{"edition":"usa","organization":"Toxic-Free Future","organizationId":"org:toxic-free-future","boundaryVersion":"USA-50-states-DC-v1","updated":"2026-09-14","model":{"version":"usa-tff-alpha-two-policy-partial-2","costScope":"Two years of full recipient expense at 2024 scale, including all programs, regrants and support; no best-program denominator. Only TCE cancer and PFAS mortality-timing branches quantified. Public and corporate implementation resources excluded from recipient cost, disclosed separately.","geographicAttribution":"USA50states+DC residents. Federal occupational model is predominantly domestic; g=.995 is a judgment excluding territorial/nonresident exposure. No global supply-chain benefits or Washington-to-USA population multiplier. PFAS includes Tribal residents of the 50states; territories excluded through the small judgment allocation allowance.","formula":"C=2*2,689,041. TCE=F*m*Y(T)*e*a*b*q, with F=64.1/15.4 and Y=sum(t=1..T)1/1.03^t. PFAS: B=(1300*qi+5700*qa)*d*mp; P=B*(1-1/1.03^2)*u*pp*ap*b. Q_all=TCE+P-H; Q_USA=g*Q_all; price=10*C/Q_USA if positive. PFAS qi/qa are lifetime QALYs discounted to the avoided death date; d discounts those dates to2026. Two-year shift factor prices timing, not a permanent loss of the full regulation. TCE q includes latency to each exposure year, Y discounts exposure timing.","counterfactual":"Existing rule, committed company transitions, enforcement and other advocates remain. e is the expected fraction of full-rule health protection retained by additional coalition defense: central .025 represents a 10-percentage-point difference in probability of preserving25% of modeled exposure benefit, not a 25%chance the whole ban survives. Five full-equivalent years are a judgment, not observed2027–31 exposures. For PFAS, compare earlier treatment with the proposed two-year delayed stream, retain the MCLs, and discount by u for actual delay/mitigation/independent action. pp is the incremental coalition probability of preventing the modeled delay; ap is TFF's distinct PFAS causal share.","attribution":"a=.05 is TFF's subjective share of the incremental coalition contribution, recognizing coordination but many partners. b=.5 discounts replacement by reserves, other donors and institutional funding. Neither comes from a measured causal attribution study; scenario variation is deliberately wide. PFAS uses pp=.1, ap=.03 and shared b=.5; its public opposition is observed but this particular influence is not measured. No equal allocation among signatories.","uncertainty":"Very-low-confidence two-branch partial central. EPA risk forecasts are not observed donor outcomes. Mortality timing, QALYs, clinical transport, effective delay and political influence are judgments. Broad scenarios include near-zero, zero and harm, not confidence intervals. Other programs remain unpriced, so this is neither an aggregate estimate nor a lower bound. The rigid two-year shift of the entire modeled health stream is a structural approximation, not EPA's estimate of the extension's health effect. The parameter u accounts for exemption uptake, independent early treatment, state rules and interim mitigation; actual delay and health accrual may differ across systems and years.","nativeOutcomes":"Specific policy protections retained, unique workers with lower exposure, full-equivalent protected exposure years, potential cancer cases prevented, clinical QALYs. Bills, letters, products tested, pounds of chemicals and retailer scores are not QALYs. PFAS branch counts timing of modeled developmental, cardiovascular and kidney-cancer mortality only; excludes bladder co-removal and all nonfatal events.","inputs":[{"name":"C","value":5378082,"unit":"USD, two full annual recipient budgets","basis":"judgment","rationale":"Judgment extrapolation to two years at the observed annual recipient expense: 2×2024 total expense; two-year support horizon is judgment.","sourceIds":["tff-99024"]},{"name":"F","value":4.162337662337662,"unit":"potential cancers avoided per full-equivalent exposure year","basis":"observed","rationale":"Derived from two rounded EPA model figures: $64.1 million annualized cost / $15.4 million per cancer avoided. Model-based forecast, not observed cases; approximated20-year average.","sourceIds":["tff-tce-rule"]},{"name":"m","value":1,"unit":"clinical/exposure model transport multiplier","basis":"judgment","rationale":"Central retains EPA average; .5–2 