and Health Administration (OSHA) regulates tattoo shops themselves. Shops are subject to routine OSHA inspections, and must comply with OSHA standards by having hard surface floors, a working sink at each tattoo station, and equipment such as autoclave sterilizers.[15] The focus of OSHA, of course, is on the safety of the employees in the workplace rather than the tattoo consumers.
B. Temporary Tattoos
The FDA has also become involved in investigating the safety of temporary tattoos. Temporary tattoos fade several days to weeks after application. Most temporary tattoos contain color additives approved for cosmetic contact with the skin.[16] However, the FDA is closely monitoring the import of temporary tattoos. In 1994, the FDA began to take notice of a proliferation of temporary tattoos entering the United States that did not bear labeling, or had misleading labels.[17] These tattoos mostly originated in Taiwan, the United Kingdom, Japan, and Hong Kong.[18] The FDA was particularly concerned about the products that bore an “FDA approved” statement, yet contained unsafe color additives, or failed to list the ingredients at all. The FDA decided to increase its coverage and review of all temporary tattoo entries. Temporary tattoos appearing to contain unsafe color additives, non-permitted colors, lacking an ingredient declaration, and/or bearing an “FDA approved” statement were to be detained.[19] For temporary tattoos with ingredient declarations, only those products which listed unsafe color additives (those not in conformity with a regulation issued pursuant to Section 706(b)), were to be detained.[20] No color additives analyses were required for the detention of the products in cases where the labels indicated impermissible additives.[21] FDA, primarily through its Cosmetics Adverse Reaction Monitoring (CARM) system, continues to receive reports of allergic reactions to temporary tattoos.[22]
While many of these temporary tattoos are much like rub-on body stickers that peel and fade with time, other kinds of temporary tattoos have gained popularity in recent years. In the case of henna tattoos, popularity did not necessarily result from a fad, but gained support from a cultural tradition and consumer base spanning five thousand years.[23] In the West, today, henna tattoos have become more mainstream—moving away from the Arab and Asian communities that had included them as a symbol of auspicious occasions and cultural continuity, to being sighted on celebrities, trendsetters, and travelers.
These henna tattoos have become of increasing concern to the FDA as the agency has only approved henna as a hair dye, and “not for direct application to the skin.”[24] Unadulterated henna produces a reddish brown tint on the hair or skin, but there has been a rise in the number of henna products on the market advertising themselves as “black henna” or “blue henna.”[25] Further investigation of these products has generally revealed that they are filled with additives designed to increase the longevity of the henna tattoo and dilute the amount of more expensive henna in the product. Some of these additives have produced mild to severe allergic reactions.
Henna tattoos have become a part of the FDA’s “watch list” because they are readily available, aesthetically appealing, and potentially dangerous. The remainder of this paper will focus narrowly on the tradition of henna tattooing, the FDA’s regulatory steps, and the overall safety of the art form. This examination will begin to answer the question of why the FDA has become so concerned and involved with temporary tattoos, specifically henna, and remained rather constant in its hands-off approach to permanent tattoos.
According to the Food, Drug, and Cosmetic Act, the Food and Drug Administration considers henna to be:
Sec. 73.2190 Henna
(a) Identity. The color additive henna is the dried leaf and petiole of Lawsonia alba Lam. (Lawsonia inermis L.). It may be identified by its
characteristic odor and by characteristic plant histology.
(b) Specifications. Henna shall conform to the following
specifications:
It shall not contain more than 10 percent of plant material from Lawsonia alba Lam. (Lawsonia inermis L.) other than the leaf and petiole, and shall be free from admixture with material from any other species of plant.
Moisture, not more than 10 percent.
Total ash, not more than 15 percent.
Acid-insoluble ash, not more than 5 percent.
Lead (as Pb), not more than 20 parts per million.
Arsenic (as As), not more than 3 parts per million.
(c) Uses and restrictions. The color additive henna may be safely used for coloring hair only. It may not be used for coloring the eyelashes or eyebrows, or generally in the area of the eye.
(d) Labeling. The label for henna shall bear the information required by Sec. 70.25 of this chapter and the following statements or their equivalent:
´´Do not use in the area of the eye.''
´´Do not use on cut or abraded scalp.''
(e) Exemption from certification. Certification of this color additive for the prescribed use is not necessary for the protection of the public health and therefore batches thereof are exempt from the certification requirements of section 721(c) of the act.[26]
Henna is the only vegetable dye to remain indefinitely. It does not coat the hair, but actually goes into a “chemical combination” with the hair.[27] The color additive regulation, 21 CFR 73.2190, only allows for the safe use of henna in hair coloring. The regulation does not permit the safe use of henna to create colored designs directly on the skin.[28]This unapproved use of a color additive makes henna tattoo (mehndi) products adulterated and therefore illegal.[29] Like temporary tattoos, henna tattoos have resulted in reports of reactions and injuries to the FDA.
Cosmetics, including these temporary tattooing products, must have their ingredients listed on the label in order to be approved for retail sale. Without an ingredient declaration, they are considered by the FDA to be misbranded and are illegal to pass in interstate commerce.[30] The ingredient declaration is mandated by the FDA’s authority under the Fair Packaging and Labeling Act (FPLA).[31] The Act does not apply to cosmetic samples and products used exclusively by professionals, and therefore, henna applied at a salon, fair, or kiosk is not subject to the ingredient declaration requirements.[32]
Except for the coal tar colors used in coal dyes, color additives used in cosmetics must be approved by the FDA for their intended uses. Some additives may not be used unless the FDA has certified, through its own research, that the composition of the batch meets the regulatory requirements.[33] Cosmetics that don’t comply with these restrictions on color additives are considered adulterated and are illegal in interstate commerce.
With the exception of color additives, FDA does not have the regulatory authority to approve cosmetic products or ingredients, although the presence of several substances is banned or restricted due to established safety concerns.[34] If the safety of a product or its ingredients has not been substantiated, however, the product can be considered to be misbranded, and therefore illegal, if it does not have this warning on the label: “Warning- The safety of this product has not been determined.”[35] Because the FDA has not determined the safety of henna or mehndi products, this label must appear on these cosmetics.[36]
For several years, the FDA has been detaining without physically examining, henna-based skin colorants.[37] For example, in an important alert from 1996, the FDA detained henna powder from Pakistan on the grounds that it was an unsafe color additive.[38] Under Section 801(a)(3), the FDA had authority since the product did not appear to be a hair dye, but was intended for the purposes of decorating the skin, and therefore could be considered an unsafe color additive under Section 721(a) [adulteration, Section 601(e)]. The Los Angeles district had seized the product, and reported that it did not contain directions for use, but that the label declared henna as the sole ingredient and depicted designs on the feet and hands. Many other countries have been affected by this FDA position, including Pakistan, India, Hong Kong, and Taiwan.[39]
As a bit more background-- Henna is the dried and powdered leaf of the dwarf evergreen shrub Lawsonia inermis, a member of the Loosestrife family, Lythraceae, which reaches a height of approximately 2.5-3m. The henna plant thrives in hot climates, and areas such as Saudi Arabia, Iran, Sri Lanka, India, Egypt, and Sudan are its major producers.[40] The cooling properties of the plant are well known. The most striking quality of henna is that it contains a natural chemical that interacts with the keratin of the skin and hair to give it a rust-red color.[41] It is this characteristic that makes henna the choice for body painting (also known as mehndi) in many cultures. Henna, and the adornment that it produces, creates many different shades—from reddish orange to brown-black.[42]
Mehndi means henna in the Hindi language, but the word might also derive from the Sanskrit “mehagni,” which is a synonym for turmeric. The Vedas, the ancient sacred literature of Hinduism, describes the various uses for both henna and turmeric. Both plants were important in Vedic traditions for they represented the symbols of “outer” and “inner sun.”[43] Vedic believers desire to awaken the “inner light.” To reach this purpose, Mehndi designs often include depictions of the sun on the palm of the hand as a representation of the enlightened mind.
