The Toxicities of Laundry Products in the Home: A Review and Commentary on Environmental Oncology

Abstract

This review of the aggregated data to date finds the overwhelming weight of the evidence supports the contention that many laundry products, via contained ingredients and byproducts such as phthalates, plasticizers, bisphenols, polybrominated diphenyl ethers (PBDEs), polycyclic aromatic hydrocarbons (PAHs), phenols, per-and polyfluoroalkyl substances (PFAS) known as "forever chemicals", and the contaminant 1,4-dioxane, add significant elevated risk to humans in the reproductive/fertility; respiratory/pulmonary (asthma, cardiopulmonary disease); neurological/cognitive (ADHD, autism); metabolic (diabetes, obesity); and oncogenic (cancer) domains of human health. We focus discussion on the toxicity of these laundry products, the subject of much research and regulatory scrutiny, in order to provide a new understanding of the current state-of-the-art in environmental oncology as it concerns these toxins. We also provide a summary of existing and emerging legislation to regulate and thereby limit the potential multifaceted harms of these products. Concerns have been sufficiently serious and well evidenced that most of these toxic chemicals have been banned in the EU and dozens of nations, with pending prohibitions in over a dozen states in the U.S., and with major retailers now pledging for their elimination from cosmetics, personal care and household products in the near future. But as both a corrective, and a motivation, we also document some of the regulatory resistance and inertia that regrettably impedes more aggressive action.

Full text

World Journal of Clinical Cancer Research (ISSN 2831-3275)
The Toxicities of Laundry Products in the Home:
A Review and Commentary on Environmental
Oncology
Constantine Kaniklidis*
Director, Medical Research, No Surrender Breast Cancer
Foundation (NSBCF)
Corresponding author
Constantine Kaniklidis*
Director, Medical Research, No Surrender Breast Cancer
Foundation (NSBCF): Locust Valley, New York, US
Email: edge@evidencewatch.com
Received Date: July 04 2022
Accepted Date: July 05 2022
Published Date: August 04 2022
Abstract
This review of the aggregated data to date nds the
overwhelming weight of the evidence supports the contention
that many laundry products, via contained ingredients and
byproducts such as phthalates, plasticizers, bisphenols,
polybrominated diphenyl ethers (PBDEs), polycyclic aromatic
hydrocarbons (PAHs), phenols, per-and polyuoroalkyl
substances (PFAS) known as “forever chemicals”, and the
contaminant 1,4-dioxane, add signicant elevated risk to
humans in the reproductive/fertility; respiratory/pulmonary
(asthma, cardiopulmonary disease); neurological/cognitive
(ADHD, autism); metabolic (diabetes, obesity); and oncogenic
(cancer) domains of human health. We focus discussion
on the toxicity of these laundry products, the subject of
much research and regulatory scrutiny, in order to provide
a new understanding of the current state-of-the-art in
environmental oncology as it concerns these toxins. We also
provide a summary of existing and emerging legislation to
regulate and thereby limit the potential multifaceted harms
of these products. Concerns have been suciently serious
and well evidenced that most of these toxic chemicals have
been banned in the EU and dozens of nations, with pending
prohibitions in over a dozen states in the U.S., and with major
retailers now pledging for their elimination from cosmetics,
personal care and household products in the near future.
But as both a corrective, and a motivation, we also document
some of the regulatory resistance and inertia that regrettably
impedes more aggressive action.
Overview of the Dangers: Our review of the aggregated
data to date nds the weight of the evidence demonstrating
that among household, personal care, and cosmetic products,
fragranced laundry products and dryer sheets in particular,
add signicant risk to humans in various domains, especially
(1) reproductive/fertility, stemming largely from endocrine
disrupting chemical (EDC) components like phthalates,
bisphenols, and parabens that can dysregulate estrogen
pathways, and can also serve as “pubertal inuencers”,
advancing to younger years the age of puberty; (2) respiratory/
pulmonary, in particular asthma and cardiopulmonary
diseases; (3) neurological/cognitive, in terms of components
that can exert neurotoxic activity, with adverse impact on
ADHD and autism, among others; (4) metabolic disease,
especially diabetes and obesity, with components said to be
obesogenic; (5) and oncologic, via increased risk of endocrine-
related cancers, especially breast, prostate, and colorectal
cancers, as well other malignancies.
Numerous extensive investigations and aggregated scientic
safety and toxicity studies have concluded that common
products used in the laundry process contain complex
mixtures of endocrine-disrupting compounds (EDCs) and
asthma-related compounds [Dodson 2012]. Endocrine
disrupting compounds (EDCs) are agents that can alter
hormonal signaling and the expected normal functioning
of the endocrine system in both humans and animals via
mimicking estrogen, and have potential eects on developing
reproductive and nervous systems, metabolism, and cancer
development and outcome, and can also be associated with
adverse developmental eects and in humans [Colborn 1993]
[Parlett 2013] [Jurewicz 2011] [Chen 2014] [Ventrice 2014] [Lee
2022]. The most common EDCs are dioxins, polychlorinated
biphenyls (PCBs), bisphenol A (BPA), peruoroalkyl and
polyuoroalkyl substances (PFAS), and parabens. These
are found in detergents including plasticizers, commonly
phthalates, used in these laundry detergents to increase the
separation of particles to prevent clumping and improve a
material’s plasticity or uidity, and in plastics, children’s toys,
foods, cosmetics, and some pharmaceuticals [NIEHS].
