FORMALDEHYDE EXPOSURE IN THE COSMETOLOGY INDUSTRY FROM
BRAZILIAN BLOWOUTS by
Kristin L. Frawley
Bachelor of Science, Point Park University, 2010
Submitted to the Graduate Faculty of
Environmental and Occupational Health
Graduate School of Public Health in partial fulfillment of the requirements for the degree of
Master of Public Health
University of Pittsburgh
2013

UNIVERSITY OF PITTSBURGH
Graduate School of Public Health
This essay is submitted by
Kristin L. Frawley on
August 26, 2013 and approved by
Essay Advisor:
James Peterson, PhD
Associate Professor
Environmental and Occupational Health
Graduate School of Public Health
University of Pittsburgh
Essay Reader:
Ravi Sharma, PhD
Assistant Professor
Behavioral and Community Health Sciences
Graduate School of Public Health
University of Pittsburgh
Essay Reader:
Charles J. Vukotich Jr, MS
Senior Project Manager
Center for Public Health Practice
Graduate School of Public Health
University of Pittsburgh ii

Copyright © by Kristin L. Frawley
2013 iii

Dr. James Peterson, PhD
FORMALDEHYDE EXPOSURE IN THE COSMETOLOGY INDUSTRY FROM
BRAZILIAN BLOWOUTS
Kristin L. Frawley, MPH
University of Pittsburgh, 2013
ABSTRACT
Brazilian Blowout is a method of temporarily straightening hair using both a protein and a preservative solution, followed by heating the hair with a very hot flat iron. This chemical process is of public health importance because it can put customers of the hair salon and the cosmetologist at risk for exposure to higher than normal concentrations of formaldehyde, a known toxicant and suspected human carcinogen. Brazilian Blowout came under scrutiny in
2010 when its products, packaged and labeled as “formaldehyde free,” were found to release significant amounts of formaldehyde. Prompted by complaints from cosmetologists, the
Occupational Safety and Health Administration (OSHA) began an investigation which would prove that the “formaldehyde-free” products did, in fact, contain an aqueous (hydrated) form of formaldehyde, also known as methylene glycol. When heated with a flat iron, methylene glycol releases water and formaldehyde gas into the salon. OSHA set a 15-minute short term exposure limit (STEL) of 2 parts formaldehyde per million parts air (ppm). The salons studied during the
OSHA investigation had levels as high as five times the OSHA STEL. These findings led to salons being cited for using products that contained or could release formaldehyde, neglecting to follow the requirements in OSHA's formaldehyde standard, and failing to provide workers training and information on the health hazards and symptomatic signs of exposure to formaldehyde. However, this problem has not been completely eradicated. iv

TABLE OF CONTENTS
PREFACE ................................................................................................................................. VIII
1.0
INTRODUCTION ........................................................................................................ 1
1.1
A BRIEF CASE HISTORY: DAWN MARINO [20] ....................................... 2
2.0
3.0
CHEMICAL BASIS ..................................................................................................... 4
FORMALDEHYDE TOXICOLOGICAL OVERVIEW ......................................... 7
4.0
4.1
REGULATORY ACTIVITY .................................................................................... 11
OCCUPATIONAL SAFETY AND HELATH ADMINISTRATION (OSHA)
............................................................................................................................. 11
4.2
4.3
HEALTH CANADA .......................................................................................... 14
FOOD AND DRUG ADMISTRATION (FDA) .............................................. 16
5.0
4.4
4.5
CALIFORNIA DEPARTMENT OF PUBLIC HEALTH (CDPH) .............. 17
COSMETIC INGREDIENT REVIEW (CIR) ................................................ 17
CONCLUSION ........................................................................................................... 18
BIBLIOGRAPHY ....................................................................................................................... 22
v

LIST OF TABLES
Table 1. PRODUCTS LISTED IN HEALTH CANADA ADVISORIES AND LEVEL ............ 15
vi

LIST OF FIGURES
Figure 1. FORMALDEHYDE TO METHYLENE GLYCOL
Ошибка! определена.
Закладка не
Figure 2. ALKALINE HYDOLYSIS……………………………………………………………..5
Figure 3. FORMALDEHYDE LEVELS MEASURED IN SALONS…………………………..12
Figure 4. HIGH FORMALDEHYDE CONCENTRATIONS……………………………….…..14
Figure 5. BRAZILIAN BLOWOUT FORMALDEHYDE FREE PRODUCT MSDS………….20
vii

PREFACE
This essay presents the occupational/environmental health risk posed from the use of formaldehyde in the cosmetology industry. It shows how an individual’s exposure to Brazilian
Blowouts can have serious health implications and how following the safety precautions outlined by OSHA can help to keep cosmetologists safe.
Grateful acknowledgment is here made to those who helped this researcher gather data for this essay and those who helped to make sure the message was properly written and formatted. This work would not have reached its present form without their invaluable help. viii