Henna is known for its “apothecary powers” and its “magical properties.”[44] “Depending on the culture, these henna-based talismans conjure spirits, celebrate prosperity, ritualize nuptials, offer protection or serve as intimate, erotic love charms.”[45] The use of henna is intimately tied to animistic beliefs. Some people also believe that henna is powerful because of its color.[46] According to one henna aficionado, “’In Morocco, they talk about different objects having a lot of baraka—power. The actual henna plant has a lot of that. And the design has a lot of baraka as well. And the art of Mehndi, an extremely private blessing, is a dialogue between the personal and the invisible.’”[47]
This dialogue between the personal and invisible has been a theme for more than five thousand years, and has woven itself into cultures and their sacred texts throughout Asia, Africa, and now most recently, the Americas and Europe. Ancient Egyptians painted their hands and feet with henna. From Egypt and other Northern African countries, mehndi spread to the Middle East from which it was most likely taken to India by the Persians when Mahmud of Ghazni invaded India during 1001-26 A.D., or by the forerunners of the Mugal empire around 1500 A.D.[48]
The Bible’s Song of Songs exalts the beauty of the henna plant: “My Beloved is like a cluster of henna flowers among the vines of Engedi.”[49] The Talmud, similarly, mentions that henna is a suitable remedy for urinary diseases. The Prophet Mohammed used henna to dye his beard, and his successors, the caliphs, followed suit. Murals from the 4th and 5th centuries, found in caves in Sri Lanka and India, portray the Hindu gods beautified with henna.[50] The plant’s cosmetic uses were documented in a Chinese text from 304 A.D.[51] The use of henna spread throughout the world, but the practices and their symbolism are more convergent than one might expect at first glance.
In ancient Egypt, henna was applied to the hands and feet of dead pharaohs. The Egyptians believed that naturally derived reddish substances, such as ochre, blood, and henna possessed traits that improved “human awareness of the earth’s energies.”[52] The Egyptians were also fond of painting themselves with henna throughout their lives as a way to remain in touch with the spiritual. Cleopatra intrigued Anthony by applying henna to her fingers, toenails, and palms.[53] Women of the common classes used henna to prepare for their transition from girl to bride. The night before the wedding, an Egyptian young woman’s hands and feet were bound up with henna in preparation for the festivities.[54]
The Arabs were the first to use henna to dye the hair.[55] In many Arab cultures, henna is often mixed with vinegar and made into a hot poultice used to treat boils and folliculitis lesions. The henna is thought to reduce pain and swelling.[56] Arabic medicine has also suggested it be used to lower body temperature in cases of high fever. [57] “The cultural aspect of traditional Arabic medicine developed from the ancient Arab civilization with a magic religious mode of thought that has prevailed throughout the civilization.”[58] Therefore, it is not altogether surprising that the aesthetic and the therapeutic became so intricately tied together.
In North Africa, desert nomads wrapped henna leaves around their hands and feet, believing it to have a cooling effect.[59] In the twelfth century, mehndi spread to India where the practice expanded.[60] Henna body-painting became a way to celebrate auspicious occasions, most often marriages and births. This is the time in which the art of mehndi became more organized and cohesive. Mehndi is practiced by Sikhs, Muslims, and Hindus, as well as by Jews, during festivals and among brides-to-be to mark their commitments with good fortune and celebrate their new status as women.[61] There are three main schools of henna design: Arabic, Indian, and Sudanese. The Arabic designs usually feature large patterns on the hands or feet. Indian designs, in comparison, are more fine-lined and paisley-styled. The Sudanese designs are grand and bold, with geometric angles and configurations.[62]
While there are different schools of design, the process of making the henna paste is very much similar across cultures. In order to use the henna to create temporary body tattoos, the henna leaves must be crushed into a soft powder and mixed with liquid to form a smooth paste. The paste is usually prepared the night before the application. Prior to applying the henna tattoo, the skin is washed with soap and water and softened with either eucalyptus oil or special mehndi oil. The henna paste is then applied either freehand or with some utensils such as a toothpick, stencil, or a tube with a pointed tip (such as those used in cake decorating). After the design is completed, the paste is allowed to remain on the skin. The intent is to allow the design to dry and darken, while at the same time preventing over-drying which can lead to the mehndi flaking off before it has cured. A mixture of two parts lemon juice and one part sugar is sometimes applied to the skin during the drying period to prevent flaking. Usually, the paste is left on the skin for at least four hours. However, the longer it remains on the skin, the darker and deeper the color will be.[63] One author has described the results as “imprints—deep red strokes that fade into the echo of an image.”[64] The image itself is perhaps not as important as the process and the cultural significance that the mehndi application has. As will be outlined below in four brief case studies, this cache is evident in settings as diverse as weddings and healing ceremonies.
Traditions follow the people who have performed them, even if the relocation is to a distant and alien place where the performance of the rituals is made more difficult by the dispersion of a cultural community and its resources. Cultural images from homelands weave themselves most predominantly into festive occasions, such as weddings.[65] The “transfer of images from one cultural context to another is an evident feature of the migration process” and is of great concern to urban anthropologists.[66] Weddings allow for the regrouping of communities, and the strengthening of cultural bonds, as anthropologist Pnina Werbner, noted in her study of immigrant Pakistani weddings and mehndi ceremonies in Great Britain.[67]
Often times, a mehndi ceremony is performed for the groom as well, but it is held in location separate from the bride’s celebration. The visiting party of women brings the mehndi, which is shaped into a dark cake and decorated with candles and tinsel or red and white flower petals. The “cake” is known as dulham, the word for bride and bridegroom (dulhan and dulha). The woman is seated under a red veil. Nuts, dates, and dried coconut (a mixture known as bid) are stuffed into the woman’s mouth and poured into her lap by the attendants. Afterwards, the dulham is lit with candles, and the bride’s hands and feet are decorated with intricate mehndi patterns. (If a ceremony takes place for him, the groom is usually decorated only with a round mark on each of his palms.) The women and the girls present at the mehndi rite decorate their own hands with the remaining paste. The decoration and celebration continue into the wee hours of the morning.[68]
The mehndi ceremony on the night before the wedding is punctuated with song. The older women sing lyrics of lamentation, while the younger women answer with songs of love. It is customary for the bride to weep. Insults are tossed back and forth between the bride and her attendants. The bride also receives joke gifts, many of which are sexual in nature.[69] Some of the younger women dance erotically. As the early morning comes, a ritual clown enters and the sexual innuendo increases as a way to make the bride feel more comfortable with the wedding night that is close at hand.[70] By this time, the bride has been painted with henna. When the henna is washed off and she takes a ritual bath, her hands are smeared with oil and heated over a stove or fire. After the heating, she is not permitted to wash her hands. The following day is usually the Nikah, the contract-signing ceremony where the young woman throws away her old clothes and puts on her wedding finery.[71]
The henna ceremony is marked by much symbolic significance. “Extreme heat, redness and light—signaled by the lit candles—and... ‘coldness’ (the mehndi) are juxtaposed.”[72] The mixture is supposed to bring about a “mysterious potentiality,” moving the couple from a state of separateness and coldness to one of heat and energy.[73] Henna contains the opposing qualities of hot and cold. It is interesting to note, from an anthropological perspective, that henna itself is “uniquely transformative, since it undergoes a visible transformation.”[74] Henna begins as a green plant, a kind of bush. The dried leaves, considered to be cold, are mixed with water, sugar, and lemon to form a dark paste that is viewed to have cooling properties. The paste itself is used to cool the feet and hands during hot summer months, and is also relied upon as a treatment for rashes and poxes, believed by many henna-using cultures to be caused by excessive heat within the bloodstream.[75] As henna dries upon the skin, it moves from light and cold, to dark and hot, as a cultural symbol. Perhaps, the symbolic heat of henna is nowhere more apparent than in the actual heating of the bride’s hands after mehndi. More generally speaking, henna is viewed as a bearer of vitality and life.
