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Evidence of dioxins, According to WHO, it takes It is estimated the average

phthalates and other between 7-11 years for the women will use over 11,000
carcinogens like furans body to eliminate just 50% tampons or menstrual pads
in six tampon brands. of all dioxins it contains. over her lifetime – many
Because of this, intrauterine health experts agree that this
exposure to dioxin could have level of repeated exposure to
implications for unborn toxins like dioxin is proble-
children during pregnancy. matic.

Why the toxic tampon


issue isn’t going away
A briefing paper
Rune Leithe

WHAT’S THE ISSUE? WHY SHOULD WE BE WORRIED?


In the past year, scientists and health professionals A series of reports and investigations have drawn media
have voiced growing concern over the potential risks attention to this issue, fuelling public concern and protest.
of using tampons and other personal hygiene products Notable research includes the 2013 Chem Fatale study1
such as diapers. Increasing evidence suggests some of which highlighted potential health concerns relating to
these products contain trace levels of toxins that, over toxic and allergenic chemicals found in feminine care
time, could pose a significant health risk to those who products, and the 2017 French documentary Tampons,
use them. These toxins include dioxins and phthalates, our closest enemy2 which found evidence of dioxins,
both classed as endocrine disruptors which are coming phthalates and other carcinogens like furans in six tam-
under increased scrutiny. New research is now linking pon brands.
the presence of dioxin and phthalates in these products
back to the original production process – dioxin from Also in 2017, France’s National Institute of Consump-
the chlorine used to bleach the material and phthalates tion’s 60 million consumers magazine published test
which are added to the plastic compounds in these ma- results showing similar potentially toxic substances in a
terials. The manufacturers of these products are failing range of tampon and diaper brands it analysed 3. These
to disclose the use of these harmful chemicals, which is findings reportedly went viral on Asian blogs targeted at
heightening these risks further. mums, leading to national reports4 of sales of Pampers

1. https://www.womensvoices.org/wp-content/uploads/2013/11/Chem-Fatale-Repor t.pdf
2. http://balanga.tv/film/tampon-our-closest-enemy/
3. https://www.60millions-mag.com/kiosque/aler te-sur-les-tampons-et-protections-feminines
4. m.koreatimes.co.kr/pad/news/view.jsp?req_newsidx=223249

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diapers being halted in South Korea and the launch of a health and environmental effects and on their alterna-
government safety probe. US activists have since called tives” especially for women and children.
for new rules5 to force manufacturers to disclose the
chemicals and materials they use in tampons and other Phthalates meanwhile have been linked to breast cancer,
menstrual products, following the introduction of a new diabetes, asthma, altered reproductive development
Congress bill, the Menstrual Products Right to Know Act 6. and low IQ. The human health effects from exposure
to low levels of phthalates are not yet fully known, but
Despite these developments, the chemicals used in such are being studied by government agencies around the
products remain for the most part, unregulated and world. The healthcare costs 12 of exposure to these types
authorities seem unwilling to act. As far back as 2002, of endocrine disruptors within the EU alone is estimated
a study 7 co-authored by a researcher working for the to be in the region of 157 billion a year – more than 1%
US Environmental Protection Agency found various of European GDP.
dioxins and furans in four tampon brands, yet suggested
that the use of tampons and diapers did not contribute HOW DOES REGULAR TAMPON USE
significantly to dioxin exposure. However assumptions INCREASE THESE RISKS?
were made in estimating these tampon dioxin exposure Feminine hygiene products are worn either inside the
levels, and these estimates varied significantly. There body or close to the skin, which makes women especially
still remains a lack of evidence on the direct and cumu- vulnerable to any adverse health effects. Such products
lative exposure of these toxins to intimate body tissues. are intended for use on vaginal and vulvar tissue – tissue
that is structurally different and more sensitive than
WHAT ARE THE HEALTH RISKS OF skin on other parts of the body. This tissue is also more
THESE TOXINS? hydrated and permeable, aiding the transfer of chemi-
Dioxins belong to a ‘dirty dozen’ group of chemically- cals direct into the bloodstream without being properly
related compounds known as persistent organic pollu- metabolised or eliminated. The Chem Fatale report 13
tants (POPs) and as such, are classed as very dangerous highlights one study that found when hormonal steroids
by the World Health Organisation (WHO) 8 . were administered vaginally, the resulting levels of the
Dioxin is a cancer causing agent, but even at very low drug in the body were 10-80 times higher compared to
levels it can cause other adverse health effects including the same dose administered orally.
reproductive problems and hormone interference.
It is estimated the average women will use over 11,000
Dioxin exposure for women can increase the risk of tampons or menstrual pads over her lifetime – many
pelvic inflammatory disease and endometriosis – one of health experts14 agree that this level of repeated exposure
the studies highlighted in Tampons, our closest enemy 9 to toxins like dioxin is problematic, especially as dioxin
found that patients with endometriosis had higher can bioaccumulate in the human body due to its ability
levels of dioxins in their bodies, a finding reflected in to be absorbed and stored by fatty tissue. According to
other research10. It should be noted that once dioxins WHO, it takes between 7-11 years for the body to elimi-
are released into the environment, they bioaccumulate nate15 just 50% of all dioxins it contains. Because of this,
and are very slow to disintegrate so repeated exposure to intrauterine exposure to dioxin could have implications16
them – as in the case of monthly tampon or daily diaper for unborn children during pregnancy, while breast
use – may heighten these risks further. milk can also be a source of dioxin exposure.