The implications in the oncology setting alone are extensive.
Consider that systematic review and meta-analysis has
concluded that exposure to these EDCs is strongly linked to
dysregulated inammatory responses, via their association
with circulating levels of inammatory markers like C-reactive
protein (CRP) and interleukin (IL)-6, among others [Liu
2022] [Danforth 2021]. In turn, research from University of
Pennsylvania researchers from their nested case-control study
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that drew cases and controls from the WABC-II (Wellness After
Breast Cancer-II Cohort) prospective cohort study provides
plausible evidence that levels of serum inammatory protein
CRP is independently associated with an increased breast
cancer relapse risk in hormone-positive / HER2-negative
(HR+/HER2-) breast cancer in the adjuvant setting [McAndrew
2021], and there is further systematic review and meta-
analytic evidence that high serum CRP in metastatic breast
cancer patients is an indicator of poor prognosis [Mikkelsen
2022], these associations are being validated across multiple
malignancy types. At the genome level, we have the ndings of
the WHI dbGaP (Women’s Health Initiative Database for
Genotypes and Phenotypes) Study, a genome-wide association
study (GWAS) [Jung 2021a] and the rst study characterizing
genetic determinants of inammatory cytokines, especially
CRP and IL-6, and the genomic associations of these
inammatory markers with breast cancer development, and
the same researchers documented the potential causal
relationship between genetically elevated CRP concentrations
and postmenopausal invasive breast cancer, under inuence
of particular lifestyle factors and breast cancer subtypes, using
a Mendelian randomization approach [Jung 2021b].
There are
similar ndings for the association between IL-6 and CRP in
other malignancies like colorectal cancer (CRC) [Ose 2022] [An
2022] [Hidayat 2021], and the oncogenic eect of EDCs extends
to endometriosis [Wieczorek 2022], and prostate cancer [Bleak
2021] [Corti 2022] [Lacouture 2022], among still other
malignancy types [Michels 2021].
Phthalates, also being endocrine disruptors, are used in
fragrances, home and personal care products, and laundry
products, and because they are semi-volatile, they are found in
indoor air and dust, with exposure to humans via inhalation,
ingestion, and skin absorption. In addition, note that
phthalates – like DEP (diethyl phthalate) - are often added to
fragrance to make the scent linger, so are extremely common
in all scented products including dryer sheets and softeners.
These phthalates (Phth), known endocrine- disruptors, may
play a role in breast carcinogenesis. Low- molecular-weight
phthalates (LMWPhth) are commonly found in personal care
products while high MWPhth (HMWPhth) are used primarily as
plasticizers. The weight of the scientic evidence nds that
phthalates are associated with asthma and wheezing in
children [Bornehag 2010] [Kumar 1995] [Parks 2020], among
other harms (see below), as are other common laundry agents.
The specic epidemiology of one of these, asthma-related
QACs (quaternary ammonium compounds, aka “quats”) has
been documented extensively by the Mount Sinai Seliko
Centers for Occupational Health (SSCOH) in collaboration with
the Bellevue/NYU Occupational & Environmental Medicine
Clinic (BNOEMC) [SSCOH/BNOEMC 2016].
This has led to numerous calls by environmental scientists for
the total prohibition of such agents from all consumer
products. Consider Project TENDR (Targeting Environmental
Neuro-Development Risks) [http://projecttendr.com/], led by
Dr. Russ Hauser, Professor of Reproductive Physiology and
Professor of Environmental and Occupational Epidemiology
at Harvard T.H. Chan School of Public Health, which recently
issued, along with experts in toxic chemicals and
neurodevelopment, a National Call to Action (“Why phthalates
should be restricted or banned from consumer products”
[Hauser 2021]), supported by the National Institute of
Environmental Health Sciences NIEHS) National Toxicology
Program (NTP); the Center for Environmental Research and
Children’s Health (CERCH); the American Academy of
Pediatrics Environmental Health Council; the Environmental
Defense Fund (EDF); the Collaborative on Health and the
Environment (CHE); the National Medical Association
Commission on Environmental Health; the Science and
Environmental Health Network (SEHN); the Natural Resources
Defense Council (NRDC); and the Children’s Environmental
Health Network (CEHN), among dozens of others across the
nation. (See our summary of legislation below).