During the mehndi rite, the younger women at the bridal celebration often sing:
Light the oven in the garden/ Nowadays the girls wear side hair-partings and open wide trousers./The white cock is on the roof’s edge/The girl with the mauve dupatta, the boy is in love with you./The mango floats in the waterpot/With longing such as this/O that God had not caused me to be born.[76]
Anthropologists have interpreted these verses as a balancing and representation of the “cold” and “hot” properties and symbolic meanings inherent in the henna ceremony.[77] Regardless of how the bride and groom analyze the symbols of the ceremony, the mehndi rite is a critical component of the transition from lives as single persons to a marital unit.
Hindu pregnancy rites often contain elements of the marriage ceremony. Some anthropologists have viewed the symbols and rituals elaborated during this special time as a re-marriage of sorts.[78] During mid-pregnancy, the fourth or fifth month, some Hindu communities bathe the pregnant woman, dress her in new clothes, plait her hair, and stain her hands with henna. Her kinswomen sing songs throughout the night, with the hope of preventing miscarriage. Sweets are sent by her parents and placed in her lap.[79]
For some other community members, the seventh month of pregnancy marks the ritual. The woman’s parents bring her gifts, including henna.[80] She is then placed upon a stool in her husband’s house, dressed in a red suit, and tattooed on the hands with henna.[81] There are some deviations from this tradition, such as the wearing of a green suit.[82]
After the birth of a child, some Hindu communities observe a period of confinement for the mother. The duration can be up to forty days. During this time, the mother must not stain the palms of her hands with henna, until the ancestors have been worshipped appropriately and a feast provided for the kinsmen.[83]
In other communities, the kinswomen and local priest’s wife come to the mother who has just born a child to sing songs all night, with the rationale that the gods will offer the new child a better fate if they are awake and a lamp is kept burning. After the ceremony, the mother is allowed to eat grain and the child is dressed and adorned. If the child is a boy, mango leaves are hung on the door of the house and handprints are made on either side of it in, in the corners, with henna.[84]
Henna remains a thriving tradition among the Sephardic Jews as well. Brides and sometimes their grooms are tattooed with henna two nights before the wedding ceremony. Interestingly enough, the three letters which compose the word henna in Hebrew are an acronym for three mitzvot (commandments) directed solely towards women: challah (the twisted egg-based bread women traditionally bake); niddah (Jewish laws pertaining to menstruation and “family purity”); and candle-lighting.[85]
In Yemen, Jews often covered a bride’s body with henna dye. The person applying the henna paid for the privilege with a wedding gift. In this part of the world, the term “henna night” is synonymous with marriage.[86] Some communities in Israel still maintain this tradition. “Traditional mehndi is similar to prayer because it admits to the presence of forces beyond our comprehension.”[87] Here, the prayer is a communal one for the blessing of the marriage and the household that will flow from it.
Henna’s ritual use is not confined to auspicious occasions. Rather, it has been used in Africa by the Zar as a means of curing illnesses believed to be inflicted by malignant forces. The Zar are a healing cult of the Northern Sudan. They believe strongly in the influence of spirits on their psychological and physical well-being. Usually, people first resort to Islam for the healing of their illnesses, since the Zar are often associated with the “work of the devil” and “anti-Islamic” practices.[88] However, when established religion fails an afflicted individual, the source is considered to be possession by an evil spirit, and the Zar are called upon for relief.
Prior to a Zar healing ceremony, the afflicted individual must be kept clean, dress in clean and colorful clothing, be coated with perfume and incense periodically, and have his or her hands and feet daubed with henna.[89] The person is not expected to do any work, and must remain undisturbed and unprovoked. Once the ill person has reached this state of ritual preparedness, the ceremony can begin.
The ceremony usually lasts seven days, in which the possessed person is calmed and directed to rest. Relaxation is only interrupted for periods of dancing, as dancing is believed to relieve tension and please the spirit world. By the seventh day, the person is supposed to be more tranquil. The conclusion of the healing is marked by the meeting of the spirit’s demands (usually gifts of food, clothing, or other worldly goods), and a large sheep is offered in sacrifice. Before the sheep is slaughtered, its hindlegs, forelegs, and forehead are coated with henna.[90] The remains of the henna, sweets, blood, and bones of the sacrificed animal are thrown into the Nile to appease the spirits of the river.
After the sacrifice, the possessed person is sent into seclusion in his or her house. For women, the period may run as long as forty days,[91] during which time she may receive female visitors, but must not be called upon by men. During the isolation, perfumes, incenses, and henna are used to soothe and adorn her body, and her needs are attended to by others. Over time, the person is reincorporated into normal social life.[92] “The Zar is a cult which gives expression to the problems of the subordinate position of women in a male-dominated society. The Zar allows women to express these problems, to enjoy a temporary freedom, and to have their own way.”[93] The healing rituals are reminiscent of the kinds of attention and pampering that occur during the days before a woman’s wedding.
We rarely have skin and mucous membrane irritations from the color additions in food, drugs, and cosmetics. We have the rarity of lipstick dermatitis which is welcome by reformers and prohibitionists of cosmetics... In medical practice, we group these rare ill results under the term of ‘allergy’ which is mysterious until defined as altered reactivity. Then we know that name allergy doesn’t explain anything! It only gives a Latin name and places the whole matter into the oblivion of a pigeon-hole. But allergy doesn’t remain pigeon-holed for long. Each new piece of evidence drags the entire matter forth in the light of courts of law if not into the sunlight and rational laboratory procedures.[94]
The cynicism with cosmetics regulation expressed by the author of the excerpt featured above remains a thriving part of today’s food, drug, and cosmetics regulatory landscape. In the case of henna, there is a tension between thousands of years of assumedly safe ritual usage and the modern regulatory scheme of seizure and import regulation. In calling into question the appropriateness of mehndi products for the marketplace, the FDA is extending its arm and sweeping in a vast span of tradition, history, and culture. However, this maneuver may ultimately be beneficial to the protection of the health of the citizenry. Indeed, in simply considering the populations most affected by today’s henna regulations— newly arrived immigrants, English-as-a-second-language women, and innocent children—the FDA’s position on henna tattooing may be prudent and necessary. In order to resolve the issue of whether the FDA has gone too far in impinging upon cultural practices and communities, and the more general art of self-adornment, it is necessary to review the medical and scientific literature concerning henna usage.