Regulation that aims to eliminate or severely restrict This may cause effects on children later in life such as
the production and use of dioxin and other POPs exists changes in liver function, thyroid hormone levels, and
under the Stockholm Convention on Persistent Organic decreased learning capability. Diapers containing dioxins
Pollutants11, an international treaty that is legally also pose similar risks to babies and young infants in
binding. Among other things, the Convention calls on terms of frequency of use – newborn babies may require
relevant parties to promote “educational and public around 12 nappy changes 17 a day. In September 2017,
awareness programmes on POPs, as well as on their German TV broadcaster ZDF found dioxins in one of
five tested diapers18.
5. https://www.nytimes.com/2017/05/24/well/live/period-activists-want-tampon-makers-to-disclose-ingredients.html
6. https://www.congress.gov/bill/115th-congress/house-bill/2416
7. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1240689/pdf/ehp0110-000023.pdf
8. www.who.int/mediacentre/factsheets/fs225/en/
9. http://balanga.tv/film/tampon-our-closest-enemy/
10. https://academic.oup.com/humrep/article/12/2/373/677006
11. www.pops.int/TheConvention/Overview/TextoftheConvention/tabid/2232/Default.aspx
12. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4399291/
13. https://www.womensvoices.org/wp-content/uploads/2013/11/Chem-Fatale-Report.pdf
14. https://www.theguardian.com/lifeandstyle/2016/mar/21/tampon-health-concerns-toxic-shock-syndrome-menstruation-women
15. www.who.int/mediacentre/factsheets/fs225/en/
16. www.health.state.mn.us/divs/eh/risk/chemhazards/dioxins.html
17. https://www.babycentre.co.uk/a1053592/10-tips-for-newborn-nappy-changing
18. https://www.zdf.de/verbraucher/wiso/schadstoffe-in-windeln-100.html

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The absorbent nature of tampons has also been strongly Rivasi wrote to the European Commission raising the
linked to Toxic Shock Syndrome (TSS), as illustrated in issue of non-disclosure, but her concerns were disre-
the case of P&G having to recall 19 its Rely tampon brand garded 26. Since then, France’s Directorate-General for
in 1980 after a study published by US agency Centers Competition, Consumer Affairs & Fraud Control has
for Disease Control & Prevention found that women released a statement 27 on the findings of its own investi-
who used high-absorbency tampons had a 17 to 30 times gation into tampon safety, claiming that they pose no
higher risk of getting TSS. Reported cases of TSS have serious nor immediate danger – this is despite their
significantly decreased since the 1980s, but one promi- analysis revealing traces of dioxins, phthalates and
nent researcher in this field, Philip Tierno20, has isolated other toxins. Meanwhile in the US, it remains to be seen
the bacterial toxin that causes TSS from Rayon, a tam- whether the recently introduced 28 Menstrual Products
pon fibre made from wood-based cellulose. As Rayon Right to Know Act will eventually pass into law.
may contain traces of dioxin, the by-product from its
production21, questions need to be asked whether dioxin WHAT NEEDS TO HAPPEN NOW?
exposure is a contributory factor to TSS as well. It’s important to recognise that the root of the problem
goes back to the production process, in particular the
WHAT IS BEING DONE ABOUT IT? bleaching process used for these products. Most of the
Very little. One of the problems is the lack of account- cellulose fibres contained within these products will have
ability and disclosure by regulators and manufacturers. been bleached using a technology known as Elemental
According to reports 22, the US Food & Drug Admini- Chlorine Free (ECF). The name is slightly misleading
stration (FDA) says the bleaching methods for Rayon as ECF uses chlorine dioxide, which poses various
tampons that leave trace amounts of dioxin in the dangers 29, both to human health and the wider environ-
products are no longer in use – but the FDA’s claim ment.
seems reliant on dioxin test data submitted by tampon
manufacturers which is not publicly available. It’s also One of these risks is that the ECF bleaching process can
worth noting that FDA industry guidance 23 on chemical leave a chlorine ‘footprint’ in the final product (tampon,
residues recommends that manufacturers identify the menstrual pad or diaper) in the form of trace amounts
bleaching process used for tampons and menstrual pads of dioxins. These chemical residues will stay embedded
– this includes Elemental Chlorine-Free (ECF) which in the product throughout its entire lifecycle, as proven
can still release dioxins (see next section What needs to by the various safety tests carried out on such products
happen now?). mentioned previously. The use of ECF also generates
other chlorinated compounds during the production
In the US, tampons are classified as medical devices process such as AOX (Adsorbable Organic Halides)
which means that there’s no packaging labelling require- emissions and more acute toxic substances like chloro-
ment for ingredients like chemical residues, making it phenol. These are often discharged into waterways as
impossible for consumers to avoid any potential toxins effluent, causing pollution and further harm to wildlife
found in these products. A similar situation exists in and eco-systems.
Europe where there are no European standards limiting
the level of these substances in tampons. Instead, tam- The solution is for pulp mills, the producers of these
pons are covered by the General Product Safety Direc- fibres, to switch to a safer bleaching technology known
tive 24 , which does not oblige manufacturers to disclose Total Chlorine Free (TCF). Instead of using chlorine,
product components or ingredients on their packaging. TCF supplements the bleaching process with oxygen,
Some consumer information on tampon composition ozone and/or hydrogen peroxide. It remains the cleanest
is available from a French-based association of tampon technology available for bleaching, and products made
manufacturers, GroupHygiène25, but this doesn’t go into with it can be considered genuinely chlorine free. TCF
the detail of specific chemicals used. also delivers wider ecological and social benefits as it
eliminates the risk of toxic chlorinated compounds esca-
Moves are being made to try and address the situation, ping into waterways, helping to safeguard eco-systems
but progress has been limited. In 2016 MEP Michèle and local communities.

19. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3238331/
20. https://www.theguardian.com/lifeandstyle/2016/mar/21/tampon-health-concerns-toxic-shock-syndrome-menstruation-women
21. https://www.congress.gov/bill/110th-congress/house-bill/5181/text
22. https://www.theguardian.com/lifeandstyle/2016/mar/21/tampon-health-concerns-toxic-shock-syndrome-menstruation-women
23. https://www.fda.gov/MedicalDevices/ucm071781.htm
24. www.europarl.europa.eu/sides/getAllAnswers.do?reference=E-2015-013116&language=EN
25. https://www.grouphygiene.org/fr/composants-fonctionnalite-protections-periodiques/
26. www.lemonde.fr/sante/article/2017/04/26/michele-rivasi-la-commission-europeenne-est-complice-des-industriels_5118219_1651302.html
27. https://www.economie.gouv.fr/dgccrf/securite-des-produits-dhygiene-feminine
28. https://www.congress.gov/bill/115th-congress/house-bill/2416/all-info
29. https://environmentamerica.org/reports/ame/pulp-fiction-chemical-hazard-reduction-pulp-and-paper-mills

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Despite its green credentials, uptake of TCF remains Consumers have a powerful role to play here through
limited 30 especially outside of Europe. ECF continues exercising their purchasing power. Where possible,
to be the technology of choice partly due to misleading alternative tampon and diaper brands like Natracare32
claims that it is comparable to, if not better than, TCF and Naty 33 should be promoted, which have been
in terms of quality and environmental performance. ethically produced and are totally chlorine free. While
The producers of these products must now come under organic cotton tampon brands are perceived by some as
increasing scrutiny to clean up their act – the bleaching being a safer alternative, especially for reducing the risk
process represents one of the most important environ- of TSS, they too may have been bleached using ECF and
mental pollutant stages in the pulp industry, and TCF therefore could contain dioxin residues.
offers the ultimate detox solution.
Going forward, campaigning efforts should be stepped
Safer alternatives also need to be found for phthalates, up by NGOs and authorities to raise awareness of these
which are used to soften the plastics contained with issues. More open discussion is needed to remove the so-
tampons, diapers and other personal hygiene products. cial stigmas associated with menstruation, which in turn
Chemical alternatives31 such as citrates, sebacates, should encourage more scientific scrutiny into the safety
adipates and phosphates are already being substituted aspects of tampon use. Increased public engagement on
in toys and medical devices – however most of these are the issue will also place greater pressure on manufacturers
not well studied with regard to their potential effects on of these products to take such concerns seriously and
human health and the environment and are thought to clean up their supply chains – thus encouraging pulp
pose various risks. The safest approach therefore would mills to adopt cleaner processes like TCF bleaching.
be to eliminate the use of plastic altogether and switch
to chlorine free pulp or organic cotton based products. If we are to work towards a future in which personal
hygiene products are completely safe for human use,
WHY DETOX IS THE WAY FORWARD society must demand action on three fronts. First, to
The assurance that TCF offers cannot be underesti- demand that manufacturers disclose every ingredient
mated when it comes to protecting public health. in their products and for this to be made mandatory
There are many products made using ECF technology on the product packaging. Second, to only accept 100%
besides personal hygiene products, such as paper, tissues chlorine-free (TCF) products. Third, to eliminate
and napkins. Unlike ECF, TCF offers a guarantee that plastics – or at least use biodegradeable plastics – from
these products are chlorine free. such products. These three steps should give the level of
assurances needed to deliver genuine change.

Rune Leithe, Ecology and Pioneering AB

30. www.aet.org/science_of_ecf/eco_risk/2013_pulp.html
31. https://www.sustainableproduction.org/downloads/PhthalateAlternatives-January2011.pdf
32. www.natracare.com
33. https://www.naty.com/

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