Doug Schoon Responds to Misleading Claims by Oregon OSHA That “Methylene Glycol” Is a Synonym For “Formaldehyde”

Ask Doug Schoon why Oregon OSHA confuses Methylene Glycol with Formaldehyde and he’ll reply:

“Oregon OSHA is quoting the “regulations”, but their scientists know the regulations are contrary to the scientific facts and have recently told me this!

In reality, Methylene Glycol and Formaldehyde are very different, both chemically and physically! Methylene Glycol is a liquid; Formaldehyde is a gas. Even so, Oregon OSHA has recently declared that these are “synonyms”, yet these two substances have very different chemical compositions and belong to different chemical families, the Aldehyde vs. Alcohols*.

Also in 1972, both Methylene Glycol and Formaldehyde were assigned different CAS registry numbers indicating the American Chemical Society also believes these are different and unique chemical substances. Chemists with an understanding of organic chemistry will agree, whatever their opinion about these substances, that Methylene Glycol and Formaldehyde are two completely different chemicals.

It is unfortunate that this world-wide misunderstand continues to propagating confusion and mislead medical, environmental and other scientific researchers around the world. Confusion between these two chemicals is wrongly affecting important scientific research and correcting this error is long overdue. Scientific researchers and others should be educated to the facts; Methylene Glycol and Formaldehyde are NOT the same chemical substance.

I have considerable respect for OSHA and very much appreciate the great work they do to improve worker safety. Even so, OSHA should correct the regulations to be consistent with scientific facts. They should consider Methylene Glycol and Formaldehyde as two unique and individual substances, measure them as such and individually report their concentrations using correct chemical names.”

*Glycols belong to the Alcohol family of chemical substances

Oregon OSHA New Release: http://www.orosha.org/admin/newsrelease/2010/nr2010_25.pdf

OSHA- Occupational Safety and Health Administration (US Federal Department)

CAS- Chemical Abstract Service

EINECS- European Inventory of Existing Commercial Chemical Substance

INCI- International Nomenclature of Cosmetic Ingredients dictionary

Aldehyde- organic compound that contains a carbonyl center bonded to a hydrogen.

Glycol- organic compounds that belongs to the alcohol family and contains two alcohol groups.

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  • http://greenskincareblog.com/ Kristin Fraser Cotte

    Thanks for bringing some scientific clarity to this issue Doug. I’ve been trying to find science backed info for a few weeks since all of the press on the Brazilian Blowout product containing Formaldehyde. Coincidentally, this coincided with a visit to my hairdresser, where she suggested the treatment and swore up and down it was “natural” and would not damage my hair… hmmm.

    Thanks for your informative contributions to PCT!

  • http://www.facebook.com/people/Fatin-Khawarizmi/100000541803855 Fatin Khawarizmi

    Still so many things are absurd and need a scientific explanation, i did read about some vitamins in yeast that they couldn’t give it a specification, specially some kind of vit B .
    Interesting article.

  • http://www.fit2b.us Beth

    I get so irritated at people that want to make everything poisonous. It’s ridiculous. With all the close friends I have in the makeup/skincare business, they are going to love this article!

  • Brittanylanemiller

    So… I would like to know what METHYLENE GLYCOL will do to your body? I am a hair stylist and have been doing the Brazilian Blowout in my salon. I want to help make people’s hair beautiful but I also don’t want to get cancer and lose mine!

  • http://twitter.com/essentialU Kayla Fioravanti

    A picture is worth a thousand words! The molecular model says it all. Thanks for this very informative post.

  • Me

    Douog – you should be ashamed of yoruself…..seriously, who is paying you off??
    Anyone with decent chemistry background will tell you of equilibriums and how formaldehyde converts to Meth.glycol and it goes back and forth….just like saying that NH3 and NH4OH are so drastically different….
    And even if you stick to your claim…then tell me how is methylene glycol safe if it is so much like anti-freeze?? (ethylene glycol)??

    • Dene Godfrey

      @Me – I note your heavily sarcastic response in another PCT post as well as this one, and I also note that you hide behind total anonimity. Your chemistry background clearly is not sufficient for you to know that the pural of equilibrium is equilibria. Nor is it sufficient for you to fully understand equilibria! NH3 is a gas, ammonium hydroxide is a liquid. That is quite a drastic difference!
      You compound your obvious ignorance by making an entirely unscientific statement about antifreeze. “If it is so much like” is not a scientific basis for a toxicological comparison. You may as well claimn that sodium chloride is dangerous because it is so much like sodium. Ridiculous!
      To try to prove an argument by asserting that someone is “being paid off” is neither logical nor what I would expect from anyone trying to prove a point. In fact, it is quite offensive as a tactic, especially when your own claims are so entirely wrong. Instead of crawling around under your cloak of invisibility, please have the guts to use your real name – or would that prove too embarrassing for you? Posts like this have no place on PCT, and it is a testament to the fairness of Kristin and Lisa that it was actually allowed web space!

      I don’t enjoy being this blunt, but I do find this comment offensive and wrong.

      • bruce akers

        I agree with your statement that me’s post was in an improper tone, and should give more respect to the people here involved. However, his NH3+ H20 NH4OH example is a very good one to explain the CH20 + H20 CH4O2. Yes one is a gas, but we all know gases can dissolve in liquid, the CO2 in beer a perfect example. Formaldehyde is very soluble in water, and reacts to form an equilibrium with CH4O2. The part about anti-freeze, I agree is irrelevant, but no reason to throw out his whole argument, he did make one valid and important point. The two species aren’t that different when in an aqueous state.

        • Doug Schoon

          Hi Bruce,
          I understand what you are saying but disagree with one of your statements. Formaldehyde is not very soluble in water. That’s the misunderstand that lead to this confusion. The early manufacturers of this substance thought they were making “formaldehyde water” and sold it as such, and the myth continues today. Formaldehyde is very “reactive” with water and much prefers to be methylene glycol, a chemical the world seems to pretend doesn’t exist. My point is to say we should all admit this exists and measure/report it as such. Why not? This misunderstanding is confusing medical research around the world, e.g. many researchers feed rats with 37% formalin, report the results as formaldehyde ingestion since they are completely unaware they’ve actually fed these rats, 59% methylene glycol and 15% methanol! That sounds like a problem waiting to be address and solved. I’m flabbergasted that so many want to ignore the scientific facts and live with the misconceptions. I hope you agree and will help push for correction of this misinformation.

