Course:SPPH 381E/Projects

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By: Aysan Dehghani (45686821)

The Life-Cycle of Tampons: A Work and Safety Risk Assessment

Figure 1. Percentage of women who use feminine hygiene products (Wendee A72).


Tampons cost over 26 billion USD globally (2019)[1] and on average, a woman will use between 11,000 and 16,000 tampons in her lifetime[2]. Figure 1 shows that in comparison to other feminine hygiene products such as pads, wipes, powders and panty liners, tampons have the highest number of users[3]. As tampons are absorbents, they are primarily made to prevent menstrual leakage from two absorbent ingredients: rayon and purified cotton. In this risk-assessment assignment of tampons, the main ingredient of focus is cotton: an absorbent fiber. As tampons are considered a medical device, they are regulated by the Food and Drug Administration (FDA)[4] and the ingredients used to manufacture a tampon are required to be fully accessible to the public. Although the process is not fully disclosed to the average tampon user, some companies such as Tampax have been mostly transparent about how their products reach the average Tampax user. Tampax, America's largest tampon brand, is a feminine care company regulated by Procter and Gamble (P&G), one of America's largest manufacturer of fast-consumer goods, which harvests cotton from family-owned farms, such as Barnhardt Purified Cotton. Before reaching the average consumer, cotton used to make the Tampax tampons are harvested on farms across the States and purified in Barnhardt factories. In the factories, the cotton goes through an extensive process to remove the excess waste and plant material from the cotton fibers. This process includes: ginning cycle; purification; scoaring; and chemical testing. In this risk-assessment assignment, the hazards towards workers in manufacturing companies during purification and scoaring of cotton are assessed using the Hierarchy of Controls model (Figure 5.).

History of Development

Since the time of the Ancient Romans, women fashioned devices out of wool to absorb menstrual flow, and in places such as Hawaii and parts of Africa, women used ferns and rolls of grass to control leakage[2]. It was not until 1931, when Earl Hass, an osteopathic physician, patents a period product comprised of a compressed cotton with a string in the centre and housed in a paper tube (an applicator) (Figure 2), that the modern day tampon was born. Shortly after, Gertrude Tendrich, the female founder of Tampax, bought the patent from Hass and started a female-led and female focused company that empowered women to manufacture products that affects their health and bodies. For many, this is an oversight today by large corporations that do not disclose materials and ingredients that are present in their tampons. For many, their reaction to tampons have led to toxic shock syndrome (TSS): a condition caused by bacteria in tampon materials releasing toxins in the body. Since the 1980s, consumer groups in the US have been wanting to know more about tampons due to multiple outbreaks of TSS, but since tampons are FDA regulated, full disclosure is not required[2]. Hence, it is crucial that such transparency in the manufacturing is evident - both for women, and workers.

Figure 2. Earl Hass' first tampon with an applicator patent, 1933

Tampon Ingredients

Table 1. Tampon Ingredients[4][5]. Below are the possible ingredients used to manufacture a tampon.
Absorbent core Overwrap fabric/non-woven cover Withdrawal string Additives/adjuvants Applicator
Rayon Rayon Rayon Fragrance ingredients cardboard
Cotton Polyethylene Cotton lubricants plastic
Organic cotton Polyproylene Polyester odor control agents polythylene polymer
Polyester Polypropylene anti-bacterial (Anti-TSS) compounds plant-based LDPE plastic
Organic cotton Water repellant wax colorants colorants
hydrophobic or hydrophilic fiber finishes

Raw Materials Production: Farming

After cotton has been harvested on one of Barnhardt's family farms, producers use conventional tillage practices to cut down and chop cotton stalks[6]. It is important to note that in this process, mostly everything is automated. Hand labour is no longer used in the US to manage cotton crops. Instead, it is harvested via machines, which are either a picker or a stripper. Cotton plants have their own life-cycle purifying process during manufacturing (Figure 3), which for Tampax, takes place in the Barnhardt Purified Cotton manufacturing centre, or the P&G plant in Auburn Maine, which is the main manufacturing plant for tampons in the U.S. Before being purified though, the plant goes through a ginning cycle (Figure 7.): this is where all the seeds and stems are separated out from the organic cotton[7].

Figure 7. Gin machine at Barnhardt Factory

Hazards in Farming Cotton

Hazard: Cotton dust [100mg/m3 = dangerous to life and health] 

Hazard Identification

Hazard Identified Chemical Biological Physical Ergenomic Safety Environmental Work Organization
Cotton Dust X
Acute health effects

Cotton dust is a colourless, odorless, solid, and is generated through processing of cotton fibers[8]. Amidst cotton dust, workers are at risk of breathing in the dust and experiencing symptoms of chest tightness, breathing difficulties, wheezing and coughing. Cotton dust could lead to more symptoms including irritation of the eyes, nose, throat and lungs.