1.0 INTRODUCTION
Brazilian Blowout is a commercial name for a process more informatively described as a keratin smoothing treatment. Brazilian Blowout is a method of temporarily straightening curly hair by washing the hair with a “liquid keratin” (i.e. protein solution) and a preservative solution, then heating the hair with a very hot flat iron (450°F). Through this chemical process both customers of the hair salon and the cosmetologist are at risk for exposure to higher than normal concentrations of formaldehyde, a known human carcinogen, according to the Agency for Toxic
Substances and Disease Registry (ATSDR) [1]. Hence, the target audience for this essay is salon owners, salon employees and their customers. While there are other brands and formulas of keratin smoothing products on the market, this paper will focus specifically on the Brazilian
Blowout since it is the most controversial of the keratin smoothing treatments offered to salon patrons, as well as being, the most advertized by the salons and requires a licensed cosmetologist to perform the process.
According to the brazilianblowout.com website [2], their process is as follows: The hair stylist shampoos the hair with the Brazilian Blowout Anti-Residue Professional Shampoo to prepare hair for smoothing. Once the hair is towel dried the stylist then divides the hair into sections and begins combing the Brazilian Blowout Professional Smoothing Treatment
(formaldehyde source) through each section of the hair from root to tip; lightly dusting each
1

section with the solution. The hair is dried with a blow drier on high heat setting with a round brush to begin straightening the hair. Next, the hair is divided into sections and again heat is applied, this time with the flat iron on a high heat setting (450°F). Once these steps are complete, the hair is rinsed using no shampoo and the Brazilian Blowout Masque is applied to further seal in the professional formulation. After 60 seconds, the stylist rinses the hair again and dries it with a towel. Then, the Brazilian Blowout Smoothing Serum is applied to further seal the cuticle and assist in detangling the hair prior to the final blow dry. Once again heat is applied to the hair as it is blown dry and styled (the stylist could once more use the flat iron). This process takes approximately 90 minutes and is usually repeated every 3 months [2]. The process, according to Brazilian Blowout, “through the use of a Brazilian Super Nutrient Complex and a proprietary polymer system… actually improves the condition of the hair by creating a protective protein layer around the hair shaft to eliminate frizz and smooth the cuticle. The end result is smooth, healthy, conditioned hair with a radiant shine” [2]. However, the experience of Dawn
Marino (below) illustrates the adverse health implications to be considered in relation this process.
1.1
A BRIEF CASE HISTORY: DAWN MARINO [20]
Dawn began her cosmetology career in January 2010 as an assistant in a hair salon offering Brazilian Blowouts to smooth curly, wavy, out-of-control hair. A few weeks in, Dawn began to notice that her eyes would burn when stylists would blow dry client’s hair after the
Brazilian Blowout formula was applied. She would have to seek refuge in the stockroom after the flat iron process due to the clouds of fumes resulting from the process. At this time the salon
2

sent out coupons to the public to boost sales on the process, and increase revenue to the salon. In
March, Dawn began feeling frequently ill and had to call off of work, which previously she never had to do.
Every month she felt sicker and sicker, calling off of work at least twice a month, and barely able to get out of bed. She was dizzy, coughing and had sinus congestion worse than any she had before. At this point she went to a doctor and was given antibiotics for a sinus infection, she also began carrying plastic bags with her, since she was throwing up frequently.
In May, Dawn called off of work and again went to her doctor because her throat was very irritated and she could hardly swallow. Once more she was given antibiotics and sent home.
It was at this appointment that the doctor questioned her about her “environment” and said something had to be irritating her. Dawn was surrounded by Brazilian Blowouts on a daily basis, but was unsure if that was the problem. After several days her condition deteriorated. She had trouble breathing and was wheezing and coughing up a strange phlegm. It was at this point that she knew something was seriously wrong and went on-line to read about the potential dangers of
Brazilian Blowouts. She returned yet again to the doctor telling him of her suspicion and, after several tests, Dawn was finally diagnosed with formaldehyde poisoning. She also had asthma and started to use an inhaler on a daily basis, since being over-exposed to excessive amounts of formaldehyde had caused Dawn to become overly sensitive. The Brazilian Blowout Company denied that their product contained formaldehyde and her former boss denied that the Brazilian
Blowout was to blame for her illness because it was labeled as “formaldehyde free” [20].
3

2.0 CHEMICAL BASIS
O H OH
C + O C
H H H H H OH
(Formaldehyde) (Water) (Methylene Glycol)
*Formaldehyde (CH
2
O) molecular structure, when it is added to water methylene glycol is formed, when méthylène glycol is heated and water evaporates the formaldehyde is released as gas [CH
2
O+H
2
O

