Lather, rinse, repeat…as needed?

by egndukwe on October 3, 2012

We all remember them. The uncomfortable commercials that would make you hurriedly search for the volume button on the remote, then look around to make sure no one was watching over your shoulder.  The awkward looks family members would give you when they walked into the room mid-commercial and you rushed to explain that it was just a shampoo commercial, you promise. I can’t be the only one.

These days, the “climactic” Herbal Essences commercials are a thing of the past. Owned by Proctor and Gamble (P&G), consumers may have noticed that Herbal Essences recently changed more than just their marketing strategy. In 2010, under threat of an impending lawsuit in the state of California, P&G announced their decision to reformulate the brand’s shampoos. Why were they being sued?

Obtained from

In 2007, the Green Patriot Working Group (GPWG) began testing various consumer products for levels of 1,4 dioxane. Commonly called dioxane, the toxin is known to irritate the eyes and respiratory tract. Although there are no established safe levels of dioxane, the Environmental Protection Agency (EPA) states that laboratory studies found that lifetime exposure to dioxane in animals can lead to cancer, as well as kidney and liver damage. Many companies are able to avoid listing dioxane on product ingredient lists, as it’s not technically an ingredient. Instead, it’s a byproduct of a process used in production called ethoxylation.

Ethoxylation is a complicated name for a simple process used to make products gentler on the skin. For example, many cleansing products for the hair and body use Sodium Lauryl Sulfate (SLS) which works to remove oils. However, as is, SLS can be harsh and drying to the skin.  To reduce these effects, companies might add ethylene oxide to SLS, to make it milder. The problem is that adding ethylene oxide also creates dioxane. As a byproduct, dioxane is not needed, and producers didn’t intend for it to be there. But it’s there regardless. GPWG found that Herbal Essences products contained dioxane levels as high as 24 parts per million (notice the levels found in Tide Detergent…but I digress).

After analyzing their results, the GPWG’s founder filed an intent to sue P&G for violation of Proposition 65, a California law that requires businesses to include warnings when exposing consumers to certain toxins. Dioxane is listed as a cancer agent on the Proposition’s list of Chemicals Known to the State to Cause Cancer or Reproductive Toxicity. Soon after the intent was filed, P&G announced their decision to reformulate their shampoos.

P&G is not the only major manufacturing company to respond to consumer pressure to remove harmful ingredients from their products. In August, Johnson & Johnson announced their intention to remove potentially harmful toxins,including formaldehyde, from its products. The company maintains the position that their products are safe, but insists they’re making changes to ensure their consumer’s peace of mind.

What’s most unnerving to me is that companies are using loopholes to avoid listing the presence of harmful chemicals in their products. It may be idealistic to expect to completely avoid exposure to harmful toxins, but as a consumer, how can I make informed decisions…without the information?

**Updated on 10-4-12**

Elizabeth Fryer October 3, 2012 at 12:10 pm

Interesting article. You give a parenthetical phrase “notice the levels found in Tide,” but I don’t see them anywhere to notice them.

The placement of “including formaldehyde” makes it seem like it’s a J&J product. To make that clear, say “…harmful toxins, including formaldehyde, from its products.” If you wanted to save formaldehyde for the end, for the kicker, then you’d have to add a sentence: “Included in these toxins is formaldehyde.”

egndukwe October 3, 2012 at 9:12 pm

Hi Elizabeth, the Tide detergent dioxane levels can be found on the second page of the link from the phrase “products contained dioxane.” I see how the wording could be confusing and I made changes to reflect your suggestions, thanks for the feedback!

Elizabeth Fryer October 7, 2012 at 2:35 pm

If I were grading your blog, I would leave this comment: It is unacceptable to expect readers to click a link and then scroll to the *second* page of that site to find the point you want to make in your writing. If you want readers to note the amount in Tide, you should provide that amount in your writing.

The ppm link is OK because it takes readers right to the definition, they don’t have to scroll and search for the info you want them to have.

Never make readers have to work to get the point of your writing. Make it easy for them to understand. (Do you and your fellow students share comments made on your separate posts?)

Andrew Maynard October 7, 2012 at 9:43 pm

Hi Elizabeth,

I can take that one – we talk quite a lot as a class about the comments on different posts, to make sure there’s a lot of cross-learning :-)

Angela October 3, 2012 at 12:18 pm

Super interesting and informative post. I had noticed that Herbal Essences had changed their packaging, but didn’t know about the new formula. (As a desensitised German, the raciness of the commercials totally escaped me, although I did witness some male British friends getting very excited about the shower scenes).