Collectively,
on the neurological front alone, there is overwhelming
scientic evidence linking these toxic environmental
chemicals to neurodevelopmental disorders that can impair
brain development and increase risks for learning, attention,
and behavioral disorders in childhood, including autism
spectrum disorder (ASD), attention decits, hyperactivity,
intellectual disability and learning disorders [Engel 2021] with
bisphenols similarly associated with cognitive decits and
attention-decit disorder in children following prenatal
exposure [Kahn 2020].
Hazards in the Laundry: The labeling terms “natural,” “non-
toxic,” and “green” are unregulated and require no standard-
ized ingredient information. Indeed, a recent study [Steine-
mann 2011] found that the volatile organic compound (VOC)
composition of “green”-labeled fragranced products was not
signicantly dierent from that of other fragranced prod-ucts
with regard to number of hazardous chemicals as de-ned
under U.S. federal laws [Potera 2011].
Testing by the
Environmental Working Group (EWG) has also revealed that
75% of the fragrances contain phthalates, linked to diabetes,
obesity and hormone (endocrine) disruption which aects
both development and fertility, and the Mt. Sinai Children’s
Environmental Health Center (CEHC) has linked early prenatal
exposure to synthetic fragrance that includes endocrine
disruptors (as with dryer sheets), both to ADHD and autism
[Landrigan 2012] [Mount Sinai 2012] [Bagasra 2013].
Recognizing that household dust is a vast repository of con-
sumer product chemicals and pollutants, researchers at UC
Davis conducted a large study of these potentially hazardous
agents in California house dust [Shin 2020], including semi-
volatile organic compounds (SVOCs) for which household
dust is a reservoir, nding that in the 119 newly detected
compounds, 13 had endocrine-disrupting potential, while an-
other 7 had neurotoxic potential.
These included phthalates;
plasticizers; phenols and bisphenols; PBDEs (polybrominat-
ed diphenyl ethers); OP-FRs (organophosphate ame retar-

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dants); PAHs (polycyclic aromatic hydrocarbons); and PFAS.
One large analysis investigated 1135 chemicals in cleaning
products and 886 in laundry products with potential repro-
ductive and estrogen-receptor mediated (ER-mediated) tox-
icities using the European Union CLP (Classication, Labeling
and Packaging) classication and the EPA’s ToxCast database,
identifying 53 with potential reproductive toxicity and 310
with potential ER-mediated toxicity [Lee 2021], suggesting ex-
tensive potential EDC exposure from laundry detergents and
household cleaners. Given the high level of hazards stem-
ming from toxins and contaminants in laundry products, the
environmental education group, the Hitchcock Center, has
called them “wearable air pollution” [Dover 2012], supporting
seminal studies on dryer air vent emissions [Goodman 2019]
[Steinmann 2013]. In addition, scented laundry product emis-
sions emanating from dryer vents during the normal process
of clothes washing, in the home and in commercial locations,
are categorized as an “exposure context” for adverse conse-
quences on human health [Steinemann 2021], and motivate
fragrance-free policies in indoor environments, workplaces,
schools, health care facilities, and public buildings [Steine-
maan 2019a], justied in part by the fact that on an average
32.2% of the general population the United States, Australia,
the United Kingdom, and Sweden report adverse health ef-
fects when exposed to fragranced products, higher in asth-
matic (57.8%) and in autism spectrum disorders/ASD (75.8%),
populations [Steinemann 2019b].
PFAS in the Laundry - and in Us - Forever
This latter group of chemicals, the PFAS (per- and polyuoro-
alkyl substances) represents a class of thousands of chemi-
cals used in cosmetics, laundry products, household cleaning
products, cookware and food packaging, carpeting, outdoor
attire, reghting foams and in almost innumerable industrial
processes, before been discharged into our waterways and
which are linked to cancer promotion, hormone disruption,
immune suppression, and adverse reproductive functioning.
Because of the fact that they are highly resistant to breaking
down in the environment and so may be with us forever, they
are commonly called “forever chemicals”, and can be found in
the blood, breast milk, and a newborn baby’s umbilical cord
blood [Peruorochemicals CDC 2017]. And contrary to con-
stant reassurance by the chemical industry that current use of
PFAS does not build up in humans, recent evidence decisive-
ly shows the opposite. In a recent study [Zheng 2021] these
toxic PFAS chemicals were found in 100% of breast milk sam-
ples in mothers tested in the United States, exposing nursing
infants to signicant harms, including the later development
of immune dysfunction, dyslipidemia, pregnancy-induced hy-
pertension, damage to the liver, elevated risk of thyroid dis-
ease, reduced fertility, and various cancers [Rappazo 2017]
[Sunderland 2019]. And it is demonstrated that current-use
short-chain PFAS have been increasing worldwide, doubling
about every 4 years [Zheng 2021]. Finally, there’s is mounting
evidence that PFAS exposure may exert immunotoxic activ-
ity, compromising the eective antibody immune response,
especially critical in vulnerable populations, including infants
and children, requiring COVID-19 vaccination [Quinete 2021]
[Catelan 2021] [Grandjean 2017]. At this time, both extensive
research eorts, and regulatory activity in PFAS identica-
tion, toxicity, pervasiveness, remediation and mitigation are
ongoing and accelerating across the globe, and there is now
widespread recognition of PFAS being a critical health hazard
facing the modern world [Panieri 2022] [Newell 2022] [Anto-
niou 2022] [Brennan 2021] [Bell 2021]; see below for more.