          • http://pulse.yahoo.com/_RM6FYXYOF2F6DPIXTOEKXA3724 Bruce

            Doug
            I looked formaldehyde up in the Merck Index (12th edition) , a source I consider quite scientific, and it lists formaldehyde as “very sol in water, up to 55%”. If you have a reference to contradictory information I would certainly love to see it.

          • http://pulse.yahoo.com/_RM6FYXYOF2F6DPIXTOEKXA3724 Bruce

            Doug
            and upon further research, I find the equilibrium constant for the reaction K=[CH2(OH)2]/[CH2O][H20] is equal to 18 (gotta love having old O.Chem textbooks lying around), so I will agree you are correct, that although formaldehyde is quite soluble, most of it does exist in the Glycol form. So it would seem the tox data on aqueous fomaldehyde is actually a study on Methylene Glycol. This being said, it still does not contradict the toxicity of the formaldehyde releasing preservatives since they are certainly aqueous, penetration studies aside. One could also make the argument that even the inhalation studies might have some validity since one could assume that most of the damage is done once the aldehyde is introduced into the blood steam and becomes the glycol. I certainly agree with your statement that the terminology may be flawed here, just not sure if this contradicts the findings. Thanks for pointing this out.

            It does bring me back to a point the FDA has never truly clarified for me. Are we supposed to label products by what ingredients are added, or by what reactants are produced? Should Lye be on the label of soaps, or is it saponified oil? Sorry for the tanget, but I am tangental…

          • Mjmontgomery

            Hello Doug:

            Thank you for all your information regarding Methylene Glycol.

            I am a hairdresser who uses a product by the name of Brazilian Blowout that contains Methylene Glycol. It is also heated during the application process and smokes.

            Would you please ease my concern that the use of this product could harm me and my client?

            Thank you in advance!
            Jo Montgomery

          • http://www.cactusandivy.com Lisa M. Rodgers

            Hey Jo -

            Many thanks for your question. Have you checked out Doug’s post http://personalcaretruth.com/2010/10/the-hair-smoothing-controversy/

      • Me

        As you can see I did realize I was wrong in my tone.
        However, you can’t question my knowledge of chemistry just b/c I don’t care to spell correctly.
        As for the NH3 vs NH4OH – thanks for confirming my analogy. Yes, NH3, like formaldehyde is a gas. Yes; NH4OH like meth glycol is liquid….now time to check out chemistry text book and see how well that analogy works….both gases are highly reactive, both of them when “mixed” with water will form those 2 respective entities that then are in a state of equilibrium….funny that for both the point of saturation in H2O is about 40%. They are drastically different from each other – YES, but to explain to a layman about formalin and meth glycol – I believe it was a good example.
        And by using your example of NaCL being like metal Na is just so wrong and illogical…sorry if you can’t see my point and have to resort to such analogies….frankly it is as poor as my initial argument to Doug about being paid off….

        One more item; about being annonymous….recently graduated and started working at one of the leading natural cosmetic companies and I am a bit disillusion….not becasue they don’t care about the consumers (they really do) but b/c they choose to use the same logic…once I leave it and won’t be associated with any such company – I feel I can then represent myself.

        • Dene62

          @Me – my choosing to pick you up on using an incorrect word was intended as more of a response to the tone of your message, rather than to question your knowledge of chemistry, and I appreciate both your admission that your tone was wrong (although I fail to understand why you felt the need to be quite so rude) and your reason for retaining your anonymity (although I hope that you can appreciate my initial response, given the tone of your comment).

          As Doug has agreed with my assessment of your comparison with ammonia, etc, I will not dwell further on this other than to say that my comparison using NaCl WAS a reasonable (ie illogical) comparison on this basis.

    • Doug Schoon

      Hello Me,
      I don’t dispute that methylene glycol (MG) is in equilibrium with formaldehyde, but instead I say this should be more carefully studied and properly reported, esp. since MG is favored 99.6 to 0.04 and it clearly the more important species. If you read my statement, it asks OSHA and others to “correctly” measure and report what they find and not cause confusion by mixing and matching terminology to fit regulations based on a 100+ misunderstand. The regulations should match the science, not the other way around. How can we ever get to the truth if we hide from it? We should be studying MG, not pretending it doesn’t exist by calling it formaldehyde.
      BTW: Ammonia gas and Ammonium hydroxide are pretty different. If you were being exposed to one or the other, wouldn’t you want to know which one?

      • Me

        First of all I have to appologize to you. My tone was absolutely inappropriate. I am sorry for that. However, I do stand by my assessment; Formalin is to Meth Glycol as Ammonia to Ammmonium hydroxide. The idea here is that both react with water – you cannot identify NH3 gas inside that “solution” – it converts to what people refer to NH4OH but we know that even that isn’t 100% correct….due to the interaction with water and forming a equilibrium.

        The bottom line for me; If, as a consumer, I speak of formaldehyde in cosmetics – I know it means; Formaldehyde donors = formaldehyde = meth glycol. It’s all the same to me. I don’t want ANY of it.
        Even though, regs may allow up to a certain limit of formaldehyde in the final formula – I believe that responsible producer won’t resort to this game of saying…”well, it’s not really formaldehyde – it’s meth glycol”
        Hope you see my point.

  • Doug Schoon

    Hi Maria,

    I’ve told both the NTP and EPA about this error and the EPA publically thanked me for my “insightful comments”. These agencies aren’t using scare-tactics, the regulations are scientifically wrong. There is no question that methylene glycol is NOT formaldehyde, despite what you see on the Internet. What I am saying is scientific fact!

    You correctly point out that the same product has been tested by many official government agencies who have reported the “same product” to have between 7-12% formaldehyde. That wide variation ALONE demonstrates these test methods are badly flawed and yield inaccurate results for water-containing cosmetics. I completely agree this should be about “air exposure levels”. That’s what’s important and what Oregon OSHA should have measured and reported.

    Another very real issue is that MOST salons don’t understand or ignore the importance of proper ventilation. A fan isn’t “ventilation”. Salons need to invest in ventilation suitable for the work they perform and that’s not happening. For example, they’ll move into an office space previously occupied by a travel agency and do nothing to improve the ventilation. Many beauty schools have little to no ventilation. This was an important problem before these hair smoothing treatments came along and continues to be a huge problem this industry needs to address.