CH
2
(OH)
2
]
Figure 1. FORMALDEHYDE TO METHYLENE GLYCOL
When added to water formaldehyde rapidly becomes hydrated and forms methylene glycol (Figure 1) [22]. On this basis it can be claimed that aqueous formulations do not strictly
“contain formaldehyde” under ambient conditions. However, when methylene glycol is heated it undergoes dehydration to release water vapor and formaldehyde gas – therefore, the same aqueous formulations actually do contain (or evolve) formaldehyde if vaporized by heating.
Chemical studies have proven that formaldehyde is a reactive electrophilic species that reacts readily with various functional groups of biological macromolecules, including hair proteins like keratin, in a cross linking fashion [22]. For example, the most frequent type of cross-link formed
4

by formaldehyde in collagen is between the nitrogen atom at the end of the side-chain of lysine and the nitrogen atom of a peptide linkage [24].
The use of formaldehyde as a biochemical reagent occurred rather late in history, the primary reason was the late development of formaldehyde manufacture by the chemical industry.
It has been widely used as a preservative for biological specimens [22]. In the case of chemical smoothing, the formaldehyde is used both as a cross-linker to stabilize the keratin and also to improve the shelf life of the product it is added to, in this case the Brazilian Blowout
Professional Smoothing Treatment.
The chemical process of the Brazilian Blowout works by breaking down the disulfide bonds that cause hair to curl through an alkaline hydrolysis mechanism (Figure 2) generating a cysteine thiol and a cysteine sulfenic acid [23]. The hair is then straightened and finally strengthened with keratin so that the hair remains straight. When formaldehyde is applied the molecules diffuse into the hair and cross-link strands of keratin, and cross-link the new keratin with the keratin already in the customer’s hair. When the saturated hair is blown dry and then compressed with a hot flat iron, the cross-linking reaction is accelerated [23]. This process straightens the hair and removes the curl more permanently than just heating with the flat iron, which only tends to break hydrogen bonds in the hair.
R
2
OH
S S + OH R
2
S
R
1
R
1
S -
* This is the process used in the Brazilian blowout to break disulfide bonds in the hair
Figure 2. ALKALINE HYDOLYSIS
5

The cosmetologist actually carries out the process in three discernible stages ( i.e.
topical applications): relaxing, neutralizing and conditioning [3]. After the hair has been washed with the shampoo supplied to strip it of any residues, the Brazilian Blowout Professional Treatment
“relaxer” (highly alkaline, but also containing formaldehyde/methylene glycol) is applied. This treatment is used to break the disulfide bonds by alkaline hydrolysis prior to straightening.
Although formaldehyde has now been applied, there is presumably not much “resetting” by formaldehyde-dependent cross linking until heat is also applied.
Next, the alkali-containing formulation is washed off once the desired amount of straightening has been achieved using a mild acid, thereby restoring neutrality ( i.e.
restoring the
“pH balance” of the hair). At this point the hair is somewhat straightened, but very delicate and so a keratin conditioner is applied to repair the existing damage as well as protect the hair from further damage [3]. Formaldehyde that was present in the relaxer persists and cross-links the keratin when heat is applied. The problem with this process lies in the formaldehyde gas released into the salon when the hair is heated during the final drying and flat ironing procedures.
This is due to the increase in temperature favoring the disassociation of formaldehyde from the polymers. When methylene glycol is heated to 450°F with the flat iron, it tilts the formaldehydemethylene glycol in favor of formaldehyde, releasing formaldehyde [24] in this case, into the salon along with water molecules ( i.e.
a cloud of formaldehyde vapor). For a client getting a single treatment, any side effects from breathing the formaldehyde gas should disappear once they step outside of the salon and into open, fresh air. The real issue concerns the cosmetologist who is working in the salon where the levels are elevated for 8 or 10 hours a day for 3 to 5 days a week [21].
6

3.0 FORMALDEHYDE TOXICOLOGICAL OVERVIEW
Formaldehyde, CH
2
O, is a colorless, flammable gas at room temperature with a distinct odor and which dissolves easily in water. Some of the synonyms for formaldehyde (in solution) found in labeling are as follows: methyl aldehyde, methanal, methylene glycol, methylene oxide and “formalin.” When these are heated the formaldehyde is released as formaldehyde gas into the air. Formaldehyde has a relative molecular mass of 30.03g/mol. A c onversion factor : mg/m3
= 1.23 × ppm; calculated from: mg/m3 = (relative molecular mass/24.45) × ppm, assuming standard temperature (25 °C) and pressure (103.5 kPa).
Formaldehyde is naturally produced in very small amounts in our bodies as a part of our normal metabolism and does not usually cause us harm [16]. In low level exposures, almost all tissues in the human body have the ability to break down formaldehyde, converting it into a low toxicity chemical called formate that can inhibit respiration, but is excreted in the urine, or it can be converted to carbon dioxide and breathed out of the body [17]. Most of the formaldehyde inhaled in small concentrations can be easily metabolized in the cells lining the respiratory tract and then the products exhaled. At high levels, formaldehyde can enter the bloodstream.
Formaldehyde can then either be metabolized, allowing the body to make larger molecules needed in tissues, or it can haptenate human protein [16]. Formaldehyde can also be absorbed by the skin through dermal contact. However, it does not accumulate in the human body, as we are capable of metabolizing it quickly and it is not stored in fat [17]. In most cases formaldehyde
7