The Fragrance-Free Myth
Note that although many of these products may be labeled as
‘fragrance-free’ they may still contain fragrance compounds
if those are used not for scent per se, but rather as preser-
vatives or xatives. In a seminal study of eective volatile
organic compound (VOC)-reduction strategies [Goodman
2019], researchers conducted a comprehensive investigation
of emissions from dryer vents during use of fragranced ver-
sus fragrance-free laundry products, showing that the sim-
ple strategy of changing from fragranced to fragrance-free
products can be an eective approach to reducing ambient
air pollution and potential health risks. Thus, in households
using fragranced laundry detergents, the highest concentra-
tion of d-limonene (a common fragrance agent found in laun-
dry products like dryer sheets and detergents) from a dryer
vent was 118 μg/m3, compared to just 0.26 μg/m3 in house-
holds using only fragrance-free laundry products, and after
households using fragranced detergent switched to using
fragrance-free detergent, the concentrations of d-limonene
in dryer vent emissions were reduced by up to 99.7%. D-lim-
onene is associated with multiple adverse eects, including
breathing diculties manifested in wheezing or coughing
[NICNAS 2002], and can react with ozone to generate haz-
ardous air pollutants which include formaldehyde, acetal-
dehyde, and ultrane particles, known respiratory irritants
and carcinogens [Nazaro 2004]. As one extensive review
noted, “these fragrance compounds are wolves in sheep’s
clothing”, referring to constituents of phthalates, parabens,
and essential oils, among others, found in household clean-
ing/fragrant agents including laundry detergents, given their
long-term health perils secondary to their ability to dysreg-
ulate hormonal signaling systems [Patel 2017]. In addition,
laundry detergents, laundry drying sheets, fabric softeners
are evidenced to contain and constitute articial fragrances
that are both “optional and hazardous commodities” [Patel
2021]. Moreover, researchers investigating the specic haz-
ard of neurotoxicity of these fragrance products have found
that of a vast array of commercial products, these laundry
product toxins contained the highest number and concentra-
tion of endocrine disruptors (and of asthma-triggering com-
pounds) [Pinkas 2017]. In the U.S. 12.5% of adults reported
adverse health eects (asthma attacks, migraine headaches)
from the fragrance of laundry products emitting from a dryer
vent, with 28.9% of adults with diagnosed asthma or an asth-
ma-like condition reporting adverse health eects from these
dryer-vent fragrances [Steinemann 2018; 2018c]. It has been

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noted that the pathologies triggered by endocrine disrupting
compounds (EDCs) include neuropathies like depression and
autism; malignant disease like breast cancer and prostate
cancer; endocrinopathies like gynecomastia; organ damage
like hepatotoxicity, among many others [Patel 2017]. On a
positive note, as we noted above it has been demonstrated
that switching from fragranced to fragrance-free laundry
products allows dryer vent emissions of a leading contami-
nant and environmental pollutant, limonene, to be reduced up
to 99.7% [Goodman 2021].
The Cancer Connection: In addition, there are “secondary
hazard” eects: limonene and other volatile aromatic terpenes
(pine, citrus oils, essential oils) react with ozone present in the
surrounding air to generate secondary pollutants that include
formaldehyde (probable human carcinogen), acetaldehyde
(probable human carcinogen), acetone (respiratory /
pulmonary irritant), and ultra-ne particles known as PM0.1,
particles classied by the International Agency for Research on
Cancer (IARC) and the US National Toxicology Program (NTP)
as Group 1 human carcinogens, associated with lung cancer
and as well as cardiopulmonary disease) [ACS]).
Another class
of agents commonly used in dryer sheets is nonylphenol
ethoxylates (or NPEs), a mix of petrochemical cleaning agents
also used in many laundry detergents as surfactants, lowering
the surface tension of water to allow for a deeper cleaning and
penetration. And it is known that certain agents like
dichlorobenzene can not only induce short-term irritation of
the skin, throat and eyes, but have chronic, long-term eects
on the liver, skin, and central nervous system (CNS), which has
led the United States Environmental Protection Agency (EPA)
to warn of it being suspected to cause human cancer,
therefore classifying it as a possible human carcinogen [EPA
1999.].
But despite being completely banned in Canada and
the EU, these agents are still found in laundry products in the
U.S.