Chronic health effects

Over an extended period of time, workers are at higher risk of developing chronic diseases such as byssinosis (Figure 8[9].): a disease of the lungs through repeated exposure to carcinogens, including dust, which the Cancer Council[10] classifies dust as a carcinogen.

Figure 8. High Resolution CT Scan of ill-defined Nodules in Lungs from Byssinosis

Workplace Exposure and Control

Figure 5. Hierarchy of Controls (WorkSafe BC)

To reference the hierarchy of controls[11] (Figure 5), to best protect workers from cotton dust, engineering controls are the most effective way of reducing exposure. This is because isolating people from cotton dust through effective means can reduce exposure. Evidently, there is no way to eliminate or largely minimize the dust, but there are ways to protect workers through standards of engineering controls.


The measurement procedures in place for collecting samples of cotton dust is through a vertical elutriator preselector (Figure 11[12]), which has a high-efficiency membrane filter that can analyze cotton dust amounts[8]. To avoid using such tools and decreasing efficiency at the workplace, it is recommended that there are good housekeeping practices designed to prevent an increase of lung disease incidences. For such workplaces, there is a positive correlation between age and duration of exposure. Although the demographics for Barnhardt's employees are not disclosed, one can assume that workers between the ages of 30-50 are more prevalent in manufacturing settings.

Figure 11. A Vertical Elutriator

Studies[13] find that there is a correlation between age and duration of exposure (Figure 12[13].). In all, early prevention is the right course of action, as the closer the worker is to the beginning of a process, the higher the dust level will be (pre-ginning for example). If a worker is exposed to the higher dust levels for a number of years, even decades, their medical prevention becomes too late when they're in the mid-50s for example, and they could develop serious cases of lung diseases such as byssinosis.

Figure 12. Correlation between duration of exposure and age

Work practices[8]:

  • changing clothes promptly when contaminated
  • having eye-wash fountaions at work sites
  • not eating or drinking where there is cotton dust handling
  • using a full facepiece PPE with an air-respirator
  • using PPE goggles at the work-site at all times

Product Manufacturing

Figure 3. Cotton Purifying Stages (Barnhardt Natural Fibers).

With the main Tampax P&G plant located in Auburn Maine, the purification of cotton takes place within the main plant across the U.S. With the plant employing about 400 people, the plant's location is in the country's least-populous state, as its location takes advantage of the timber supplies of tree-derived cellulose fibers tampon manufacturers use for absorbency, and cardboard for packaging[14].

At Barnhardt cotton processing, the finished product (cotton post-ginning), goes through an extensive purification process at the cotton processing plant before it ends up at the hands of consumers. Figure 3. displays the stages of purification of cotton. This is because cotton fiber has a coating of natural waxes that protect it from rain, which ultimately makes it hydrophobic (water repellant), which pretty much renders the tampon useless, as consumers use it to absorb menstrual flow and prevent leakage. Hence, the cotton purification stage in manufacturing's main goal is to create absorbency.

Cotton Purification[15]

Figure 4. Scouring with a Kier[16]
Table 2. Cotton Purification Stages: Scouring and Purifying For the purposes of this risk assessment, only the first 3 stages of the purification process are evaluated in the table below, as they involve harmful chemicals (hydrogen peroxide) and equipment (kiers) that workers are exposed to. Moreover, the longevity and repetitious nature of their tasks could expose them to more hazards they might not notice.
1 This stage involves removing all the non-lint material by opening the dense tufts of fiber from the ginned cotton bales, to EVOC (enhanced, visual, opening, cleaning system), which removes much of the plant matter. The rest of the process takes place in kiers: a large circular boiler used in bleaching and scouring cotton fiber. Kiers are sped up and pressurized to speed up wet purification process.
2 During scouring, a solution containing sodium hydroxide is pumped into the kier to scour the cotton. This is to soften any of the small amounts of plant matter that are in the cotton.
3 Barnhardt uses hydrogen peroxide as an oxidizing agent to whiten the fibers by oxidizing the colour matter, which makes the process of purifying totally chlorine free (TCF). Once all the colouring bodies have been removed, the cotton fibers are pure cellulose.