  • Philippe Papadimitriou

    Hello Doug,

    You know I am in favor of truth and do my part of education on the matter of Formaldehyde/Methylene Glycol. This short article is another informative brief report to forward to whoever I need to pass the info.

    I join you when you say we need to know about MG safety now that we have been mistaken so long.

    I will anyways give Bruce his share (with an intellectual “bravo”), because he brought very interesting views on toxicity reports done on Formaldehyde. I think it is important to check the materials and methods used on every single safety study regarding the gaz to know if we did finally assess the safety of MG or formaldehyde. Would be stupid to spend too much time starting new studies to come to the same conclusions. If the methods use the “gaz in water” (I try to keep it simple for everyone to understand), then the toxicity reports are linked to 99.6/100 MG.

    @ Bruce,
    Well done!
    Concerning your Merck Index quote on the other side, I guess it would be good to know on what basis (what study) did the editor or its collaborators select this info. I do not think there has been much change in the Formaldehyde entry for a long time in Merck Indexes as this substance is considered to be too well-known probably, and ..erroneously. I have here the 10th edition as the oldest (1983) and the same info is available. In this same 10th edition, the entry on “Formaldehyde Solution” is simply wrong in regard to the subject here addressed. What’s on your 12th edition? If this is wrong in your edition, it prooves that there are some mistakes on this chemical bible; at least the edition to which you are referring yourself.

    To your other question (what to announce on packaging), I think you’d better stick to what you put rather than what you expect as reactants. Particularly if you are mixing plant extracts. I guess you see my point. Or natural cosmetic manufacturers will have far more work, complexe formulas and use far more paper for their cases…

  • http://twitter.com/chemistscorner Chemists Corner

    I was trying to find information about the differences between Methylene Glycol & Formaldehyde but perhaps it doesn’t exist.

    The freezing point of Formaldehyde is -118C. The boiling point is -19C. (http://vpl.astro.washington.edu/spectra/h2co.htm)

    What is the freezing and boiling point of Methylene Glycol?

    The point that Bruce makes is a good one. The toxicity tests of these materials is not likely done with Formaldehyde but rather the blend of Formaldehyde/Methylene Glycol.

  • Kernyl

    Maria has got it right. We can discuss the properties of formaldehyde vs Methylene Glycol all day long and what we know about toxicity and it really doesn’t matter. The bottom line is that people are getting sick from this product. It should be taken off the market until it can be reformulated into a safe product.
    We can discuss the fine points and do the research later.

  • ChemSmith

    Correct me if I’m wrong, but I’m pretty sure people don’t walk around all day with wet hair. As soon as the hair dryer is turned on you start driving off water and forcing the chemical equilibrium towards formaldehyde. Since all the MG in the mix gets turned into formaldehyde in short order it is criminal to pretend otherwise.

    • Dene Godfrey

      Of course you are right, ChemSmith, people DON’T walk around all day with wet hair. But please can you explain what this has to do with Doug’s article, which doesn’t mention hair at all, and is solely concerned with explaining the difference between methylene glycol and formaldehyde. I think it is criminal to make accusations without properly reading the article! There seems to be a few steps missing from a thought process here.

      • ChemSmith

        This whole kerfuffle came about because of Schoon’s insistence that the formaldehyde in a hair care product was in fact not. His assertion is based on the flawed assumption that the formaldehyde is in aqueous solution and therefore in its gem-diol form. As the solvent evaporates the equilibrium shifts. Learn the context of the discussion before inserting ad hominem arguments.

        • Dene62

          You certainly seem to have mastered the art of the unneccesarily rude comment. Being clever doesn’t preclude anyone from being polite! The point I was trying to make was that you were being sarcastic about wet hair, and Doug’s article at no point mentions hair. Whether or not your point was actually correct,it was out of context and unreasonably rude (as is your follow-up comments). There are hardly ANY rude comments on any other post on this site. Rudeness and arrogance detract from your point, whether or not you are factually accurate. It is simply not neccesary, and is especially unpleasant when hiding behind a pseudonym.

          • ChemSmith

            There is also hardly any chemists discussing the chemistry in this article. Likewise most of the comments are ignoring the logical fallacy of an appeal to authority. While Mr. Schoon certainly has a large amount of experience with the regulations involving cosmetics, that does not mean his statements are undeniable facts. In this case his statements are grossly misleading.

            My choice of brash language was made in order to get my comment to stand out against the din of self congratulation permeating this thread. I also chose to make my comments in the context of the overall discussion regarding the use of toxins in hair care products. I’m sorry you don’t like my stylistic choices.

          • Philippe Papadimitriou

            Dear Chemsmith,

            We beg for your indulgence as you have definitely shown us your superior knowledge in chemistry (Le Chatelier – great!). Remind me where you have taught us something and I will bow in admiration.

            Now, note the “toxins” semantics only regards toxic substances produced by living organisms. Many people only consider peptides and proteins to be toxins, but small molecules are also sometimes viewed as entering the category. Please accept my apologies for correcting you, none of the ingredients used in cosmetics (not only hair care) are toxins.
            Please do not try to pretend formaldehyde is a toxin as it is produced by some living organisms.

            What is the other “Bhopal menace” in hair care to you?

            NB: I agree on the “self congratulation” aspect, but that didn’t mean we were not addressing the problem.

    • Philippe Papadimitriou

      I think this is a valid point.
      But we are speaking here about low concentrations and with a time parameter for evaporation. Even with a hair dryer, this should not be of concern if a company follow the actual regulations (with in mind this reverse reaction). We are not speaking about the very high concentrations found in this BB sad affair.

      MG’s toxicity still needs to be assessed and more has to be known on the equilibrium.
      Formaldehyde is mainly used in nail products (that do not evaporate – on the contrary) and as this is not my field, I can not tell you if it can be replaced, but I was very surprised to learn about formaldehyde used in hair care products.

      Your point should be considered by experts if a new regulation has to be published.

      By now, MG was quite unknown and I do not think concentrations of it were high, as people sticked to the formaldehyde restriction.

  • Doug Schoon

    Hi Chemsmith,

    The hair always contains moisture and is NEVER “dry” and typically 10-12% of the weight of normal hair is moisture. Even the moisture in the air reacts with Formaldehyde and coverts it into MG. Also, it is highly unlikely that all of the Methylene Glycol is fully converted to Formaldehyde. Methylene Glycol is very stable and prefers to stay as Methylene Glycol. It takes a tremendous amount of heat to convert Methylene Glycol totally into Formaldehyde. I believe the temperatures required for full conversion would be so high the hair would also be vaporized. Then within nanoseconds of cooling the equilibrium shifts back instantly again toward formation of Methylene Glycol, which is by far more stable.