Women in the Arab and Asian worlds began to use black henna because they were unable to obtain natural henna for body art.[98] There was a shortage in the market due to a strong import demand in places like Europe and Australia, which depleted the domestic supply. Black henna hair color was what was on-hand in times of dearth, and it carved out its own niche among low-income or uneducated users. In the U.S., black henna has managed to penetrate the henna supply due to miseducation about the seriousness of the side effects, as well as improper labeling from exporting countries.[99]
Some people have reportedly suffered dermatological side effects from black henna powder use, even when the powder itself has not tested positive for traces of PPD.[100] It could be that the other synthetic dyes and oxidizing chemicals in the powder are the cause. In many cases, henna products contain only 50% henna, with chemicals and fillers making up the other half.[101] Some of these additives include silver nitrate, carmine, titanium dioxide, ethylcellulose, barium peroxide, tartaric acid, and pyrogallol.[102] Carmine is very hazardous and can produce swelling and other PPD-mimicking symptoms. Silver nitrate can cause chemical burns which may not manifest for several days. The FDA requires that products called henna or that use henna on their label may not have such adulterations, and therefore, cannot be sold in the United States. However, in such exporting countries as India and Pakistan, contamination and mislabeling problems are rampant. This reality has forced the FDA to block the import of certain henna products.[103]
Adulterated henna products pose such great risks because of the time they are allowed to remain on the skin.[104] The treatment can span from one hour to overnight. Many of the adverse chemicals used to adulterate henna are traditionally found in hair colorings. These chemicals were never intended to be left on the skin, but rather applied to the dead shaft of the hair. In comparison to body paints and non-toxic pen ink, these chemicals can enter the bloodstream.[105]
The concern with black henna products has lulled many consumers into a false sense of security when they encounter other henna pastes or powders. PPD can be found in either black or red henna products.[106] Therefore, safety does not necessarily follow from the use of red henna. Red henna application has resulted in blood poisoning and tetanus.[107] The reactions may be due to the presence of iron oxide-- a frequent and illegal (in the U.S.) additive to red henna powders.[108] Other henna adulterants include lead, bacteria, fecal matter, unsafe colorants, pesticides, solvents, and skin irritating fillers. These additives have made henna users ill since at least the 1930’s.
Most at risk for allergies are henna body-art tourists who get it done while they are vacationing, rather than applying it themselves or having it done professionally in their home countries. While adulterating henna with PPD is also illegal in Europe, the arm of regulation doesn’t extend to countries such as Morocco, Thailand, and India where the system is not well regulated.[109]
Many individuals add herbs or other substances to henna in order to strengthen its longevity or increase the vibrancy of its color. Researchers in Morocco have been concerned that one of the dilutants used in henna body paint has been lead. Their investigation showed that lead concentrations in pure henna samples were low, while when henna was mixed with other products, the concentrations increased.[110] According to these researchers, misuse and misapplication of henna and other traditional remedies and cosmetics has escalated in recent years due to “ignorance, poverty, and illiteracy.”[111]
In the Moroccan study, twenty samples of henna were obtained from herbalists in the Marrakech markets. These samples consisted of fourteen red-colored, four black (mixed with chemicals such as para-phenylenediamine), and two green. The lead concentrations ranged from 2.2 to 6.5 Mg/g, with the highest lead concentrations being in the products with the additives. In general, however, the lead concentrations in the henna samples were not high enough to be of substantial concern.[112] Even with that said, an individual’s overall lifetime exposure to lead is important. There is increased recognition that even low levels of lead can result in neurological or neurobehavioral developmental delays and impairments in children exposed in utero or during early childhood. This lead exposure can come from the mother’s use of henna, or the application to the child itself. Taken in conjunction with the increase in the rate of infant mortality in Morocco by 57% in the urban population, and even more so in the rural areas, this dilemma can have larger dimensions that anticipated at first glance.[113]
Contact dermatitis to natural henna is rarely reported.[114] Most cases of dermatitis relate to the scented oils used in the tattoos, or PPD. In a case study of a twenty-five year old woman with allergic contact dermatitis at the site of her two henna tattoos, physicians concluded that she did not have an allergy to henna, and that the irritation must have resulted from the additives in the henna paste.[115]
According to a French study, as the use of henna skin painting has increased, the quality and purity of the henna pastes has declined.[116] Traveling artists are more likely than traditional artists to turn to “black henna” or hair dye to perform the tattooing. These mixtures can contain substances that produce side effects such as active sensitization, particularly to para-phenylenediamine and the other aromatic amines. The sensitization may result in a flare-up in the tattooed area, or contact dermatitis. Dermatitis occurs after an individual becomes sensitized and has new exposure to hapten or other similar molecules during tattooing or hair dying. The sensitivity is not limited to re-exposure to the henna paste, but can also be exacerbated by some textile dyes.[117]
In a Swiss study, four patients developed contact dermatitis from black henna tattoos that they received while vacationing in the Middle East and Asia.[118] Two to ten days after the tattooing, itchy, reddish swelling appeared at the tattoo site, following the outlines of the pattern. Patch testing demonstrated that the patients all experienced high sensitivity to p-phenylenediamine (PPD). The causative agent for the reactions did not appear to be the henna itself, but the PPD additive— most likely used to effect a darker color.[119]
Four patients developed allergic contact dermatitis after receiving pseudo-tattoos made from black henna.[120] These tattoos were purchased from itinerant henna artists in France, Egypt, and the United States. There was a delay in the appearance of symptoms, suggesting previous sensitization in one patient and active sensitization in three patients. Three patients underwent patch testing which yielded positive results for PPD. A positive patch test for p-toluylenediamine was also found in one patient. These sensitizers are found in hair dye.[121] The results suggested that the pastes used by the artists likely contained natural henna, which can act as a “rare and weak skin sensitizer,” and also probably contained chemical coloring agents, diaminobenzenes, such as p-phenylenediamine and diaminotoluenes.[122] “The long duration of skin contact, the high concentrations of sensitizing materials, and the lack of a neutralizing agent dramatically increase the risk of skin sensitization, which is why such substances are prohibited for direct skin application.”[123] The dermatologists involved in the study predicted that more cases of sensitization would be reported in coming years, as skin painting gains increased acceptance.
Finally, a Turkish study also reported allergic reactions, in the form of skin lesions, to henna tattoos applied to the arms of children. In one of the cases, the lesions after healing left hypo-pigmentation in the form of the original fish-shaped tattoo.[124] Unlike the mild to moderate irritation experienced by the participants in the other studies, these effects were of a more permanent nature.