Hazards in Cotton Purification

Hazards: Kier boiler and Hydrogen Peroxide

Hazard Identification

Table 3. Identifying Type of Workplace Safety Hazard: Hydrogen Peroxide and Bleaching Kiers
Hazard Identified Chemical Biological Physical Ergenomic Safety Environmental Work Organization
Hydrogen peroxide X
Bleaching kiers X X X
Hydrogen peroxide

Acute health effects

Hydrogen peroxide (H₂O₂) is a colourless, odorless liquid, and a common oxidizing and bleaching agent. Due to it being usually in a water solution, it does not appear harmful or dangerus. But contact with H₂O₂ can severely burn the skin and eyes, and cause possible eye damage. Moreover, it can irritate the nose and throat, and higher concentrations can cause skin rashes, redness and blisters[8]

Chronic health effects

The long-term effects of H₂O₂ can cause diseases such as pulmonary edema, the obstructive build-up of fluid in the lungs, which is classified as a medical emergency[8]. As for the skin, prolonged exposure can cause temporary whitening of the skin and stinging sensations.

Bleaching Kier

Bleaching kiers (Figure 4) are vertical tanks about 3 meters in diameter and 4 meters in height[17], and are one of the most common causes of injury and fatality in the clothing industry[17]. When in process, one of the workers have to go into kiers (which uses boiling water, bleaching solution, and alkaline liquor in the process), to stack or remove pieces of cloth. Deaths have occured in the workplace wherein one worker has been in the kier and another worker unknowingly opened the valves to insert one of the liquids.

Noise in Bleaching Kiers

Another hazard of bleaching kiers is the level of noise the kier emits. Moreover, it is impossible for workers to hear one another without shouting into each other's ears, which can be damaging in itself. Moreover, the noise in the kier rooms often go above 85 dB, which according to the Hear Health Foundation, any noise about 70 dB is damaging[18].


Although hydrogen peroxide and its amounts are mainly pre-determined and labelled in the workplace, workers might be less cautious to it if they have been in the place of work for extensive periods of time. Perhaps re-labelling or conducting safety-checks to make sure staff know where harmful chemicals are stored and used could ensure that workers are alert.

Workplace Exposure and Control

Figure 6. PPE Standard against Hydrogen Peroxide

In order to intervene and aid workers against hazardous chemicals such as hydrogen peroxide, it is important to report signs and symptoms early on when they suspect exposure to hydrogen peroxide. The CDC suggests that initial medical screening take place to rule out any previous medical history that might be exacerbated by hydrogen peroxide[19]. Moreover, although engineering controls are preferred, respirators can be of better use in this situation. Without workers, vessels such as bleaching kiers cannot operate alone, hence isolating workers from the hazard is not a direct solution. Devices such as vessels or tanks that employees can walk into during emergency situations are more effective, instead of having accidents occur and following-up later. Some other controls include:

PPE (Figure 6.):

  • face shields as wide at 8 inches minimum should be used around hydrogen peroxide to prevent any excessive breathing-in and other risks of irritation.
  • consistence use of clothing and gloves to avoid skin contact
  • if clothing is contaminated: they should be kept in a close storage space or container until it can be discarded
  • in the case of emergency: there should be facilities for quick drenching of the body.


  • the consistent washing of hands is a safety measurement that could help reduce skin irritation and exposure to hydrogen peroxide
  • showering thoroughly after work


  • when trying to dispose hydrogen peroxide, the substance should be diluted with copious quantities of water, hydrogen peroxide may be flushed into a sewer.


  • To keep caution and identify H₂O₂ in the workplace, all containers handling the chemical should be labelled.


In summary, the identification of hazards in the workplace such as manufacturing plants and farms is crucial to protecting workers that are needed in our feminine care industry. As reported, there are staff shortages[14] in P&G's plants, as workers are not compensated with a fair hourly wage. With a factory that employs over 400 people, measures are required to keep the employees safe, which in turn, keeps the products safe as the workers are not in fear of their safety at work, and hence they can conduct their tasks at work. In this risk-assessment and life-cycle summary of tampons, in reference to the hierarchy of control (Figure 5.), engineering controls are preferred, but within cotton factories, PPE's were mostly suggested. Careful covering of workers in PPE ensures that they are protected at work, and pre- follow-up screening is preferred in and out of work. The evaluation of hazards such as cotton dust on workers showed that most workers in these settings are between the ages of 30 and 50, which means that there is a lower prevalence of early detection if medical screenings are conducted decades after a worker's exposure in their workplace. In accordance with CDC's methods of prevention and safety in the workplace shown in this risk-assessment, I would add that allowing workers to have immediate access to medical screening after or before work is crucial, and extensive follow-ups after even minor incidents could eliminate any chances of diseases or chronic illnesses arising. Ensuring that worker's safety is secured can ensure successful practices.


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