does not cause irritation, but some individuals are unusually sensitive, such as people with asthma [17]. The following studies have been carried out to determine the levels of formaldehyde acceptable for occupational health and safety.
In a human occupational exposure study by Bingham, Cohrssen, and Powell (2001) [16] it was determined that irritating effects to the upper respiratory tract begin at around 0.1 ppm and become more common at 0.2 ppm. Symptoms in the lower airways such as cough, chest tightness, and wheezing are observed at higher levels greater than 0.5 ppm, but may occur in the presence of fine particles at lower concentrations of about 0.07 ppm. Formaldehyde exposures up to 2-3 ppm can cause acute nose, throat, and eye irritation [16].
A study by Zenz, Dickerson and Horvath (1994) [17], again, an occupational human exposure study, determined acute effects of airborne formaldehyde exposure are as follows: odor can be detected at 0.05-1.0 ppm, eye irritation can be felt at, 0.01-2 ppm; irritation of the nose or throat occurs at about 0.10-11 ppm; and cough, chest tightness and wheezing at about 5-
30 ppm; pulmonary edema, inflammation and pneumonia have been documented at 50-100 ppm and finally, death at exposures greater than 100 ppm [16]. NIOSH reports that formaldehyde is immediately dangerous to life and health at 20 ppm [17].
Formaldehyde has been known to cause a burning sensation in the eyes, nose, and lungs at high concentrations. Classified as a volatile organic compound (VOC), formaldehyde is a gaseous pollutant produced by both human activity and natural sources and can be found in both indoor and outdoor air. A major source of formaldehyde is found in smog in the lower atmosphere [17] as well as combustion processes. It is produced in cigarette smoke, by gas cookers and fireplaces affecting indoor air quality. Formaldehyde can be added to consumer products such as antiseptics, medicines, cosmetics, dish-washing liquids, fabric softeners, and
8

hair smoothers [17]. It is a highly reactive molecule that can irritate tissues that it comes into contact with. Formaldehyde-induced non-cancer and cancer effects appear to occur only at portals-of-entry, for example the upper respiratory tract by inhalation, skin through contact, and to the gastrointestinal tract with oral exposure [1]. The primary way to become exposed to formaldehyde is by breathing it in. Sitting in a salon with poor ventilation and limited space can make the concentration of formaldehyde in the area higher than expected. If more than one person is having the process done at the same time, the concentration can be very dangerous for both the stylists and the customers of the salon. OSHA has set a legal limit of 0.75 ppm formaldehyde in air per 8-hour work day [1] and a 15-minute short term exposure limit (STEL) of 2 parts formaldehyde per million parts air (ppm) [4].
Formaldehyde was first listed in the Second Annual Report on Carcinogens in 1981 as
“reasonably anticipated to be a human carcinogen” [15] based on studies with experimental animals. By the Twelfth Report on Carcinogens (2011) it was classified as a known human carcinogen [15]. The Brazilian Blowout MSDS classifies formaldehyde gas as a “suspected” carcinogen.
There are a number of carcinogenic effects documented from occupational exposure to formaldehyde, the worst of which were found by an expert working group with the International
Agency for Research on Cancer (IARC). The group determined that there is sufficient evidence proving that formaldehyde causes a rare form of cancer (nasopharyngeal cancer) in humans [4].
In a publication by the World Health Organization (WHO), Pathology & Genetics: Head and
Neck Tumours, edited by Leon Barnes, John W. Eveson, Peter Reichart, David Sidransky formaldehyde is listed as an environmental risk factor for nasopharyngeal cancer [5]. Due to
9

complaints regarding the use of formaldehyde, the cosmetics industry began to produce formaldehyde free products that have been used nationwide by salons.
10

4.0 REGULATORY ACTIVITY
4.1
OCCUPATIONAL SAFETY AND HELATH ADMINISTRATION (OSHA)
The Occupational Safety and Health Administration (OSHA) conducted a study in a salon in Oregon to investigate complaints from stylists and hair salon owners about exposure to formaldehyde while using Brazilian Blowout products. In particular, this included products labeled “formaldehyde free” on the product label and on the material safety data sheets (MSDS).
According to Oregon OSHA, the first reports about serious side effects from formaldehyde exposure in hair smoothing products, labeled as formaldehyde free, surfaced when they investigated a complaint from a hair stylist, Dawn Marino (see above: A BRIEF CASE
HISTORY: DAWN MARINO), who had experienced nosebleeds, eye irritation, and trouble breathing while using a Brazilian Blowout product labeled as being formaldehyde free [6]. The
Acai Professional Smoothing Solution was originally shipped by Brazilian Blowout on
8/12/2010 to the salon in question located in the Portland, Oregon area. A number of stylists expressed concerns about health effects they reported experiencing while using Brazilian
Blowout Products. The original container, which was labeled "formaldehyde free," was delivered to Oregon OSHA for sample analysis on September 1, 2010, along with the MSDS.
The Oregon OSHA laboratory analyzed the sample using four different test methods.
Formaldehyde was reported to be detected by each method at 10.6%, 6.3%, 10.6% and 10.4% of
11