The connection of these agents to breast cancer has been
particularly well researched and documented. Most
alarmingly, new human clinical evidence from the Multiethnic
Cohort Study of 798 women presented June (2020) shows that
phthalate exposure – and also parabens [BCPP Parabens] and
other EDCs – is associated with increased risk of invasive
breast cancer [Wu 2020], and may be higher risk still in
subgroups of women with greater genetic susceptibility such
as women with BRCA-mutations, as shown in a systematic
review of 56 studies [Zeinomar 2020], cross-validating other
critical studies [Terry 2019] [Ahern 2019].
A widely used class
of phthalates, known as high molecular weight phthalates
(HMWPhth) are used primarily as plasticizers found in a broad
swatch of products from personal care to laundry products
including dryer sheets, but in the notoriously underregulated
U.S. markets, producers are not required by the FDA to list all
ingredients in a product, only so-called “active ingredients”,
and numerous individual chemicals in cosmetics like
phthalates in fragrances are not required to be labeled,
and so represent a hidden danger to the consumer [BCPP
Phthalates]. This is in contrast to the EU where full-disclosure is
required, and endocrine disruptors like phthalates and
parabens have already been prohibited since 2005.
We also have several epidemiological studies linking endocrine
disrupting compound (EDC) exposure with breast cancer risk,
and still more importantly, with poor prognosis, which include
the case-control study nding increased risk of breast cancer in
North Mexico states among women exposed to diethyl
phthalate [Lopez-Carrillo 2010], in agreement with the reviews
from The Silent Spring Institute [Rodgers 2018], and the
“Coimbra” Review [Encarnação 2019]. This wide spectrum and
penetration of adverse eects of endocrine disrupting
compound (EDC) was acknowledged by The Endocrine Society
as early as 2009 in their Scientic Statement on EDCs
addressing the concerns to public health based on evidence of
the eects of EDCs on male [Radke 2018] and female
reproduction, breast development, prostate and breast
cancer, neuroendocrinology, thyroid, metabolism and obesity,
and cardiovascular endocrinology [Diamanti-Kandarakis
2009], and multiple studies document that the well-known
hallmarks of cancer can develop at concentrations within the
range of those measured in human breast tissues [Darbre
2021]. In addition, EDCs can function as pubertal inuencers,
accelerating the processing of maturation of secondary sexual
characteristics [Lucaccioni 2020], with recent studies
accumulating evidence of exposure to EDCs during puberty
predisposing to breast cancer later in life, and aecting a
woman’s reproductive potential and ovarian reserve, and may
inuence outcome in assisted reproductive technology (ART),
while elevating risk of the development of breast cancer at any
age [Karwacka 2019] [Yilmaz 2020] [Giulivo 2017] [Morgan
2017], with certain EDCs in the paraben class of environmental
phenols associated with 30–50% higher odds of breast cancer
development and inversely associated with all-cause mortality
[Parada 2019]. Indeed, using data from the National Health
and Nutrition Examination Survey (NHANES) prospectively
linked to National Center for Health Statistics (NCHS) mortality
data, women in the United States were found to be at greater
mortality risk in association with exposure to certain (ethyl,
methyl, butyl), and total, parabens [Hendryx 2022].
In this connection, Breast Cancer Prevention Partners (BCPP)
released a landmark report in 2018 — Right to Know: Exposing
Toxic Fragrance Chemicals in Beauty, Personal Care and
Cleaning Products [BCPP Right to Know]. The report exposes
the presence of harmful fragrance chemicals linked to cancer,
hormone disruption, reproductive harm, and respiratory
toxicity, not appearing on the label, especially unregulated
toxic fragrance chemicals, all tested by BCPP using
state-of-the-art laboratory testing via two-dimensional gas
chromatography (GCxGC) Time-of-Flight (TOF) analysis.
Fragrance chemicals made up three-quarters of the toxic
chemicals in the beauty, personal care and cleaning /

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household products tested, with one in four of the total 338
fragrance chemicals detected linked to serious chronic health
eects, as documented in their Red List of Chemicals of
Concern as part of their Campaign for Safe Cosmetics [BCPP
Red List]. The list included 102 chemicals found in personal
care products that pose serious chronic health concerns
including cancer, hormone disruption, and reproductive and
developmental harm, and also now includes chemicals used
in cleaning products and in fragrance (including dryer sheet),
cross-conrmed by authoritative scientic bodies.
Intersecting with their oncological impact, a recent review of
the evidence has found an “obesogenic” impact from EDCs
including bisphenols, phthalates, biphenyls, and parabens,
all common in laundry products including dryer sheets and
laundry softeners, in that early life exposure to EDCs may
impose an increased risk of obesity in later life [Yang 2018]
[Mallhi 2011] and the eect of such exposure has further
been found to correlate with increased body weight and/
or body mass index during all life stages [Legeay 2017]
[Liu 2019] [Liu 2017], among many other hazards including
neurotoxicity, reproductive toxicity, cytotoxicity, genotoxicity,
and carcinogenicity associated with the notorious bisphenol
A (BPA) [Xing 2022].