    Also, we all are constantly exposed to Formaldehyde every day and it is even found in every breath. It’s a normal component of our breath so clearly there are safe levels of exposure and Formaldehyde is not inherently dangerous.

    Doug

    • Philippe Papadimitriou

      That’s what happens when I speak about an issue I do not master. Hair contains water. Logical after all.

      Thanks for the relevant point, Doug!
      Thanks also for clarifying the obvious main goal of your article.

      I guess the comments have gone quite far.

    • ChemSmith

      Are you familiar with the work of Henry Louis Le Chatelier? Perhaps you should familiarize yourself with his principles. Of particular note is the concept that as a reagent is removed from a reaction mixture in equilibrium the other reagents adjust their concentrations to maintain said equilibrium. Because of the high reactivity of formaldehyde, any aldehyde formed will rapidly react with any nearby proteins or DNA. While the former may be beneficial for the hair care industry, the latter is a far more pressing concern from a health and safety perspective.
      Your insistence that two compounds in rapid equilibrium should be treated as distinct reveals either a fantastically poor understanding of basic chemistry or willfully deceptive intentions that border on criminal negligence. Next I expect you will say R-Thalidomide should be used to treat morning sickness as that isomer is safe. Your actions will only lead to a negative impression of chemistry as a profession. The industry has had enough problems thanks to Love Canal, Union Carbide, and Silent Spring. Kindly take your snake oil to a different continent.

      • Philippe Papadimitriou

        Chemsmith,

        While what you are saying isn’t totally wrong, I regret you say it with so much disrespect here.
        First of all, read Doug’s article again and note it is referring to the fact two molecules were confused for years of science. This is the main point. The only point actually.
        I guess you should at least give some credit to any scientist for his (or her) will to shed light on an issue that has been considered right for decades and that is not.

        Then, in the comments, to which Doug did not share his views about toxicology, came the toxicology debate. I regret your answer to Doug is so aggressive as he is not the one to blame. I would ask you to read all his comments again and come to the conclusion if your rude comments (and cynism) towards him are appropriate. Dene was right in his comment, there is no point to apostophise Doug on this aspect.

        If you want to discuss about chemistry, ok, but you do not need to insult members on this forum. We are all here to share our views and help each other. If you want to discuss about toxicology, refer yourself to the right persons and if you can be of so much help, do not hesitate to write to the OSHA at your own turn.

        Formaldehyde is naturally produced by the human body and we do not die from its presence. I do not know about natural concentrations produced, nor about the final percentage of exposure to it, when a product containing the maximum 0.2% authorised (considering the multiple equilibriums involved as MG also polymerises (polyoxymethylene glycols – J.G.M. Winkelman et al., Kinetics and chemical equilibrium of the hydration of formaldehyde, Chemical Engineering Science, 57, 2002, 4067-4076)) and the fact a gas expands in all directions (not to mention it would highly probably react with water in the air or the portion of water cointained in tissues before having reached DNA or any protein). Then if you can send me the info of skin penetration of formaldehyde (as a gas) or the one of MG (for toxicological problems to occur, the product has to enter), I will agree to discuss the issue further.
        Do you know the skin penetration rate and yield of caffeine (a molcule known to penetrate much)? Do not answer with a typical formaldehyde or MG is smaller than caffeine, I know; this is not my point. I can send you the data to releave your fears. That is if you agree to give me an e-mail address where we can further exchange or maybe your name.

        I am not familiar with the names you mention, but can not understand their relationship with “snake oil”..!

        Regards,

        Philippe

        • ChemSmith

          My objections to Mr. Schoon’s statements come from his false assertions that MG is different from formaldehyde and therefor harmless. This is like saying sugar isn’t sweet if you put it in water. Because he is acting dishonestly I feel no need to accord him any respect. He has sacrificed his scientific integrity for the sake of profit. And make no mistake that he has entered this discussion for profit. His CV speaks to a long standing relationship with corporate side of the cosmetics industry. They employ his services to negotiate with regulatory agencies. It is in his and his clients interests to have MG ruled a harmless component because it will permit them to circumvent the regulatory agencies. Whether Mr. Schoon is lying about the science because of ignorance or bad faith is a different discussion, but in any case he has a clear conflict of interest. The opinion of the American Chemistry Council (an organization that typically shows a friendly face to industry) can be found an the following address.
          www dot americanchemistry.com/s_acc/bin.asp?CID=2447&DID=11550&DOC=FILE.PDF
          For your own edification I recommend a quick wikipedia search of the term Bhopal disaster, Love Canal, and Silent Spring. All three are rather good reads.

          • Philippe Papadimitriou

            Chemsmith,

            Thank you for providing this interesting link (document dated Dec., the 9th 2010). I believe it will bring new light to the issue. While this document is relevant, it does not mean Doug’s article is wrong. The awareness brought by Doug was important. And it started much earlier than his present article. His views are the ones that have permitted the edition of the document you offer a link to. Even if the conclusions presented therein do not match exactly what he made us all aware of, they took HIS opinion into account while they didn’t take mine nor yours. Only for this, it at least important to give him credits.

            Besides, we still see that the problematic is not fully understood as the document mentions “formaldehyde in water” as if the species was solubilised. This has to scientifically be corrected. I guess you will agree.

            The next important point to consider is that methodologies to dose formaldehyde in finished products give wrong results. This has not been proven by Doug, but by other scientists. Doug once again made us all aware of it. This other problem has to be addressed. On this, I believe you will also agree.

            As you probably have read below, other comments were more directly discussing the toxicology issue. Some LinkedIn discussions went quite far with it as well. I am sure this kind of brainstorming can be a platform for scientists to really advance. Nobody did ever say formaldehyde was totally safe. Nobody came with the conclusion its restriction should vanish. Nobody did say methylene glycol was safe. Nobody did finally say we should not study this more in depth. The MG polymers also have to be studied. It makes sense that we have to see this as a whole and may not seperate chemical species fully. I guess it somehow relates to “chemical speciation”. If this is correct, the CIR conclusions for formaldehyde probably are still valid. Something new has to be done on MG. If this is ever done, it will be thanks to Doug Schoon (partially). This is of value, isn’t it?