the product [18]. Two separate test methods also used to analyze this product detected formaldehyde concentrations at 8.4% and 8.6% respectively [18].
After the initial studies found evidence that the product indeed tested positive for formaldehyde, the Oregon OSHA then tested 100 samples of various formaldehyde free keratinbased hair smoothing products and found formaldehyde levels in some products well above what could legally be labeled as “formaldehyde-free.” None of the products were listed as containing formaldehyde and did not included hazard information on the label or in the MSDS. It was noted that manufacturers, importers, and distributors of these hair smoothing products had not listed formaldehyde as an ingredient and had not included hazard information on the label or in the
MSDS. Based on these findings, Oregon OSHA published a Hazard Alert and a full report in
October 2010. Oregon OSHA also alerted Federal OSHA and State OSHA programs where the products were manufactured, imported, or distributed because the hazard information for the product was not correct and did not meet the requirements of OSHA's Formaldehyde and Hazard
Communication Standards [18].
* Includes four vertical bars – one each representing Application/Blow Dry and the total amount of formaldehyde measured in parts per million (ppm) for Salon 1 (4 ppm), Salon 2 (2.5 ppm) and Salon 3 (5.5 ppm) followed by a bar representing Final Blow Dry and the Formaldehyde measured in parts per million (ppm) also for
12

Salon 3 (10 ppm). The graph also notes the OSHA Short Term Exposure Limit of 2 parts per million (ppm) as a grey dotted line. [18] (Accessed from the OSHA website July 26, 2013)
Figure 3. FORMALDEHYDE LEVELS MEASURED IN SALONS
In 2011, Federal OSHA investigated three salons and found that stylists using either Brazilian
Blowout Acai Professional Smoothing Solution or Cadiveu Brasil Cacau were exposed to formaldehyde above OSHA’s 15-minute short term exposure limit (STEL) of 2 parts formaldehyde per million parts air (ppm), putting their health at risk (Figure 3). In salon 3, formaldehyde levels during the blow drying phase of treatment were measured at five times the
OSHA STEL. All three salons were issued OSHA citations and two salons were fined for failing to protect stylists from the health risks associated with high levels of formaldehyde. OSHA cited many salons for using products that contained or could release formaldehyde because they did not follow the requirements in OSHA’s formaldehyde standard to provide workers training and information on the health hazards and signs and symptoms of exposure to formaldehyde.
Federal OSHA issued additional citations to 37 salons (including beauty schools) and 9 distributors or manufacturers in 2011 and 2012 [17].
Based on these findings in Figure 4, Oregon OSHA published a Hazard Alert in October
2010 [14]. Oregon OSHA also alerted Federal OSHA and the State OSHA programs where the products were manufactured, imported, or distributed because the hazard information for the product was not correct and did not meet the requirements of OSHA's Hazard Communication standard (29 CFR 1910.1200) [6]. The Oregon OSHA Hazard Alert informed the salons that chose to do the Brazilian Blowouts that they must provide training to their stylists and set up steps salons should take to ensure their stylists are not over exposed. It also identified what formaldehyde is, how stylists are exposed, the hazards of the exposure, exposure limits and other safety information regarding proper techniques for implementing a Brazilian Blowout [6].
13

* The above hair smoothing solutions had the highest formaldehyde concentrations tested by Oregon Officials and
Health Canada. Accessed from Minnesota Department of Health website (July 25, 2013)
Figure 4.
HIGH FORMALDEHYDE CONCENTRATIONS
4.2
HEALTH CANADA
Many countries have also begun issuing advisories regarding formaldehyde in hair smoothers and many have made it illegal to include formaldehyde or formaldehyde-producing chemicals in hair products. In October 2010, Health Canada tested Brazilian Blowout Solution manufactured by Brazilian Blowout of California and found unacceptable levels of formaldehyde, finding that Brazilian Blowout Solution contained 12% formaldehyde [19].
Health Canada issued an advisory on the Brazilian Blowout Solution October 26, 2010 [8] based on these and the other available data (Figure 4).
14

Formaldehyde is permitted as a preservative in cosmetics at levels of no more than 0.2% since formaldehyde is a known irritant, sensitizer, and is linked to cancer in humans when inhaled chronically over a long period of time. Health Canada determined that the danger is due to the reaction caused by formaldehyde gas released during the blow drying and flat ironing stages of the treatment placing clients and stylists at increased risk. Table 1 provides the names of products that have been listed in previous Health Canada advisories. Note that the Brazilian
Blowout product contained the highest level of formaldehyde at 8.4% [8].
Table 1. PRODUCTS LISTED IN HEALTH CANADA ADVISORIES WITH
LEVEL OF FORMALDEHYDE
PRODUCT
Brazilian Blowout Smoothing Solution by Brazilian Blowout
Brazilian Keratin Treatment by Marcia
Teixeira
Keratin Complex Smoothing Therapy
Treatment by Copomon (Coppola)
Global Keratin Taming System
Strawberry by Global Keratin
Global Keratin Taming System with
Juvexin Strawberry Resistant by Global Keratin
Pro-Collagen RX Keratin Treatment
IStraight Keratin (Advanced Keratin
Treatment) by IBS Beauty
Brazilian Thermal Reconstruction by
Cadiveu
LEVEL OF
FORMALDEHYDE
8.4
1.8
1.8
3.0
4.4
2.8
2.3
7.0
%
%
%
%
%
%
%
%
15