I liked the links to the official data on dioxane. However, these can be quite challenging to understand (mostly because of the bad layout (why do big institutions never hire any of those unemployed graphic designers that could help them and us out??). It might be an idea to mention suggested levels for a ‘safe limit’ by other institutions, to put the figure of e.g. ’24 parts per million’ into perspective.

egndukwe October 3, 2012 at 9:17 pm

Hi Angela, very true, a lot of the fact sheets that are made for the public can be pretty difficult to navigate around. I’ll keep that in mind for the next time and give more specifics about where to find particular information. Thanks for the feedback!

Sheela Doraiswamy October 3, 2012 at 12:56 pm

Interesting article. I had read a while ago that shampoos have ingredients that dry the scalp too much, so I switched to using an organic shampoo for a while, but it just didn’t feel like it was cleaning my hair very well. Now that I’ve read this, I might try out the organic one again.

Quintus October 3, 2012 at 1:01 pm

Again a nice post with accessible links.
I think you may have the ethoxylation process the wrong way round. Ethoxylated fatty alcohols are often converted to the organosulfate. A good example is sodium laurel sulfate which is a foaming agent in shampoos and toothpastes, as well as an industrial detergent.

egndukwe October 3, 2012 at 10:19 pm

Quintus, thank you for your feedback! What I understand from the sources I utilized is that ethylene oxide is added to alcohols and phenols to yield the milder product. In the case of Sodium Laurel Sulfate, the ethoxylation process converts Sodium Laurel Sulfate to Sodium to Laureth Sulfate, a gentler variant.

Quintus October 3, 2012 at 10:24 pm

Yes but it is the fatty alcohols which are ethoxylated first and then that product is sulfonated.

Margaret October 3, 2012 at 5:53 pm

This was a very informative article. As someone with little chemistry background it was a little hard to understand. I did want to understand it though, since this was my shampoo for years. I did like the way you explained that we as consumers might not be able to find dioxane on an ingredient list ans how it can be created in care products.

I really don’t know how I would change your approach to make this article more accessible for us without chemistry knowledge. I am glad you wrote on this topic.

egndukwe October 3, 2012 at 9:23 pm

Hi Margaret, glad you found this to be informing, I was especially drawn to the topic because of how widely popular Herbal Essences products tend to be. I’ll keep your suggestions in mind for the next post, I appreciate the feedback!

Rick October 3, 2012 at 8:01 pm

Very informative and your writing style is very smooth. One typo, I think, unless P&G only has one consumer (penultimate paragraph)!

I don’t live in the US (or the UK, or Germany) so I’m not familiar with those commercials.

adleylab October 4, 2012 at 7:32 am

i read your blog, its so nice and also provide us good knowledge about”MIND THE SCIENCE GAP”, I really like it, Thanks to write this blog.

Shara E. October 4, 2012 at 8:18 am

Great post! Do you know what the “acceptable” level of Dioxane in products is? Is 24 ppm way over that? (Under?) Is there even a consensus on a ‘safe’ level, legislative or or otherwise?

egndukwe October 4, 2012 at 11:07 am

Thanks Shara! All the information I found on the “acceptable” levels of dioxane were very vague. I’ve linked the FDA page that discusses how harmful dioxane can be in cosmetics in the 3rd paragraph under “no established levels of dioxane”. I did find results from studies which evaluated effects of exposure in humans and rats which can be found here on the 3rd page:

In the studies the exposure levels ranged from 1,000-30,000ppm, however, one thing to keep in mind is that the studies looked at inhalation of dioxane. Overall, it seems like this is an area that needs to be further researched. Thanks for the feedback!

Andrew Maynard October 4, 2012 at 4:22 pm

Hi Ezinne,

Here’s the information on 1,4-dioxane in EPA’s Integrated Risk Information System:

The estimated exposure level for a 1 in a million lifetime cancer risk is 0.35 µg/L in drinking water

Brian Zikmund-Fisher October 4, 2012 at 2:18 pm

If I may combine your post with Ali’s on Guiltless Gluttony, it seems as though we have a problem: Failure to label allows products to potentially expose people to hazards that might be significant, particularly over time. Labeling a product as having such exposure potential, however, undoubtedly triggers a negative response that may or may not take into account any sense of likelihood, magnitude, or benefit.

So how would you have wanted to be informed by the producers? Is there any type of notice that would still have led you to consider buying the shampoo anyway?