            I do not know about the presence of some “vested interests” here. I may not speak for Doug, but I doubt his career and his general work have to be considered. I also work for the cosmetic industry and fight for some assumptions to be verified. There is probably a bias, of course. But in that sense, everybody has a bias.
            I think cosmetic products may be formulated without formaldehyde, but I do not know all classes and I do not want to sound too politically-correct here to just please the audience. On the other side, know formaldehyde is rarely used in cosmetic products nowadays. Nothing to be compared to the huge problems you were mentioning (I had heard about Bhopal, but did not remember about Union Carbide; thanks for having directed me to other catastrophies, but relax, this is nothing in comparison, whatever your chemistry background).

            Just one important note. There is a main difference is in the toxicity and purpose of the preservative in cosmetics and pesticides. Pesticides are designed to be toxic to the “pest” (i.e. insect or plant). They also tend to be toxic to man. Consumer products are intended to be inert or non toxic. In addition, pesticides tend to be perfect molecules for crossing the skin (molecular weight and kp), they are designed to cross biological membranes (eg plant & insect cuticles) in order to elicit their toxic effects. Those characteristics of crossing the pest membrane actually are the ideal characteristics to cross human skin membrane. Cosmetic ingredients are tested to show poor skin penetration. So do not compare cosmetic ingredients with pesticides, because this has nothing in common. Just a short addition to not get mistaken (so many wrong things are being said about cosmetics).

            PS: I doubt Doug has gained much money while writing this article or while fighting ti let this truth be known. He -I agree- defended the cosmetic industry in a science debate, for which medecine and academics have been wrong for decades.

          • Philippe Papadimitriou

            One more point, chemical reactions where a reagent is also the solvent are rarer. One mole of formaldehyde reacts with one mole of water to give one mole of MG. How many moles of solvent here? I believe the equilibrium is difficult to be pushed the other way. Particularly with this solvent. I am wrong?

  • Doug Schoon

    I also want to comment that the purposes of my post are to clarify the chemistry surrounding this issue. OSHA, the FDA and others will make determinations about the effects of exposure. However, to do so they must have the correct information and certainly must understand the chemistry involved.

    I spoke up about this issue because the chemistry has clearly been misunderstood for quite some time. New understandings about these substances have evolved and regulators should keep up with this new information and take advantage of new analytical techniques such as 13C-NMR. Instead, this information and techniques is being ignored (even shunned) because it shows the regulations are improper and not scientifically sound.
    Doug

  • Bobup21
    • Philippe Papadimitriou

      Interesting.

      I should mention Dr Wise’s question is linked to a whole different application: the academic one where formaldehyde is used as a fixative for microscopy and histology techniques. For this use, formaldehyde is even available as a gas in glass ampoules (to avoid the interference caused by the methanol portion in formalin).
      This has nothing to do with the cosmetic application in terms of exposure and system.

      If one want to enter fomaldehyde uses in academics, there are plenty (the safety conditions of such uses are well set):

      - Formaldehyde reversible crosslinking has been widely used in labs for the characterization of protein-protein and protein-DNA interactions in intact cells or tissues. I didn’t realize Chemsmith probably addressed this issue, but I now believe his (her) “proteins and DNA” mention was linked to this very different application.
      - Formaldehyde is also used for ChIP-microarray (or ChIP-chip – Chromatin ImmunoPrecipitation-chip), in transcriptomics experiments.
      - Formaldehyde-based solutions are used as a biological preserving solvent (formol).

      The systems in concern with these methodologies are not the same than hair and nails (the only fields in cosmetics where formaldehyde is still used to my knowledge and whose composition is mainly one type of protein (thus the “fixation” relatioship) – not as complex as in vivo skin) and the dosage is also very different, the method of application in the end also has poor correlation with nail and hair products.

      On the point of chemistry thought, it is of value here.

      For more info about Bobup21′s comment:
      http://publish.uwo.ca/~jkiernan/formglut.htm
      Have you seen the title of this reference in the bottom part (by the same author of the article itself): “A formaldehyde-glutaraldehyde fixative of HIGH osmolality for use in electron microscopy”? (Note ‘osmolality’ is roughly equal to ‘concentration’.)

  • Kelly Manning

    CH20 (formaldehyde) + H20 (water) => CH4O2 (Methylene Glycol)

    Plain English, Methylene Glycol is what you get when you dissolve Formaldehyde in water.

    • Philippe Papadimitriou

      Sorry, but it is not a dissolution, but a reaction (and you write it yourself). This chemical reaction is the best proof to show “methylene glycol and formaldehyde are not synonymous” (see Doug’s title).

      Then the chemistry and the toxicology behind are not the subject of Doug’s article. They are of course more important and the reason why being discussed so much in the comments.

      I am not in the favor of formaldehyde (definitely not and was more than horrified when I heard about the recent harm of it), but one should ban it according to relevant data, not panic or wrong exposure (in terms of nature or value). I think there are enough relevant data (what does not infer we should not study this topic more in depth), but do they really question the CIR decision on formaldehyde (0.2%)? I am not an expert to say so.

  • chemistturnedbiologist

    Okay… I’m so confused. What’s the point of this article? Just to point out that formaldehyde and methylene glycol have different structures and physical properties? I get that methodology sections in literature need to be clear on the exact chemical and exact percentages used in protocols but I feel like a lot of people who have re-posted this in my own social network are missing the point. A lot of people seem to be using this as proof that methylene glycol is an okay chemical to use in cosmetic products (debatable), rather than something that points out the difference between two distinct chemicals. It just seems a bit misleading. In my own lab (molecular bio/ cancer genetics) I use paraformaldehyde powder to make a 2% fixative for IHC and IF but we have methylene glycol sitting on the shelf as well – which was what our old post-doc preferred. I get the point on good chemistry, i.e. don’t lump different chemicals under one name. I just feel like we’re losing sight of the forest for all the trees.

  • Kelly Manning

    Mixing / dissolving reagents is the first step in most solution chemistry, isn’t it.

    Doesn’t that generate a mix of dissolved and reacted material depending on the relative concentrations of the initial mix?

    And what happens to “methylene glycol” is sprayed on hair and exposed to heat guns?

  • http://echo.planet.ee echo

    Hello! I read this article and just think that when formaldehyde is a gas, then yes, there may have been some errors about the list of ingredients and if this has been fixed now, good, and thankfully there was somebody like Doug who made something to make things clear in official terminology.