4.3
FOOD AND DRUG ADMISTRATION (FDA)
The Food and Drug Administration (FDA) received a number of inquiries from consumers and salon professionals concerning the safety of the Brazilian Blowout and similar keratin soothing products. On August 22, 2011, FDA issued its own warning letter, citing
Brazilian Blowout for safety and labeling violations [7]. The letter listed health risks associated with inhaling formaldehyde and reactions that have been reported when people used their product as directed, such as, eye problems, nervous system symptoms (i.e. headaches and dizziness), respiratory tract problems, nausea, chest pain, vomiting, and rash [7]. The labeling failed to reveal possible consequences of using this product under the conditions described in the labeling and is clearly misleading as the “formaldehyde free” product was undoubtedly still exposing people to formaldehyde.
The FDA regulates the safe manufacture and distribution of cosmetics and keratin hair smoothing products, under the Federal Food, Drug, and Cosmetic Act [7]. If the cosmetics are marketed on a retail basis to consumers then cosmetics are regulated under the Fair Packaging and Labeling Act [7]. What this means to salons, is that cosmetics don’t have to be approved by the FDA before going on the market. However, keratin hair smoothing products should still be safe and companies who manufacture or market these products have a legal responsibility to make sure they are safe and the ingredients are properly labeled. This information is usually communicated with material safety data sheets. The FDA can take action against cosmetics on the market that do not comply with the law. However, FDA does not have authority over the operation of salons or the practice of cosmetology [7].
16

4.4
CALIFORNIA DEPARTMENT OF PUBLIC HEALTH (CDPH)
The California Department of Public Health (CDPH) operates a Safe Cosmetics program that orders cosmetic and beauty product makers to report when specific hazardous chemicals are above certain levels in their products. The CDPH was not given information by Brazilian
Blowout regarding the amount of formaldehyde in the “formaldehyde-free” formula.
Consequently, on November 10, 2010, the California Attorney General filed a lawsuit against the company for failure to warn consumers about the presence of formaldehyde in its products and, on April 5, 2011, the state filed a preliminary injunction against the distributor of Brazilian
Blowout [6].
4.5
COSMETIC INGREDIENT REVIEW (CIR)
Finally, the Cosmetic Ingredient Review (CIR) was established in 1976 to provide an independent review process for the industry. The CIR's Expert Panel met in June, 2011, and revised its Tentative Amended Safety Assessment for formaldehyde and methylene glycol, issuing the statement that: "formaldehyde and methylene glycol are unsafe for use in hair smoothing products, the use of which involves application of high temperatures" [6].
17

5.0 CONCLUSION
Brazilian Blowout hair products contain methylene glycol, a formulation of formaldehyde dissolved (and chemically hydrated) in water. Even when their products do not list formaldehyde on the label, or they claim to be "formaldehyde free," the product can still expose workers to formaldehyde. This is clearly, at least a disingenuous manipulation of language
(“spin”) and very probably a direct violation of OSHA regulations and the Fair Packaging and
Labeling Act (FDA concern). It has been proven that formaldehyde is not only being added to the product, but that the formaldehyde is being released as a gas upon application of heat during flat ironing, and/or blow drying. Furthermore, there is ample evidence that some salon employees have been adversely affected by such releases.
According to the MSDS from March of 2013 (Figure 5), the Brazilian Blowout still contains methylene glycol at a percentage of 3-7%. This means that hair salon employees will continue to be exposed to formaldehyde and will also be exposing clients to the formaldehyde from the Brazilian Blowout.
18