Legislation, Regulation and Voluntary Restrictions
Based on the robust aggregated evidence of multiple harms,
including the fact that in California, 1.6 tons of volatile organic
compounds or VOCs are emitted daily from fragranced
cosmetics and personal care products alone [BCPP Legislation
2020], vastly more if we add cleaning and laundry products,
California now bans 24 endocrine disrupting compounds
including phthalates and parabens linked to breast cancer,
as of the signing into law by Gov. Gavin Newsom of the
landmark Toxic-Free Cosmetics Act (TFCA), Assembly Bill
2762, as of September 30th 2020, joining the European Union
and dozens of nations - including Australia, Canada, Japan,
Mexico and the UK - in protecting against these widespread
but hidden toxic compounds [California TFCA 2020]. SB312
also closes an abused federal labeling loophole allowing
companies to claim trade secret protection for chemicals used
to impart fragrance or avor. The banned chemicals included
long chain PFAS chemicals, endocrine disruptors linked to
cancer and immune system suppression; the phthalates
dibutyl phthalate and diethylhexyl phthalate; the parabens
isobutylparaben and isopropylparaben; among others.
Besides California that has already legislated its ban through
the passage in law of the Toxic-Free Cosmetics Act (TFCA),
many states are moving towards bans of toxic personal care
and cleaning products with other joining in near future. In
addition, a move to national regulations is already underway,
with several proposals currently pending in Congress,
one being H.R. 5279 Amendment, the Cosmetic Safety
Enhancement Act (CSEA) of 2020. Note that all phthalates
are classied as dangerous substances by the European
Union’s REACH (Registration, Evaluation, Authorization and
Restriction of Chemicals) regulation. In addition, there is
increasing corporate voluntary initiatives. Many
environmentally conscious rms have taken the initiative to
ban or progressively reduce towards ultimate elimination
many of these toxic chemicals, as tracked and documented by
the group Mind the Store, a program of Toxic-Free Future,
which issues a Grade Report for the top retailers in their
annual report, Who’s Minding the Store? — A Report Card on
Retailer Actions to Eliminate Toxic Chemicals [Mind the Store
2021].
Breakthrough: New Recognition of the Toxicity of PFAS
“Forever Chemicals”
Based on a comprehensive analysis of the US EPA ECHO
database that provides an interface to federal and state data
for over 1,500,000 regulated facilities, coupled with state-
specic case studies [Andrews 2021], there are known to be
over 42,000 sources of per- and polyuoroalkyl substances
(PFAS) used in thousands of industrial and consumer
products and processes, including household and laundry
and personal care products and cosmetics, cookware, food
and food packaging, carpets, clothing, and outdoor gear, that
have extremely high environmental persistence, breaking
down very slowly over time and lingering for decades
both in people’s bodies and in the environment, and hence
known as “forever chemicals”, with risks building up over a
lifetime of exposure in humans. The EPA, after consistently –
and against the evidence - downplaying the extensively
documented hazards of PFAS, and claiming that the levels
of exposure that the EPA judged safe in humans were in
fact thousands of times higher than true safe thresholds
established beyond reasonable doubt by the best of
scientic evidence and consensus, has on June 15, 2022
now admitted that PFAS represent “an urgent public
health and environmental issue facing communities across
the United States” and that safe levels of exposure to
PFAS, the levels at which harms might not occur, should be
thousands of times lower than the limits it rst proposed
back in 2016, and has issued nonbinding health advisories
that set health risk thresholds for two PFAS, PFOA and PFOS,
to near zero, replacing 2016 guidelines that had set them to
70 parts per trillion (ppt) [EPA 2022]. This is a remarkable
move namely the EPA cutting the safe level of the PFAS
chemical PFOA by more than 17,000 times the previous
agency-declared tolerable limit, now down to just four parts
per quadrillion, and in essence declaring that any detectable
amounts of PFOA and PFOS are unsafe to consume. The
critical path to this change of regulatory sentiment occurred
with the EPA’s announcement on November 16, 2021 of a new
PFAS Strategic Roadmap, the supporting scientic research of
which was to fall under the auspices of the agency’s Science
Advisory Board (EPA SAB) based on best evidence to date,
with the EPA further adding that one of the most common
PFAS, peruorooctanoic acid (PFOA), is strongly evidenced
as a carcinogen [EPA 2021] (As an aside for moviegoers, PFOA
gured centrally in the popular lm “Dark Waters” (2019)

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directed by Todd Haynes).
But we need to go further, to not solely concentrate on
drinking water sources and reservoirs and lakes, which are
the “ends of the pipeline”, but tackle the sources that include
the everyday “up-drain” consumer products that people use
which are weaving their way down residential and commercial
drains; as Emily Remmel, Director of Regulatory Aairs of
the National Association of Clean Water Agencies (NACWA)
representing wastewater authorities, has put it, “washing
your clothes, washing your face, washing your dishes” are the
signicant upstream sources to contamination of drinking
water facilities [Bagenstose 2022].