    I think Doug made just one little mistake which caused the big discussion below – he didn’t say anything about the real question in a consumer’s head – is Methylene Glycol a health risk or not. If that would’ve been mentioned then I suppose ChemSmith and chemistturnedbiologist wouldn’t have their reaction in the first place.

    I don’t know, why that obvious question was left out of the article. Maybe it deserved a special article? When I read the article “The Hair Smoothing Controversy” then I see that there is some information about health risks. So before starting sledgehammering here, that another article should be read as well.

  • Uinvent

    The point Dr. Schoon is making is that the HPLC test used to determine the amount of formaldehyde is wrong. In fact it can only use a scavenger chemical to pull formaldehyde from another compound and measure it. So, it is wrong to say that they are measuring a true value of formaldehyde when in fact they are breaking chemicals to form the formaldehyde as a new molecularly bound chemical in some scavenger. NMR tests, which show that the amount of formaldehyde relased into the atmosphere from these products is so little it does not endanger any one. Further, the NMR tests give a reading of formaldehyde without breaking a molecule that contains it. these OSHA tests show no danger in all these so called formaldehyde containing chemicals. I also want add that in a scientific opinion by THE SCIENTIFIC COMMITTEE ON COSMETIC PRODUCTS AND NON-FOOD PRODUCTS INTENDED FOR CONSUMERS, (SCCNFP/586/02, final),
    Adopted by the SCCNFP during the 22nd plenary meeting of 17 December 2002,
    “The EU working party (WP) on Methods of Chemical Analysis of Cosmetic Products has
    observed that certain formaldehyde releasers in aqueous/polar solvents release some or all of
    the formaldehyde they contain, and they do not remain as a single compound during testing. As
    these compounds did not remain intact during various analytical conditions employed, WP
    concluded that it may not be possible to develop method(s) of analysis of these compounds. That
    could be deemed viable indicators of the amount of aldehydes present in aqueous solutions. HPLC,
    CZE and NMR studies have shown that the test solution contains several entities and has not been
    established whether all molecules present in a test solution are decomposition products of the parent compound or the parent compound itself is a mixture of isomers. In any case, several of these molecules will contain formaldehyde. Decomposition of the primary solution due to instability of the formaldehyde bonds will indicate the presence of formaldehyde by decomposition.”

  • amy

    I am a hairdresser as well and hair performed several brazilian blowout treatments in a well ventilated salon and when heat was applied during the drying process and flat iron and i DID NOt over apply, i got tightness in chest and tingling in throat and now its the following day 24hours later and still feel not well.(almost like i have bad chest allergies) so if its the methylene glycol at 37% that the company claims why do i have these symptoms and the same question repeatly asked is WHAT internal HARM will and is this chemical doing to me? Maybe it doesn’t cause cancer must be doing something harmful if so many of the same complaints.

  • nrees

    I am a hairdresser not a chemist,so all of this discussion is way over my head.All i know isthat I have used 3 smoothing sysems and 1 vegan smoothing system and ALL of them give us headaches,sore throats,chest pain, burning eyes..We have good ventilation, and open air. 26 hairdressers in 1 salon….clients not receiving the service complain…. I do not care if formaldehyde is the same as an aldehyde or mythelene glycol(which i have learned they are different from these articles) With all these side effects how can it be safe? BB told me its like peeling an onion and your eyes water..my eyes and throat don’t hurt for hours after cutting a onion..Someone needs to be HONEST About what this is doing to us PLEASE. I would like to ban them.. but it is like crack to your hair..clients try it once and they are hooked..but at what expense?

    • Amygradystylist

      Have you tried Global Keratin? I am a salon owner and it is what we use. Not once have any of my stylist nor clients complained of any irritations, odors, or burning of any kind. In fact the love the smell of what I call strawberry yogurt. They enjoy great results lasting 3-5 months with proper use of shampoos. There are 3 differrent formulas to choose depending on your clients hair texture and what they want to accomplish. Hope it helps.

  • chemist

    Hello everybody!
    I’m sorry for i have not read all the comments, but I’m a Chenist and I have to say something…..
    Formaldehyde is a gas, but if you dissolve it in water or in a solution, as are almost all hair products, it partially react with water and become Methylene Glycol (or Methane diol etc.). It dosen’t mean that the solution does not contain Formaldehyde, because It has been put formadehyde in the solution, so if you remove water by heating or even only leave the product open to air, it will release formaldehyde. It’s just a solution equilibrium between different forms of the same substance, just like CO2 that in water becomes H2CO3 (carbonic acid) or just like glucose that in solution can be found in a linear form (with a molecule of water) or in a cyclic form (without a molecule of water), but it’s always called glucose! Glucose is always called glucose In both forms, so why to call in different ways Formaldehyde?
    I can understand that for common people my words can be very difficult to understand, but believe me when I say that if you dissolve Formaldehyde in water you will always have a part of Mehtylene Glycol in solution, so if you put formaldehyde in a product you will always have a part of Methylene glycol in the product.
    I have to be sincere, I don’t know if there are substances that can stabilize one of the two forms in solution (maybe an enzime or other catalyst). But I can assure that as water leaves the product the equilibrium in the solution changes and the form Formaldehyde appeares more and more.

    • chemist

      I’m sorry, the example of glucose it’s wrong, because it does not involve a molecule of water, but it’s a change of the position of a Hydrogen. It was just a lapse of confusion.
      But the concept remains.

    • Philippe Papadimitriou

      Hello Chemist,

      Yes, we are all aware of this. This story is moch longer than this (particularly today) and if you read the above comments, you will better understand the issue. There is far more to explain, but time is an issue here.

      You example os glucose, as you admit it yourself is wrong, but we get the idea. It was already given by this other example: CO2 in water. This is an excellent example and was also given above, but here’s the deal: CO2 has a different name than carbonic acid as well ! CO2 and carbonic acid are different substances, with different names and structures.
      You are right this is chemistry, but because it is chemistry, we can be sure Formaldehyde and Methylene glycol are not the same substance (there is a water molecule/mole reacting).

      Oregon OSHA told the public these substances are “synonymous” (probably meaning one and the same). Doug’s post was only written to correct this wrong conclusion. But he, and many more involved here, knows about the chemistry.

      Thank you!

      • Philippe Papadimitriou

        Sorry I meant the “below” comments (the CO2 example was also given “below”).
        My apologies.