Page 2 of 8
Prepared to OSHA, AAC, ANSI, NOHSC, WHMIS, 2001/58 & 1272/2008/EC Standards MSDS Revision: 4.0
BB-001
MSDS Revision Date: 03/21/2013
CHEMICAL NAME(S)
AQUA (WATER)
METHYLENE GLYCOL
CYCLOPENTASILOXANE
CAS No
3. COMPOSITION & INGREDIENT INFORMATION
EXPOSURE LIMITS IN AIR (mg/m 3 )
ACGIH ppm
NOHSC ppm
OSHA ppm
RTECS No EINECS No % TLV
7732-18-5 ZC0110000 231-791-2 60-100 NA
463-57-0 NA 207-339-5 3-7
541-02-6 GY5945200 208-764-9 1-5
CEITEARYL ALCOHOL 8005-44-5 NA
BEHENTRIMONIUM METHOSULFATE 81646-13-1 NA
FRAGRANCE (PARFUM) NA NA
267-008-6 1-5
279-791-1 1-5
NA 1-5
NA
0.3 NA
NA
NA
NA
NA
STEL
NA
NA
NA
NA
OTHER
NF
NF
NF
NF
ES
TWA
ES
STEL
ES
PEAK TLV STEL IDLH
NF
0.016
NF NF
2.0 NF
NA
0.75
NA NA
2.0
20.0
NIOSH
NF
NF
NF
NF
NF
NF
NF
NF
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
EUTERPE OLERACEA (ACAI PALM)
FRUIT EXTRACT
GLYCERIN
BIXA ORELLANA (ANNATTO) SEED
EXTRACT
NA
56-81-5
NA
8015-67-6 NA
NA
NA
0.1-1 NA
0.1-1 NA
MYRCIARIA DUBIA (CAMU CAMU)
FRUIT EXTRACT
LIMONENE
LINALOOL
NA NA NA 0.1-1 NA
5989-27-5 GW6360000 227-813-5 NA NA
78-70-6 RG5775000 201-134-3 NA
101-86-0 GD6560000 202-983-3 NA
NA
NA HEXYL CINNAMAL
BUTYLPHENYL METHYLPROPIONAL 80-54-6
BENZYL BENZOATE
MW48950000 201-289-8 NA
120-51-4 DG4200000 204-402-9 NA
NA
NA
NA
MA8050000 200-289-5 0.1-1 (10)* NA
NA
NA
NA
NA
NA
NA
NA
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NF
NA NA
(5)* NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
CI 15985 (YELLOW 6) 2783-94-0 ZF6680000 220-491-7 NA NA NA NF NF NF NA NA
CI 19140 (YELLOW 5) 12225-21-7 NA 235-428-9 NA NA NA NF NF NF NA NA
* This figure represents a MSDS for Brazilian Blow out formaldehyde free product as of 2013
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
*MIST
ALLERGEN
ALLERGEN
ALLERGEN
ALLERGEN
ALLERGEN
Figure 5: BRAZILIAN BLOWOUT FORMALDEHYDE FREE PRODUCT MSDS
In the Pittsburgh area many salons carry out this process. After speaking to a stylist working in a salon in the North Hills [25], the stylist said that the owners offer training to the employees conducted by an outside source in their store. The staff is licensed to do Brazilian
Blowouts after a few hours and can charge upwards of $300 for the process. There is no limit to how many can be done in a day. The shop does not enforce the use of respirators, or masks
(gloves too are optional) for any part of the process, nor has the salon upgraded the ventilation system, or followed the recommendation that Brazilian Blowouts be done in a separate well
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ventilated room away from the other clients and stylists. Even scarier is the fact that there are stylists in this shop doing Brazilian Blowouts “on the side”, in their own homes. Consequently, there still appears to be a serious lack of regulatory enforcement.
Responsible salon owners should consider opting for hair smoothing products that do not include formaldehyde. However, should they decide to use products that may contain, or release, formaldehyde, they must follow the requirements in OSHA's formaldehyde and hazard communication standards to protect worker safety. The requirements include testing salon air during treatments to determine formaldehyde levels, providing adequate ventilation and appropriate personal protective equipment (PPE) for workers performing treatments, such as respirators, safety glasses and gloves, as well as training workers on the health hazards of formaldehyde. There are instances of salons that do not comply with OSHA regulations and owners need to be informed. In 2011 and 2012, Federal OSHA issued citations to 40 salons, including beauty schools and nine distributors and/or manufacturers with fines as high as
$17,500 for failing to protect workers from over exposure and potential formaldehyde exposure.
At around $300 per treatment, this means that a salon needs to perform slightly more than one
Brazilian Blowout per week (17,500/300 = 58) to make simply paying the fine and getting on with business regardless a cost-effective mode of operation.
The full responsibility does not only lie with the salon owners though. Stylists need to be familiar with the contents of the products they use, the hazards those products present, and the steps they can personally take to help reduce their exposure to formaldehyde; such as wearing the available protective equipment and properly cleaning up spills. It is extremely important that stylists be aware of the health hazards, signs, and symptoms of formaldehyde exposure, and immediately report to the employer any signs or symptoms of exposure when they occur. They
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should also be aware of the purpose, use and limitations of personal protective equipment (PPE) such as gloves and respirators. If they cannot get help from an employer or manufacturer when adverse effects occur from formaldehyde exposure, stylists need to know how to file a complaint and hold salon owners and manufacturers who choose to overlook safety responsible, like Dawn
Marino did.