The prevalence of PPD in henna pastes is most likely due to its accessibility. PPD is readily available in many local markets in such countries as the Sudan. Just because PPD can be purchased off of the shelf doesn’t mean that it is safe. Indeed, PPD can cause such severe toxic effects that it is often used in suicide attempts. Often times, however, the exposure to PPD is unintentional.
Poisoning by PPD-adulterated henna led to the hospitalization of 31 Sudanese children between 1984 and 1989.[125] All of the children had acute and severe angioneurotic edema and fifteen of the cases required an emergency tracheostomy to facilitate respiratory function. Acute renal failure happened in five children. Mortality rates were high with all thirteen deaths occurring within one day of admission.[126] The Sudanese clinicians called for a public education program, as well as the restriction and regulation of PPD in the Sudan. Ingestion of the henna was accidental in twelve of the children, deliberate in ten, and homicidal in three cases. Cutaneous absorption was highly probable in the remaining six cases. [127]
In another incident, a forty-year old Saudi Arabian woman became breathless after applying henna tattoos to herself at home.[128] She had received the paste from a neighbor, who had assured her that it was a special preparation made from a hair-dye mixture. Even without abrasions of the skin, hair dye can penetrate intact skin and result in systemic toxicity.[129]
Adults are not the only age cohort at risk for henna-instigated toxicity. While application over the body of newborns is quite rare, a recent Turkish pediatric medicine journal reported hemolytic anemia and acute renal failure in a 27-day-old boy who had been swabbed with henna to treat diaper rash.[130] In this case, the henna was probably resorted to due to its reputation for treating skin diseases such as seborrheic dermatitis or fungal infections.
One of the 250 agents reported as a source of occupational asthma is henna, which is of particular concern for hairdressers.[131] Occupational asthma can be fatal. Allergic reactions to henna tattoos could have a more permanent effect by preventing affected individuals from entering certain professions, such as hairdressing, leather work, rubber production, and several other industries.[132]A Moroccan study concluded that occupational asthma among hairdressers is linked to exposure to various hair dyes, bleaches, and colorants, including henna.[133]
While henna has met with skepticism and disapproval from sectors of the medical and scientific communities, its therapeutic uses should not be ignored. Researchers are experimenting with ways in which henna can be used as an alternative to more allergenic substances, and as a tool in radiotherapy. Both avenues seem to be pursuits with potentially large benefits.
Many individuals are already sensitized to oxidative dyes used for the coloring of the hair or skin. Vegetable-based dyes are often recommended to these consumers.[134] The most important of these low allergenic dyes is henna. A recent study reported that the incidence of contact dermatitis stemming from henna application was extremely rare.[135]
In another exploratory use of henna, Austrian physicians have decided to adopt mehndi as a replacement for other forms of skin markings in patients undergoing a course of external radiotherapy.[136] Henna was chosen because it stains the superficial skin layers for several weeks, can be subjected to water exposure, and resists the kind of shifting or distortion common with other radiotherapy marking techniques. In a trial conducted from November 1998 until March 2000, the physicians performed skin markings with henna in 158 patients receiving treatment for their tumors.[137] The median durability of the henna treatment was 23 days (range 12-48 days).[138] Most patients required two applications (range 1-4) to last the course of their treatment. Even with washing and showering allowed, no adverse cutaneous reactions (e.g., erythema, allergic reactions) were observed. The physicians found that the henna tattooing increased the accuracy of the treatments, and yielded “stable and invariable markings for the entire course of radiotherapy and also increased the comfort of the patients.”[139] The shifting common in other marking techniques can have a detrimental effect upon quality assurance and treatment outcome.
An alternative to the henna technique would have been permanent tattooing, but its drawbacks are obvious. The risk of infection is high, and the remnants of the therapy remain with the patient for the rest of his or her life. These factors make temporary, stable tattoos advantageous, and henna appears to be the best material for the task.[140]
Mehndi has been treated throughout the centuries as a household tradition. Women pass it down to the younger generations much like the stories of their ancestors or family culture. Even the henna blends applied to the skin are based on traditional and often family-based recipes. More recently, mehndi has managed to leach into Western culture, using a fashion world inspired by Eastern influences, as its vehicle. Mehndi has moved from the personal to the public sphere, even finding a home at galleries across the country willing to host mehndi exhibits. For example, in New York, “The Mehndi Project” combined application of henna to the bodies of patrons with a photographic display of the intricate, lace-like designs.[141]
At the same time, henna has also evoked local concern. The Santa Monica City Council banned the application of henna tattoos in November 2001.[142] Prior to that time, the henna art trade was thriving on the Promenade and the Santa Monica Pier. One henna tattoo that did not disappear led a woman to sue the city, prompting this response by the city council. According to the city attorney’s records, the suit was dismissed in September 2000, five months after it was filed, but it did raise concerns about the safety of the henna dyes.[143] The city contended that the henna tattoos were not banned for sheer safety reasons. It did not want the activity happening on the Promenade because it felt that the space was for entertainment, and that henna designs were so closely aligned to tattooing as to fall outside of the definition of entertainment.[144] The henna artists have responded by contending that they deserve the same space on the Promenade as sketch artists, balloon makers, and face painters, but the ban remains in place.
The proliferation of henna and henna-based products has raised the concern of the FDA, while also provoking the fears of immigrant and minority communities worried that their cultural traditions are subject to interference, if not outright ban. There is this incredible tension between protecting innocent consumers and respecting the autonomy of a practice that has spanned thousands of years. The FDA may be more concerned about the temporary tattoo of henna than with permanent tattooing because henna is more within arm’s reach if it is treated, as it has been, as a cosmetic and color additive.
A market-based analysis also lends support to the argument that the FDA has become involved in the henna debate because it can rather easily. As mehndi gains popularity, it goes from the realm of the private—the family-oriented tradition of preparing a bride for her rite of passage—to the commercial. It appears that mehndi is a part of the larger “cult surrounding body art.”[145] Now that it is booming within white, Western communities, more Mehndi artists are making their services available. Mehndi artists can command fees ranging from $150 to $1500 for just one wedding.[146]
However, given that medical researchers have resorted to henna in the course of radiologic treatment for cancer and other ailments,[147] it is not entirely clear that henna tattooing is the insidious force that the FDA fears, as represented by its import seizures and strict insistence upon henna for hair usage only. Rather, the existing research reveals that henna itself may be safe, but that it is the dilutents and additives that become part of the pastes and powders that should be subject to scrutiny and regulation. Communities will continue with their mehndi practices regardless of the FDA’s warning labels. Unlike the tattoos themselves, the trend does not seem to be fading, but gathering more support and interest as people of Western descent are exposed to the ancient art form. Therefore, the role of the FDA should be to reexamine the question of how henna should be used. With proper study, the FDA might conclude that henna is not only safe as a hair dye, but as applied to the skin. With this knowledge, the FDA could then stringently enforce a policy of additive-free henna body-painting products—eliminating the “black” and “blue henna” from the shelves.