  • Michael

    Well, well. If formaldehyde reacts with proteins, then, what is the problem? There will be none left to react with anything as shown by OSHA results. OSHA and other bodies have found none in the use of products such as Keratin Complex. In fact they found 7 times below the accepted levels. Methylene glycol is certainly not formaldehyde. It can generate formaldehyde by the reaction is thermodynamically in favor of methylene glycol. When water is reoved IN THE ABSCENCE OF PROTEINS, the formaldehyde will be released. Fortunately, Keratin Complex carries an excess of keratin proteins that react with any released formaldehyde gases to immediately form thiazolidines (conditioners). If no formaldehyde gas is found upon tests of ironing hair by OSHA and others, why is there so much fuss about it? Please be real. It is important that we realize that the discussion is not just about raw methylene glycol, but about a system of chemicals designed to dance and cordinate their reactions in a safe and appropriate manner. I can put all the formaldehyde I want into a solution, if the end result is harmless. In fact nature does that all day long in your body. A lot of everyday products we use have formaldehyde as an ingredient. So long as the bound reactions do not release formaldehyde upon use, what is fuss about?? Fomaldehyde through skin?? Give me a break. In air, 0.25ppm already make you teary eyed.
    When methylene glycol is heated, formaldehyde is released, but in the presence of proteins (cysteine), it vanishes immedietly and becomes a harmeless and even beneficial thiazolidine closed ring molecule. Please start thinking in context. Ask the question: Under what conditions are the reactions taking place? To tell lay people that formaldehyde is released when methylene glycol is heated is misleading, since there are other chemicals in solution that are deliberately designed to react with formaldehyde to form other benign things that people want.

    • Day4dreams

      There is “so much fuss” because people are getting ill from using these products — lots of people.  It’s not like people went looking to find something wrong with these hair straightening products; it was a case of person after person feeling ill and having side effects and that led to looking into what might be causing the illness.  Your “give me a break” tone is EXACTLY why consumers are se easily led to believe that the cosmetics industry does not really care about whether products make them sick or not.  It is just this type of dismissive attitude that is what leads to over-reacting efforts at legislation such as the Safe Cosmetic Act. Maybe you can sit in a salon all day and be exposed to the odors and never become ill…good for you.  My father smoked from the time he was 11 years old until he died in his 80′s and I don’t even remember the man having a cold much less any lung disease — does that mean cigarettes don’t contribute to cancer and other health issues?  Of course not.  You can explain and explain what can’t be happening and maybe the explainations others are giving are not exactly what is happening scientifically or chemically — but peopler are being made ill and injured by these products and that is a fact. 

  • Concerned reader

    Hopefully you are staying up with science-based findings, such as recent reports by federal OSHA of airborne exposures of formaldehyde above OSHA’s permissible exposure limit, and many salon air measurements exceeding the American Conference of Governmental Industrial Hygienists Threshold Limit Value. Perhaps you can also acknowledge that at least one brand of this product has been tested among a number of agencies world-wide as being somewhere between 8-9% formaldehyde – yes in liquid form which most of the world calls formaldehyde (which is basically the same as embalming fluid) but you can call methylene glycol if you prefer. Please share for the sake of those stylists who post on here symptoms related to formaldehyde exposure during the use of some of these products you can share the most recent alert shared by Federal OSHA at:http://www.osha.gov/SLTC/formaldehyde/hazard_alert.html and this from the State of Minnesota Department of Public Health: http://www.health.state.mn.us/news/pressrel/2011/hair042011.html.

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  • Doug Schoon

    Hi,

    I don’t think this is the same situation as CO2 in soda; in
    fact that’s what’s causing the confusion. CO2 is forced into solution and wants
    to escape as quickly as possible. That’s quite different and in the case of
    formaldehyde gas, the exact opposite occurs.

    CO2 is stable while formaldehyde gas is NOT.  The gas wants to become methylene glycol or to
    form a polymer, which is its most stable form. 
    This is why formaldehyde does not build up in the environment. It’s so
    reactive that it quickly eliminates itself to create a more stable species,
    e.g.  methylene glycol.   Moisture is always present and drives the
    formation of methylene glycol.  Unless
    you live in a water vapor free environment (no one does), formaldehyde can’t
    exist for very long.  Hair is NEVER really
    “dry” (except to touch). Even when it appears to be dry, it contains
    a large percentage of moisture as does the air we breathe. Moisture destroys formaldehyde
    in nanoseconds.

    Do I think there is an issue in salons and the potential for
    harm?  Yes, but the issue is “sensory
    irritation” which should NOT be occurring.  Salons that don’t properly ventilate can cause
    exposure at levels that lead to sensory irritation. If a salon doesn’t have the
    correct ventilation needed to eliminate sensory irritation, why are they performing
    such services?  Sensory irritation can occur
    with many different services, including perms. Salon’s need to pay MUCH more
    attention to ventilation. That’s the problem that is being overlooked here. Salons
    need to step up to the plate and get more serious about using appropriate ventilation
    for the services they provide. This isn’t option, it’s the law and it makes good sense!

  • Doug Schoon

    Hi Concerned,

    Yes, I have been watching. Salon’s seem to be well below the
    OSHA Action limit, but some are exceeding the more conservative levels set by
    the ACGIH, which is  0.1 ppm 8 hour TWA. The
    OSHA levels are designed to protect against long term health issues, which the
    lower ACGIH value protects against short term sensory irritation. Both are
    important!

     Salon’s that don’t exceed
    the ACGIH levels also don’t have problems with sensory irritation like salons
    that do. That’s why I believe that inadequate ventilation is such an important issue.
    I’ve been trying for more than 20 years to convince salons that they need
    appropriate ventilation. Clearly, this is a big problem and it’s time that this
    issue is addressed.  No matter what
    services a salon provides, it MUST have ventilation that is appropriate for the
    services performed in that salon.

  • Elizabeth Ellis

    As a cosmetology student, it is safe to say that my knowledge of
    chemistry can be considered…negligible.  I’ve read every article and
    comment I could find on this topic, but this is still bothering me: 

    If formaldehyde is (1) a gas and (2) causes cancer in test animals, then
    how are the animals being exposed to the gas?  If water vapor is always
    present (even in a lab) and formaldehyde is instantly drawn to each
    molecule of water to form potentially harmless methylene glycol, then is
    it wrong to think that the animals are actually being exposed to
    methylene glycol?  Or are there not enough pieces of H2O floating around to meet up with all of the H2CO’s?