While more punitive regulatory actions, such as a ban on Brazilian Blowouts and similar formaldehyde-formulated processes, is unlikely, organizations like OSHA and the FDA are performing outreach programs to hair salon groups, issuing health alerts, and ramping up inspections. The hope is that the Brazilian Blowout will, like many other hair fads of the past… just blow over.
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BIBLIOGRAPHY
1.
Agency for Toxic Substances and Disease Registry. “Formaldehyde CAS ID #: 50-00-0”. Toxic
Substances Portal. Atlanta Georgia. Last updated: March 3, 2011. http://www.atsdr.cdc.gov/substances/toxsubstance.asp?toxid=39
2.
Brazilian Blowout “What to Expect. Brazilian Blowout.” 2013 http://www.brazilianblowout.com/original.aspx
3.
Keratin Questions Answered, “Does Keratin Make Hair Straight?” Copyright 2010 . http://www.keratinquestions.com/does-keratin-make-hair-straight/
4.
International Agency for Research on Cancer (IARC), “Exposure Data. Formaldehyde”, 2007 http://monographs.iarc.fr/ENG/Monographs/vol100F/mono100F-29.pdf
5.
Leon Barnes, et al. “Pathology and Genetics of Head and Neck Tumours”. Editorial and
Consensus Conference in Lyon France July 16-19, 2003, Published by Int ernational Agency for
Research on Cancer (IARC), Lyon, France 2005. http://screening.iarc.fr/doc/BB9.pdf
6.
Department of Labor. “Health Alert: Hair Smoothing Products That Could Release
Formaldehyde”. Occupational Safety & Health Administration. United States 2011. http://www.osha.gov/SLTC/formaldehyde/hazard_alert.html
7.
U. S department of Health and Human Services “FDA, OSHA Act on Brazilian Blowout.
Cosmetics.” U.S Food and Drug Administration. Last Update: October 21, 2011. http://www.fda.gov/Cosmetics/ProductandIngredientSafety/ProductInformation/ucm228898.htm
Health Canada.
8.
“Several Professional Hair Smoothing Solutions Contain Excess Levels of Formaldehyde”. 2011. http://www.marketwire.com/press-release/several-professional-hair-smoothing- solutions- contain-excess-levels-of-formaldehyde-1501706.htm
9.
B. Goodman, “Position Statement of the American Chemistry Council’s Formaldehyde Panel on the Formaldehyde content of Certain Hair-Care Products” Council AC, Washington, 2010.
10.
Environmental Working Group, “Adverse Reactions and Inquiries” Flat Out Risky, Washington,
2011.
11.
Michigan Occupational Safety and Health Administration, “Hair Straightening Products and
Formaldehyde (Fact Sheet #022)”, Division GISH, Lansing, Michigan, 2011.
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12.
California Department of Public Health, “Q&A: Brazilian Blowout & Other Hair Smoothing
Salon Treatments”, Branch CSCPOH, Sacramento, California, 2011.
13.
Brazilian Blowout, Brazilian Blowout Professional Smoothing Solution”, MSDS Revision: 4.0,
Tujunga Ave. North Hollywood, California, 2013.
14.
Oregon OSHA. “Hazard Alert: Hair Smoothing Products and Formaldehyde” Department of
Consumer Business and Services. 2010.
15.
Report on Carcinogens, Twelfth Edition. “Formaldehyde CAS No. 50-00-0” National Toxicology
Program, Department of Health and Human Services, 2011.
16.
TOXNET: Toxicology Data Network. “Formaldehyde: Human Health Effects”. NLM. Field
Update on 2012-04-07. http://toxnet.nlm.nih.gov/cgi-bin/sis/search/a?dbs+hsdb: @term
+@DOCNO+164
17.
Eco –USA: Toxics:” Formaldehyde”. Agency for Toxic Substances and Disease Registry U.S.
Dept. of Health and Human Services. July 1999. http://www.ecousa.net/toxics/chemicals/formaldehyde.shtml
18.
United States Department of Labor. “Hair Salons: Facts about Formaldehyde in Hair Products”.
Occupational Safety and Health Administration (OSHA). Constitution Ave., NW, Washington,
DC. https://www.osha.gov/SLTC/hairsalons/#levels_in_hair
19.
Center for Research on Occupational and Environmental Toxicology “Emerging Issues and
Alerts”. Oregon Health and Science University. 2013
20.
Marino, Dawn. “Toxic: A Hairstylist’s Story of Formaldehyde Poisoning.” Tousled. June 22,
2011 http://tousledbeautyblog.com/2011/06/22/toxic-a-hairstylists-story-offormaldehyde-poisoning/
21.
Coleman, Stephanie. “Trendy Hair Treatment Raises Health Concerns.” The Allegheny Front. 67
Bedford Square. Pittsburgh, PA. May 16, 2013
22.
Cecil H. Fox, et al. “Formaldehyde Fixation”. The Journal of Histochemistry and Cytochemistry.
Vol. 33, No8, pp. 845-853, 1985 The Histochemical Society, Inc
23.
Hogg, Philip J. “Disulfide bonds as switches for protein function” Center for Vascular Research
University of New South Wales, Australia. TRENDS in Biomedical Sciences. Vol.28 No. 4 April
2003.
24.
Thavaraiah et al
. “Chemical and physical basics of routine formaldehyde fixation”. Department of Oral and Maxillofacial Pathology, Ragas Dental College and Hospital, Uthandi, Chennai,
India. Journal of Oral and Maxillofacial Pathology. 2012 Sep-Dec; 16(3): 400–405. doi:
10.4103/0973-029X.10249
. August 1, 2013 12:08am.
25.
Kocis, Allyson L., PA Licensed Cosmetologist. Personal Interview. 8 June 2013.
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