Of course, this strategy neglects a large source of henna-related problems. The source is professional application. Here, the FDA needs to examine the larger tattoo debate and adopt a consistent policy. The FDA would be speaking with a forked tongue if it chose to aggressively regulate henna tattoo establishments, while casting a glance in the other direction when it came to permanent tattoo parlors. An examination of the dangers of permanent tattooing is outside of the scope of this paper, but a cursory survey of the literature reveals that the same problems of scarring, dermatological difficulties, and allergic reactions exist in that area as well—indeed, with greater severity and longer term effects.
As body art practices are on the rise, the FDA should institute a task force to investigate where limited resources, finances, and staff should be directed. The current approach to intervene in the temporary tattoo trade is an initial step towards expressing public concern for the safety of a booming industry, but it falls short of addressing the potential public health concerns in a coherent, consistent manner. In the face of constraints, the FDA must act in a triage-driven fashion. With further study, the FDA may well determine that the larger obstacles are faced by the permanent tattooing industry, and that the complaints registered concerning henna tattooing are as well within control as can be expected.
[1] Grace Ziegler. “The Diuturnal Use of Perfumes and Cosmetics.” Scientific Monthly. Volume 34, Issue 3. (March 1932). 222-237.
[2] Oumeish Youssef Oumeish. “The cultural and philosophical concepts of cosmetics in beauty and art through the medical history of mankind.” Clinics in Dermatology. 2001; 19:375.
[3] Gary Drevitch. “Body art or body mutilation?” Scholastic Choices. New York. Volume 16, Issue 5. February 2001. 6-9.
[4] FDA Advisory Opinion. 21 CFR 10.85(c). Docket No. 81A-0315/AP. (1986)
[5] U.S. Food and Drug Administration- Center for Devices and Radiological Health. “Tattoo Equipment and Dyes.” August 17, 2001.
[6] FDA Advisory Opinion. 21 CFR 10.85(c). Docket No. 81A-0315/AP. (1986)
[7] Id.
[8] Id.
[9] U.S. Food and Drug Administration- Center for Devices and Radiological Health. “Tattoo Equipment and Dyes.” August 17, 2001.
[10] U.S. Food and Drug Administration. Center for Food Safety and Applied Nutrition. Office of Cosmetics and Colors Fact Sheet. November 29, 2000. “Tattoos and Permanent Makeup.”
[11] Id.
[12] Id.
[13] Id.
[14] Id.
[15] U.S. Food and Drug Administration- Center for Devices and Radiological Health. “Tattoo Equipment and Dyes.” August 17, 2001.
[16] U.S. Food and Drug Administration. Center for Food Safety and Applied Nutrition. Office of Cosmetics and Colors Fact Sheet. November 29, 2000. “Tattoos and Permanent Makeup.”
[17] FDA Important Alert #53-14, 5/23/94. “Intensified Coverage of Temporary Tattoos Containing Non-Permitted Color Additives and/or Failing to Bear Ingredient Declarations.”
[18] Id.
[19] Id.
[20] Id.
[21] Id.
[22] U.S. Food and Drug Administration. Center for Food Safety and Applied Nutrition. Office of Cosmetics and Colors Fact Sheet. November 29, 2000. “Tattoos and Permanent Makeup.”
[23] Karl Wurstbauer, Felix Sedlmayer, and H. Dieter Kogelnik. “Skin markings in external radiotherapy by temporary tattooing with henna: Improvement of accuracy and increased patient comfort.” International Journal of Radiation Oncology. Volume 50, Issue 1. May 1, 2001. 179-181.
[24] U.S. Food and Drug Administration. Center for Food Safety and Applied Nutrition. Office of Cosmetics and Colors Fact Sheet. November 29, 2000. “Tattoos and Permanent Makeup.”
[25] Id.
[26] 21 CFR 73.2190 “Food and Drugs: Listing of Color Additives Exempt from Certification: Henna”
[27] J.L. Hopkins & Co., Inc. v. United States, 34 C.C.P.A. 67 (United States Court of Customs and Patent Appeals), 1946.
[28] FDA Important Alert #53-19, 8/5/97, “Detention Without Physical Examination of Henna Based Skin Color.” Attachment Revised 12/7/01.
[29] U.S. Food and Drug Administration. Center for Food Safety and Applied Nutrition. Office of Cosmetics and Colors Fact Sheet. April 18, 2001. “Temporary Tattoos and Henna/Mehndi.”
[30] Id.
[31] Id.
[32] Id.
[33] Id.
[34] Id.
[35] Id.
[36] Id.
[37] FDA Important Alert #53-19, 8/5/97, “Detention Without Physical Examination of Henna Based Skin Color.” Attachment Revised 12/7/01.
[38] Id.
[39] FDA Important Alert #53-19, 8/5/97, “Detention Without Physical Examination of Henna Based Skin Color.” Attachment Revised 12/7/01.
[40] Karl Wurstbauer, Felix Sedlmayer, and H. Dieter Kogelnik. “Skin markings in external radiotherapy by temporary tattooing with henna: Improvement of accuracy and increased patient comfort.” International Journal of Radiation Oncology. Volume 50, Issue 1. May 1, 2001. 179-181.
[41] “Mehndi.” http://www.rajtourism.com/html/fairsfestivals/Teej/mehndi.htm
[42] George Ahmed. “Mehndi- The Vital Ingredient in Any Wedding.” http://www.shadicards.com/Mehndi.htm
[43] Ron Csillag. “A Tradition to Dye For.” The Toronto Star. September 25, 1999. Life section.
[44] Lynell George. “A Mysterious Mix of Artistry and Spirtuality, Mehndi Meets the Trend-Conscious, Skin-Baring Denizens of L.A. with the Opening of a New Exhibit.” Los Angeles Times. Life & Style. January 16, 1997. E2.
[45] Id.
[46] E. Westermarck. “The Magic Origin of Moorish Designs.” Journal of the Anthropological Institute of Great Britain and Ireland. Volume 34 (July-December 1904). 212.
[47] Lynell George. “A Mysterious Mix of Artistry and Spirtuality, Mehndi Meets the Trend-Conscious, Skin-Baring Denizens of L.A. with the Opening of a New Exhibit.” Los Angeles Times. Life & Style. January 16, 1997. E2.
[48] “Mehndi.” http://www.rajtourism.com/html/fairsfestivals/Teej/mehndi.htm
[49] Praise for henna can also be found in other texts. For example, a passage from Flaubert’s Salambo demonstrates the importance of henna to personal adornment. The servant of Hamilcar’s daughter “tinted with henna the inside of the hands of her mistress, touched her cheeks with vermilion, put antimony on her eyelids, and lengthened her eyebrows with a mixture of gum, musk, ebony, and crushed flies’ feet.” See Grace Ziegler. “The Diuturnal Use of Perfumes and Cosmetics.” Scientific Monthly. Volume 34, Issue 3. (March 1932). 231.
[50] Ron Csillag. “A Tradition to Dye For.” The Toronto Star. September 25, 1999. Life section.
[51] Id..
[52] Atiya Achakulwisut and Karnjariya Sukrung. “Hand art.” Bangkok Post. April 18, 1999. News Section.
[53] Herman Goodman. “Color in Food, Cosmetics, and Drugs.” Scientific Monthly. Volume 47, Issue 1 (July 1938). 41.