Regulatory Resistance and Failure of Duty of Care: Although
these long-overdue recognitions are welcome, this adds to
the many instances of what we call regulatory resistance and
inertia to scientic evidence and consensus, given that this
is in fact the rst time the EPA relied on scientic data about
the impact on human health of PFAS, but readily available to
researchers, forcing the EPA to wholly reverse its position on
safe levels of human exposure. As a result, the agency has
changed its position on safe levels of exposure. Still, emerging
new evidence suggests that evidence of potential human risks
of many chemicals (neurological eects, birth defects, and
cancer) were removed or minimized by EPA sta [Steiner
2022].
Another singular instance of such resistance concerns
the New York City (NYC) Hillview Reservoir, a 90-acre water
storage reservoir located in southeastern Yonkers, New
York, and the last stop before treated water for human
consumption by city residents enters the New York City (NYC)
water distribution system. Although chemical disinfection
and ultraviolet treatment can occur upstream of the Hillview
Reservoir, the reservoir itself is not covered, allowing for
pathogens from birds, animals and other contaminating
sources to enter the water stored there. But despite
regulatory requirements active against the City of New
York and the NYC Department of Environmental Protection
(DEP), to wit a New York State (NYS) Administrative Order in
1999, a federal regulation under the Safe Drinking Water Act
(SDWA) under EPA compliance monitoring in 2005, and an
EPA Administrative Order in 2010, among others, all of which
required the cover and all of which were entered into and with
specic agreed performance dates, the City of New York and
the NYC Department of Environmental Protection (DEP) failed
to meet any of the dates for the construction of the mandated
cover, whose cost in 1999 was estimated to be modest. On
March 18, 2019 U.S. Attorneys for the Eastern District of New
York (EDNY) led a Safe Drinking Water Act (SDWA) complaint
against the City of New York and the NYC Department of
Environmental Protection (DEP), seeking to require the City to
cover the Hillview Reservoir, and the Eastern District of New
York (EDNY) also lodged on that same date a proposed Judicial
Consent Decree and Judgment with the Court that would
require the City to implement the cover and needed upgrades
at the reservoir over the next thirty years, at an estimated
cost of over $2 billion, with a target date of not later than
2049. This is fty years after the City of New York and the NYC
Department of Environmental Protection (DEP) rst agreed to
its construction. The City of New York and its agent the NYC
Department of Environmental Protection (DEP) will also pay
a $1 million penalty to the United States, a $50,000 penalty
to New York State, and implement a $200,000 Water Quality
Benet Project [EDNY 2019]. This failure of due diligence
further impacts on PFAS contamination, as it is known that
avian eggs and tissues and droppings are, as the National
Audubon Society has noted, “chock-full of widely used PFAS”
[Audubon 2019], and hence add to PFAS recontamination of
unprotected – like the uncovered Hillview facility – reservoirs,
compromising human health.
Legislative Action at Local State Level: A landmark
advance is New York former Governor Cuomo’s signing
into law a bill (NYS Bill No. 4389B/A 6295A) [NYS Senate Bill
S4389B] that bans more than trace amounts of the toxin and
carcinogen 1,4-dioxane, a known contaminant and carcinogen
(classied as a Group B2, probable human carcinogen, by the
Environmental Protection Agency (EPA) that readily penetrates
the skin and can be released to the air and breathed in, and
migrates to New York’s water systems and water bodies as
well as workplaces, and in a broad spectrum of products we
use. 1,4-dioxane is widespread in laundry products, especially
detergents, but also in cosmetic products and personal care
products, and in 97% of hair relaxers, 57% of baby soaps and
children’s bubble bath and body washes and so ubiquitous
that in an assessment by the Environmental Working Group
(EWG), it was found that 22 percent of all products for any
use whatsoever may be contaminated with 1,4-dioxane [EWG
Report 2007]. Note 1,4-dioxane has three principle routes: by
skin penetration, by consumption of polluted water, and more
rarely, by inhalation (mainly among industrial workers in close
contact with it). The NYS ban ocially begins to take eect
January 1, 2023, with increasingly stringent requirements over
a two-year period, and with California and many other states
to shortly follow suit. Eorts to bring forward the start date
by a year are currently ongoing. It is important to appreciate
that 1,4-dioxane is a byproduct of the combination of other
ingredients reacting together to form it under the process
known as ethoxylation, not itself an ingredient, so it will not
be found on any product label. Common ingredients that lead
to 1,4-dioxane formation are from sodium laureth sulfate
and other laureths; chemicals in the polyethylene glycol (PEG)
class; and chemicals compounds with “xynol”, “ceteareth”,
“oleth” “laureate”, and “myrrh” as part of their designations.