Gaythia Weis October 4, 2012 at 3:40 pm

My thoughts on Brian Zikmund-Fishers point above: I favor full labeling, even though I recognize that as first implemented, this may lead to a much confusion as it does enlightenment. Thus, I think that our current FDA regulations that sometimes allow “contaminants produced during manufacturing” to escape labeling requirements are wrong. In a democracy, public access to information is vital. In my opinion, with increasing abilities to do “big data” tracking, and smart phones, we should soon be able to shop and access databases and ingredient information at the same time. Then, I believe that linking the label with product safety information can more readily lead to wiser purchasing choices.

In the meantime, those of us who are chemists, or are knowledgeable of chemical processes, need to educate the public in general regarding such things as detection limits, uncertainties of risk at low exposure levels and to the concept that chemicals are still chemical, whether or not they come from natural sources.
Here, I think it may help to make sure that the article clearly distinguishes between dioxane and the more familiar and scarier “dioxin” And route of exposure matters. One thing about shampooing hair that has changed through the years is that it is now done much more often in a shower than bending over a sink! Maybe we need to consider ventilation as well as skin contact.

Two sentences are run together here, with something missing: ” In these studies, rats were exposed to Many companies are able to avoid listing dioxane on product ingredient lists, as it’s not technically an ingredient. Instead, it’s a byproduct of a process used in production called ethoxylation.” Straightening this out should aid in making your explanation of the process of ethoxylation of surfactants easier to understand.

egndukwe October 4, 2012 at 3:51 pm

Thank you for pointing that out, that was a typo made today while considering whether to edit the post by including additional information. Thank you for the feedback!

PF Anderson October 6, 2012 at 1:16 pm

What a VERY important topic! Are you aware of the extremely high levels of dioxane in the Ann Arbor water table on the west side of town? There is a huge amount of info about it, but this is just a link to the watchdog organization.

It’s all pretty sad, and the dioxane plume from Ann Arbor will reach the Huron River in just a few more years, messing with the state water supply and Great Lakes.

As a relatively newly diagnosed celiac, I’ve become uncomfortable aware of contaminants in personal care products. It is absolutely amazing where they hide wheat.

Regarding the post itself, it is a little worrisome to me when folk use an image from elsewhere online, without providing a direct link to the original online source. It seems like folks in this blog have developed a fondness for where this image is at

The site includes guidance on how to provide attribution for their photos.

For free use in an educational blog, it is “It is mandatory to publish an acknowledgement to and the image creator on the page each free image is used on. For example: “Image courtesy of [contributor name] /”. It should be clear which image the acknowledgement relates to.”, per their details at

That information for this image should have included:
– Image creator’s user name: “photoexplorer” – view portfolio
and might have either included the image ID or a direct link
– Image ID: 10078328 – stock photo uploaded on 29 March 2012

Likewise, you selected a range of government, watchdog organizations, and popular press resources for your supporting evidence, all of which are HIGHLY prone to becoming disappearing links, but you neglected to provide end notes or a bibliography from which people could later try to identify the sources if they relocate or disappear. Some of the links you selected will be unavailable to some people, as being behind a firewall or fee-for-access. It would be a kindness to include information on the item so that people can decide whether it is worth them making the effort and paying the cost of actually seeing the evidence. For the articles from the popular press, I’m assuming that you selected articles which reference original research. Perhaps consider going back to the original research, instead of citing the NY Times?

I’m curious why you chose the Green Patriot Working Group to lead into the question, what is it that makes them such a strong and reputable reference? Or are they? You didn’t provide a link ( ) but when I found it and went to their site, the main thing I noticed was their advertisements. I tried searching for dioxane on their site and found information that was interesting, but which I wouldn’t myself consider citable. I’m guessing that’s why you didn’t include any of their links, but then why mention them? I’m confused about that.

I absolutely ADORE your final paragraph:

“What’s most unnerving to me is that companies are using loopholes to avoid listing the presence of harmful chemicals in their products. It may be idealistic to expect to completely avoid exposure to harmful toxins, but as a consumer, how can I make informed decisions…without the information?”

To me, that is the most important thing you say, and it is buried at the end. Perhaps you could have opened with that? It also isn’t clear to me that you’ve demonstrated the existence of the loopholes. I firmly believe they exist, but I would really appreciate seeing the proof.

Bravo, and thank you so much for this! I look forward very much to future posts from you, hopefully exploring more of these important topics.

Finally Bro Steve October 18, 2012 at 11:45 am

Your write up was very thought provoking and created a lot of awareness. I have to look more closely to the chemical contents of shampoo, soaps and all the skin or body cleansing formulations that I use.

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