[54] E.E. Perkins. “Marriage Ceremony in Lower Egypt.” Man. Volume 32. March 1932. 63.
[55] Oumeish Youssef Oumeish. “Traditional Arabic Medicine in Dermatology.” Clinics in Dermatology. 1999; 17:15.
[56] Oumeish Youssef Oumeish. “Traditional Arabic Medicine in Dermatology.” Clinics in Dermatology. 1999; 17:19.
[57] N. Lekouch, A. Sedki, A. Nejmeddine, S. Gamon. “Lead and traditional Moroccan pharamcopoeia.” The Science of the Total Environment 280 (2001) 40.
[58] Oumeish Youssef Oumeish. “Traditional Arabic Medicine in Dermatology.” Clinics in Dermatology. 1999; 17:13.
[59] See Paul Bohannan. “Beauty and Scarification Amongst the Tiv.” Man. Volume 56 (September 1956), 117-121. The Tiv are the largest tribe of the Benue Valley of Nigeria. Under their notions of beauty, it is desirable for the body to glow. Many rituals surround reaching this point of luminescence. A central component of beautification is cosmetics. The Tiv dye their palms and fingernails with henna, often keeping gourds of henna paste fastened over their wrists for days at a time.
[60] Women and children often get mehndi designs before the holiday of Diwali, the Hindu Festival of Lights. Hindus believe that Lakshni, the goddess of prosperity, lives in henna designs. Muslim women also get henna tattoos on festivals, birthdays, and other occasions—such as baby showers—as a way of expressing happiness. In Islamic places of worship, henna cosmetics and tattoos are permitted because they are considered to be natural; the same is not true for commercial cosmetics and nail polishes. See generally Ron Csillag. “A Tradition to Dye For.” The Toronto Star. September 25, 1999. Life section.
[61] Ron Csillag. “A Tradition to Dye For.” The Toronto Star. September 25, 1999. Life section.
[62] Atiya Achakulwisut and Karnjariya Sukrung. “Hand art.” Bangkok Post. April 18, 1999. News Section.
[63] “Mehndi.” http://www.rajtourism.com/html/fairsfestivals/Teej/mehndi.htm
[64] Lynell George. “A Mysterious Mix of Artistry and Spirtuality, Mehndi Meets the Trend-Conscious, Skin-Baring Denizens of L.A. with the Opening of a New Exhibit.” Los Angeles Times. Life & Style. January 16, 1997. E2. The henna tattoo lasts from two to six weeks, depending on skin type, the area of the body it is applied to, sun exposure, and other factors such as bathing and activity level.
[65] See Pnina Werbner. “The Virgin and the Clown Ritual Elaboration in Pakistani Migrants’ Weddings.” Man. Volume 21, Issue 2. June 1986. 227-250.
[66] Pnina Werbner. “The Virgin and the Clown Ritual Elaboration in Pakistani Migrants’ Weddings.” Man. Volume 21, Issue 2. June 1986. 227.
[67] Pnina Werbner. “The Virgin and the Clown Ritual Elaboration in Pakistani Migrants’ Weddings.” Man. Volume 21, Issue 2. June 1986. 230.
[68] Pnina Werbner. “The Virgin and the Clown Ritual Elaboration in Pakistani Migrants’ Weddings.” Man. Volume 21, Issue 2. June 1986. 234.
[69] Pnina Werbner. “The Virgin and the Clown Ritual Elaboration in Pakistani Migrants’ Weddings.” Man. Volume 21, Issue 2. June 1986. 232.
[70] Pnina Werbner. “The Virgin and the Clown Ritual Elaboration in Pakistani Migrants’ Weddings.” Man. Volume 21, Issue 2. June 1986. 243.
[71] Pnina Werbner. “The Virgin and the Clown Ritual Elaboration in Pakistani Migrants’ Weddings.” Man. Volume 21, Issue 2. June 1986. 235.
[72] Pnina Werbner. “The Virgin and the Clown Ritual Elaboration in Pakistani Migrants’ Weddings.” Man. Volume 21, Issue 2. June 1986. 237.
[73] Id.
[74] Pnina Werbner. “The Virgin and the Clown Ritual Elaboration in Pakistani Migrants’ Weddings.” Man. Volume 21, Issue 2. June 1986. 238.
[75] Id.
[76] Pnina Werbner. “The Virgin and the Clown Ritual Elaboration in Pakistani Migrants’ Weddings.” Man. Volume 21, Issue 2. June 1986. 239-240.
[77] Id.
[78] H.A. Rose. “Hindu Pregnancy Observances in the Punjab.” Journal of the Anthropological Institute of Great Britain and Ireland. Volume 35. July-December 1905. 271.
[79] H.A. Rose. “Hindu Pregnancy Observances in the Punjab.” Journal of the Anthropological Institute of Great Britain and Ireland. Volume 35. July-December 1905. 273-4.
[80] H.A. Rose. “Muhammadan Pregnancy Observances in the Punjab.” Journal of the Anthropological Institute of Great Britain and Ireland. Volume 35 (July-December 1905), 279-282.
[81] H.A. Rose. “Muhammadan Pregnancy Observances in the Punjab.” Journal of the Anthropological Institute of Great Britain and Ireland. Volume 35 (July-December 1905), 279.
[82] Id..
[83] H.A. Rose. “Hindu Birth Observances in the Punjab.” Journal of the Anthropological Institute of Great Britain and Ireland. Volume 37. July-December 1907. 227.
[84] H.A. Rose. “Hindu Birth Observances in the Punjab.” Journal of the Anthropological Institute of Great Britain and Ireland. Volume 37. July-December 1907. 230.
[85] Ron Csillag. “A Tradition to Dye For.” The Toronto Star. September 25, 1999. Life section.
[86] Id..
[87] Id.
[88] Ahmed al-Shahi. “Spirit Possession and Healing: The ZAR among the Shaygiyya of the Northern Sudan.” Bulletin (British Society of Middle Eastern Studies). Volume 11, Issue 1 (1984). 29.
[89] Ahmed al-Shahi. “Spirit Possession and Healing: The ZAR among the Shaygiyya of the Northern Sudan.” Bulletin (British Society of Middle Eastern Studies). Volume 11, Issue 1 (1984). 33.
[90] Ahmed al-Shahi. “Spirit Possession and Healing: The ZAR among the Shaygiyya of the Northern Sudan.” Bulletin (British Society of Middle Eastern Studies). Volume 11, Issue 1 (1984). 34.
[91] The significance of the forty day period is unclear, but the reader may recall that it was also a part of the Hindu pregnancy rites.
[92] Ahmed al-Shahi. “Spirit Possession and Healing: The ZAR among the Shaygiyya of the Northern Sudan.” Bulletin (British Society of Middle Eastern Studies). Volume 11, Issue 1 (1984). 34-35.
[93] Ahmed al-Shahi. “Spirit Possession and Healing: The ZAR among the Shaygiyya of the Northern Sudan.” Bulletin (British Society of Middle Eastern Studies). Volume 11, Issue 1 (1984). 39.
[94] Herman Goodman. “Color in Food, Cosmetics, and Drugs.” Scientific Monthly. Volume 47, Issue 1 (July 1938). 43.