Legislative Action at the Multi-state Level – the AG
Consortium: On March 22, 2021 New York Attorney General
Letitia James, leading a coalition of 15 attorneys general (NY,
HI, IL, MA, ME, MD, MN, NY, OR, PA, RI, VT, VA, WA, DC, and
City of New York) served legal action [NY Attorney General

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2021] in support the Biden Administration’s remedy against
the numerous deciencies of the EPA’s risk evaluation of
the highly-toxic chemical 1,4-dioxane (hereafter “dioxane”),
a risk evaluation that was one of numerous “midnight”
blatantly anti-environmental actions taken by the former
administration in its closing days. The EPA’s risk evaluation
has minimized or dismissed dioxane’s well evidenced dangers
to workers, low-income community’s residents, communities
of color, and the general public, with the manifest intent to
restrict the EPA from implementing regulatory measures to
eliminate the substantial health risks posed by dioxane.
The action of this “AG Coalition” as we call it, seeks to
support the Biden Administration’s current and projected
eorts to correct the many deciencies in the EPA’s dioxane
risk evaluation. And given that the procedures used for
chemical risk evaluations under the Toxic Substances Control
Act (TSCA) have been identied as potentially contrary to
President Biden’s Executive Order on Protecting Public Health
and the Environment and Restoring Science to Tackle the
Climate Crisis, Executive Order No. 13990 [Executive Order
Whitehouse 2021], they are therefore subject to revision,
rescission, or suspension. The AG Coalition charges that the
EPA under the former administration ignored both science
and the law in an eort to block necessary action to address
the numerous serious health and environmental dangers via
a fatally-awed risk evaluation.
The chemical is also formed as a byproduct from the
breakdown of other chemicals in a variety of consumer
products, including laundry and other detergents, household
cleaners, and personal care products, and is released into the
air, water, and soil at places where it is produced or used.
The New York Public Interest Research Group (NYPIRG)
has reported that at least 12 million New Yorkers drink
water with some level of signicant concern of 1,4-dioxane
contamination, and in addition their data analysis has found
that 176 water systems that impact 16 million New Yorkers
contain one or more emerging contaminants, with every
region in New York State aected, including Long Island’s
groundwater, which is the sole source of drinking water for
almost 3 million state residents [NYPIRG 2019].
Because of its potential for substantial harm to public
health and the environment, the EPA selected 1,4-dioxane as
one of the initial 10 chemical substances subject to its initial
risk evaluations, required under the TSCA amendments of
2016. That law requires the EPA to perform comprehensive
evaluations of the risks associated with the “full range of
exposures” people have to the chemical. The coalition
argues that the EPA’s 1,4-dioxane risk evaluation excludes
many potential pathways and exposures. Despite the fact
that 1,4-dioxane has many signicant exposure pathways
that expose people to the toxic chemical, including drinking
contaminated water, breathing contaminated air, exposure
through contaminated soil, and including exposure from
laundry products (a residue of it can be left over in clothes
after washing cycles), the EPA’s risk evaluation under the
former administration found no “unreasonable risk” to the
general public from 1,4-dioxane’s numerous uses. But the
EPA risk evaluation is fatally confounded by the fact that
the exposure to the general public the EPA examined was
limited, unrealistically, to solely recreational swimming,
with no examination of exposure pathways like drinking
contaminated water, and using household and laundry
cleaning agents that can signicantly harm people’s health.
The EPA is also charged by the AG Coalition with failing to
assess 1,4-dioxane’s exposure risks to vulnerable populations
such as infants, children, pregnant women, workers, and
the elderly whose risk may be substantially higher than
the general public, and the EPA used the unsupported
assumption that workers will use consistently, properly and
eectively, personal protective equipment which is assumed,
without evidence, to protect against 1,4-dioxane exposure,
and by doing so the EPA underestimated the chemical’s risks
to workers, and succumbed to the urgings of industry trade
groups intent on blocking related state-level policies [NY
Attorney General 2021].
Conclusions
It is clear, as we have marshaled the evidence above, that
laundry products, in such widespread use in the home, impose
extensive reproductive/fertility, respiratory/pulmonary,
neurological and neurocognitive, metabolic, and oncological
risks to human health, both by direct exposure, and by their
ultimate contamination of water distribution systems, and
that these hazards are now being recognized as requiring
urgent regulatory and legislative actions to curtail their use.
Some of these eorts we have documented in our paper are
highly commendable and are buttressed and extended by
voluntary restrictions from major retailers, to their credit. But
despite this, there remain as we have shown large pockets
of regulatory resistance and inertia, and not infrequent
politicization, we believe that must be overcome, by:
1. more comprehensive public education of the dangers,
2. more timely and mandatory legislative actions for
their prohibition and mitigation of these contaminants
within the many domains of their use, and
3. by more coordinated research aimed at building global
scientic consensus on their maximal thresholds
of safe human exposure, to replace the current
patchwork quilt of unaligned and heavily siloed
research endeavors.
Competing interests
Author has declared that no competing interests exist.

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