    Another part of this that isn’t making any sense is that if methylene
    glycol (through heat or evaporation or whatever) converts back water and
    formaldehyde, it’s okay because if any proteins are present, it will form conditioners instead of a carcinogenic gas?  What is going on?  Animals contain a decent amount of protein, from what I understand. 
    So.. formaldehyde causes cancer in animals, unless you add water.. then
    if you remove the water and formaldehyde is released again, it’s okay, because this time that same thing, instead of causing cancer, will just condition my hair?  Why did this process not save the animals from cancer in the first place?  

    Try not to waste your degrees pointing out my lack of knowledge/gross
    misuse of terminology on the topic.  I am painfully aware.  My question
    is, how were test animals exposed to a gas that naturally changes into
    something different when released?

    • Doug_Schoon

      Hi Elizabeth,Formaldehyde “may” cause cancer if the exposures are high enough and continue for long enough.Regulatory guidelines have been established to prevent this type of excessive exposure and no one should exceed these guidelines.

      Some have suggested that any/all exposure to formaldehyde dangers, but that can’t be true or we would have to stay away from our children and friends. Everyone breathes out a tiny amount of formaldehyde gas with each breath, it’s normal to do so. So clearly there is a safe level that does not cause adverse health effects. When the IARC says that formaldehyde is a carcinogen, they are only talking about the anhydrous gas.  This gas is experimentally created in small chambers and the animals are exposed to very high concentrations for long periods of time and not at all typical of what you would find in the salon.

  • Atomicfad

    I have an honest question to ask. So the mono-hydrated formaldehyde is considered methylene glycol. But, isn’t formaldehyde water soluble? So, what’s the different between Formalin (formaldehyde solution) and Methylene glycol?

    • Doug_Schoon

      No, it is not water soluble. That’s the misunderstanding that causes all these problems. Formaldehyde is a highly reactive gas that is not stable in water or in the presence of moisture. It reacts in nanoseconds to become methylene glycol. The differences between these are explained in the article.

  • Dave Kalman

    I think this debate is bogus, when it comes to health effects.  What happens when formaldehyde (gas) encounters a biological membrane (your eyes, your lung tissues, etc)?   It immediately becomes hydrated and is technically in the “methylene glycol” form.  This is rapid and reversible. 

    So, all of the health effects data and biological testing of formaldehyde actually reflect the presence of “methylene glycol”, not the “free formaldehyde” form.  Therefore, there is no reason to suppose that the health effects of a given dose of “methylene glycol” are different from the molar equivalent dose of “formaldehyde”.

    The chemical nit-picking is simply an attempt to circumvent appropriate regulation.

    • Dschoon

      Hi Dave,Thanks for your comment and I understand your concern.  I don’t agree about this and being chemical nit-picking. This is a huge international issue.  Because the chemical facts have not properly recognized, regulations, standards, testing and even medical research are based on misinformation and misunderstandings. There’s a great deal of confusion in the scientific and medical literature because of this.

       It doesn’t help that dozens of completely differences substances are all referred to as “formaldehyde”. Government regulators should recognize the correct chemistry and go from there to establish proper standards. Also, formaldehyde testing should correctly reports results, which is not happening today.

      Regulation should be based on the proper chemistry and valid testing, as should the toxicology and safety standards. These aren’t nit-picky issues.Doug

  • Lorinstylist

    Aside from the facts you listed, which are true, you are neglecting to account for the fact that “methalyne glycol” when heated with the hair dryer and the flat iron, produces formaldehyde gas.  I guess that’s one part of chemistry you are just simply ignoring.  I have had headaches, nosebleeds and eye irritations ever since I began using the cadiveu Brazilian treatment and these products claim to have .02% formaldehyde and it’s just a big lie.  When you are assessing the risks with this type of procedure, what OSHA and Oregon is doing that you are not, is looking at what becomes of the methylene glycol when it’s heated.  Why don’t you come to my salon and perform a Brazilian Blowout on someone without a mask and see how it works for you!  Get a Clue!

    • Dene Godfrey

      As you have received no other response, I will offer my 2 cents and simply point out that the article is discussing the FACT that OSHA are stating that methylene glycol is a synonym for formaldehyde, and that this statement that is entirely wrong as they are demonstrably two different molecules. What happens in your salon has no relevance to the article, as methylene glycol and formaldehdye are still two different substances, irrespective of the fact that heating methylene glycol produces formaldehyde (a fact which actually demonstrates the truth of Doug’s claim!). Try reading the article again, and you may understand that you’d misinterpreted the message. There is no intention to look beyond that basic claim of a factual error, and no intention of offering any sort of risk assessment. That would be a subject for a seperate article!
      If you are suffering from using this treatment, you should either improve the ventilation in your salon, or stop using it – it is unacceptable to suffer such effects, but this doesn’t change the fact that Doug’s article is absolutely correct.

  • mike

    Measurements of aqueous solutions containing methylene glycol do not give a true picture of formaldehyde content. Methylene glycol (MG) is from the same family as ethylene glycol. When HPLC and other methods are used to measure formaldehyde, they scavenge formaldehyde from Methylene glycol in a run-away reaction. The more they scavenge, the more MG decomposes to equilibrate with formaldehyde. Eventually they completely decompose the Mg and say that its is formaldehyde. If left alone, MG will be stable and un-reactive. It is the scavenging of formaldehyde that causes it to decompose.
    In fact the same mechanism occurs when hair reactions occur with formaldehyde. If a biological sample or keratin (cysteine) is placed in MG, it will react not with the MG but will react with the equilibrium formaldehyde gas. The MG then decomposes further to re-establish and equilibrate with formaldehyde again. The formaldehyde quickly reacts again. So, in essence, no formaldehyde is released outside such a system, as long as there is enough cysteine to form thiazolidines. You can imagine that the money (Formaldehyde) that changes hands is never seen laying around, it is always in something it is bonded to. It is like your soda pop carbonation when you release the pressure and re-closes the lid. The CO2 wants to equilibrate with its solution contents. The 0.04% must be maintained and so test actually keep decomposing MG until they completely decompose it to its full extent. In fact the test do not actually measure formaldehyde, they measure safe MG and call it formaldehyde. If you have a married couple Formaldehyde and water, they form a child called MG that is different from either. We cannot say that the child of all reactions are the same as the parents. For example water is a child of oxygen and hydrogen. We cannot measure water content and say that Hydrogen is present. Otherwise OSHA will have to regulate every drop of water with the same rules it uses to regulate Hydrogen
    .