[95] Lena Corner. “When a passing fad leaves a lasting scar.” The Independent (London). August 17, 2001. 7.
[96] Id.
[97] Id.
[98] Marie Anakee. “Safety Issues Concerning Henna.” http://www.angelfire.com/ak/anakee/mehndi3.html
[99] Id.
[100] Id.
[101] Id.
[102] Id.
[103] Id.
[104] Id.
[105] Id.
[106] Id.
[107] Id.
[108] Id.
[109] Tamara Thiessen. “Hands up who’s got a... Henna Allergy?” The Straits Times (Singapore). July 15, 2001. World, p. 7.
[110] N. Lekouch, A. Sedki, A. Nejmeddine, S. Gamon. “Lead and traditional Moroccan pharamcopoeia.” The Science of the Total Environment 280 (2001) 39.
[111] Id.
[112] N. Lekouch, A. Sedki, A. Nejmeddine, S. Gamon. “Lead and traditional Moroccan pharamcopoeia.” The Science of the Total Environment 280 (2001) 41.
[113] N. Lekouch, A. Sedki, A. Nejmeddine, S. Gamon. “Lead and traditional Moroccan pharamcopoeia.” The Science of the Total Environment 280 (2001) 42.
[114] N. Raison-Peyron, L. Meunier, L. Vian, and J. Meynadier. “Contact dermatitis caused by labile henna skin tattoo.” Annales de Dermatologie et de Venereologie. Volume 127, Issue 12. December 2000. 1083-1086.
[115] Id.
[116] See C.J. Le Coz. “Hazards of skin painting (pseudotattooing) with ‘black henna.’” Revue Française d’Allergologie et d’Immunologie Clinique. Volume 41, Issue 5. August 2001. 504-509.
[117] C.J. Le Coz. “Hazards of skin painting (pseudotattooing) with ‘black henna.’” Revue Française d’Allergologie et d’Immunologie Clinique. Volume 41, Issue 5. August 2001. 504.
[118] S. Läuchl and S. Lautenschlager. “Contact dermatitis after temporary henna tattoos—an increasing phenomenon.” Swiss Medicine Weekly. Volume 131, Issue 13-14. April 7, 2001. 199-202.
[119] Id.
[120] C.J. Le Coz, C. Lefebvre, F. Keller, and E. Grosshans. “Allergic contact dermatitis caused by skin painting (pseudotattooing) with black henna, a mixture of henna and p-phenylenediamine and its derivatives.” Archives of Dermatology. Volume 136, Issue 12. December 2000. 1515-1517.
[121] C.J. Le Coz, C. Lefebvre, F. Keller, and E. Grosshans. “Allergic contact dermatitis caused by skin painting (pseudotattooing) with black henna, a mixture of henna and p-phenylenediamine and its derivatives.” Archives of Dermatology. Volume 136, Issue 12. December 2000. 1515
[122] Id.
[123] Id.
[124] M. Onder, C.A. Atahan, P. Ozta, and M.O. Ozta. “Temporary henna tattoo reactions in children.” International Journal of Dermatology. Volume 40, Issue 9. September 2001. 577-579.
[125] M. Hashim, Y.O. Hamza, B. Yahia, F.M. Khogali, and G.I. Sulieman. “Poisoning from henna dye and para-phenylenediamine mixtures in children in Khartoum.” Annals of Tropical Paediatrics. Volume 12, Issue 1. 1992. 3-6.
[126] M. Hashim, Y.O. Hamza, B. Yahia, F.M. Khogali, and G.I. Sulieman. “Poisoning from henna dye and para-phenylenediamine mixtures in children in Khartoum.” Annals of Tropical Paediatrics. Volume 12, Issue 1. 1992. 3.
[127] Id.
[128] Kamil Abdulla and Neil Davidson. “Case Report: A woman who collapsed after painting her soles.” The Lancet. Volume 348. September 7, 1996. 658.
[129] Id.
[130] C. Devecioglu, S. Katar, O. Dogru, and M. Tas. “Henna-induced hemolytic anemia and acute renal failure.” The Turkish Journal of Pediatrics. Volume 43, Issue 1. January-March 2001. 65-66.
[131] Katherine Venables and Moira Chan-Yeung. “Occupational asthma.” The Lancet. May 17, 1997. Volume 349: 1465-69.
[132] Tamara Thiessen. “Hands up who’s got a... Henna Allergy?” The Straits Times (Singapore). July 15, 2001. World, p. 7.
[133] C.H. Laraqui Hossini, A. Alaoui Yazidi, O. Laraqui Hossini, A. Rahhali, K. Harourate, M. Mounassif, C. Verger and M. Zahraoui. “Respiratory clinical symptoms and lung function of hairdressers in Meknes.” Revue Française d’Allergologie et d’Immunologie Clinique. Volume 41, Issue 5. August 2001. 484-490.
[134] J.C. García Ortiz, M. Terron, and J. Bellido. “Contact allergy to henna.” International Archives of Allergy and Immunology. Volume 114, Issue 3. November 1997. 298-299.
[135] Id.
[136] Karl Wurstbauer, Felix Sedlmayer, and H. Dieter Kogelnik. “Skin markings in external radiotherapy by temporary tattooing with henna: Improvement of accuracy and increased patient comfort.” International Journal of Radiation Oncology. Volume 50, Issue 1. May 1, 2001. 179-181.
[137] Karl Wurstbauer, Felix Sedlmayer, and H. Dieter Kogelnik. “Skin markings in external radiotherapy by temporary tattooing with henna: Improvement of accuracy and increased patient comfort.” International Journal of Radiation Oncology. Volume 50, Issue 1. May 1, 2001. 179.
[138] Id.
[139] Id.
[140] Karl Wurstbauer, Felix Sedlmayer, and H. Dieter Kogelnik. “Skin markings in external radiotherapy by temporary tattooing with henna: Improvement of accuracy and increased patient comfort.” International Journal of Radiation Oncology. Volume 50, Issue 1. May 1, 2001. 179-181.
[141] Lynell George. “A Mysterious Mix of Artistry and Spirtuality, Mehndi Meets the Trend-Conscious, Skin-Baring Denizens of L.A. with the Opening of a New Exhibit.” Los Angeles Times. Life & Style. January 16, 1997. E2.
[142] Sufiya Abdur-Rahman. “Henna Artists Protest Ban.” Los Angeles Times. January 11, 2002.
[143] Id.
[144] Id.
[145] Lynell George. “A Mysterious Mix of Artistry and Spirtuality, Mehndi Meets the Trend-Conscious, Skin-Baring Denizens of L.A. with the Opening of a New Exhibit.” Los Angeles Times. Life & Style. January 16, 1997. E2.
[146] George Ahmed. “Mehndi- The Vital Ingredient in Any Wedding.” http://www.shadicards.com/Mehndi.htm
[147] Henna is believed to be useful for sciatica when applied to the back. It is mixed with vinegar and applied to the forehead to treat headaches. When chewed, it is beneficial in addressing the problems of oral ulcers. Henna can be painted on brittle nails to increase their strength. See Oumeish Youssef Oumeish. “The cultural and philosophical concepts of cosmetics in beauty and art through the medical history of mankind.” Clinics in Dermatology. 2001; 19:384.