scenario tests risk/implementation variation. Future affected uses may differ.","sourceIds":["tff-tce-rule","tff-tce-status"]},{"name":"q","value":3,"unit":"discounted QALYs per potential cancer case prevented","basis":"judgment","rationale":"Broad1–8 plausible range covers cancer mix, age, morbidity, competing mortality and latency. Not inferred mechanically from 5-year survival. Central3 is a subjective composite, not a published utility estimate.","sourceIds":["tff-kidney","tff-nhl","tff-liver"]},{"name":"T","value":5,"unit":"full-equivalent future exposure years","basis":"judgment","rationale":"Count a bounded policy-persistence horizon, not indefinite benefits.2–10 scenarios.","sourceIds":["tff-tce-status"]},{"name":"r","value":0.03,"unit":"annual QALY discount rate","basis":"judgment","rationale":"Discount future exposure years in addition to latency already incorporated in q.","sourceIds":[]},{"name":"e","value":0.025,"unit":"expected coalition-preserved share of full-rule benefit","basis":"judgment","rationale":"Equivalent to .10 incremental probability×.25 affected clinical scope. Existing ban and narrow current delays rule out credit for all original benefits.","sourceIds":["tff-coalition26","tff-tce-status"]},{"name":"a","value":0.05,"unit":"TFF share of incremental coalition causal contribution","basis":"judgment","rationale":"Coordination role warrants a positive but small judgment; not1/250 equal division and not sole credit.","sourceIds":["tff-coalition26","tff-victories25"]},{"name":"b","value":0.5,"unit":"funding additionality","basis":"judgment","rationale":"Reserve and donor replacement discount. No documented marginal funding gap.","sourceIds":["tff-99024"]},{"name":"g","value":0.995,"unit":"USA50states+DC resident health share","basis":"judgment","rationale":"Domestic federal occupational scope, small exclusion allowance; not headquarters geography.","sourceIds":["tff-tce-rule"]},{"name":"H","value":0,"unit":"all-population QALYs of downside","basis":"judgment","rationale":"Central0 is provisional, not measured safety; adverse scenario1, and positive H subtracts before geography.","sourceIds":[]},{"name":"otherPathways","value":null,"unit":"net QALYs from other recipient work","basis":"unknown","rationale":"State/corporate work, other chemicals, non-cancer TCE, PFAS nonfatal and non-timing outcomes unpriced; no aggregate claim.","sourceIds":[]},{"name":"PFASDeaths","value":7000,"unit":"modeled deaths over long original regulatory horizon","basis":"observed","rationale":"Rounded1,300 developmental+3,700 cardiovascular+2,000 kidney deaths. EPA forecast, not annual counts or measured outcomes. Excludes2,600 bladder co-removal deaths.","sourceIds":["tff-pfas-native","tff-pfas-ea"]},{"name":"qi","value":25,"unit":"QALYs per avoided developmental death at event date","basis":"judgment","rationale":"Lifetime3%-discounted health of an infant; broad10–30 range. Not an EPA utility input.","sourceIds":["tff-pfas-native"]},{"name":"qa","value":5,"unit":"QALYs per avoided adult death at event date","basis":"judgment","rationale":"Broad1–10 discounts age, competing mortality and health quality; not equal to all remaining years.","sourceIds":["tff-pfas-native"]},{"name":"d","value":0.3,"unit":"future-event present-value timing factor","basis":"judgment","rationale":"Original horizon 2024–2105; uniform events2029–2105 would give~.366 at 3% from 2026. Central.30 allows later accrual; .1–.6 range, not a recovered EPA event stream.","sourceIds":["tff-pfas-ea"]},{"name":"mp","value":0.5,"unit":"PFAS clinical-model transport","basis":"judgment","rationale":"Haircut for observational dose-risk links, risk-factor mediation and clinical transport; .1–1 range. Not scientific posterior probability.","sourceIds":["tff-pfas-ea"]},{"name":"u","value":0.5,"unit":"effective share of modeled two-year delay","basis":"judgment","rationale":"Judgment about exemption uptake and effective delay after independent early treatment, state rules, interim filters and other mitigation; .1–1 range. A rigid two-year health-stream shift is a structural approximation, not an EPA forecast.","sourceIds":["tff-pfas-proposal"]},{"name":"pp","value":0.1,"unit":"incremental probability of avoiding PFAS delay through coalition work","basis":"judgment","rationale":"Active opposition to a live proposal supports considering an effect, not measuring it; .01–.3 scenarios with0 possible.","sourceIds":["tff-pfas-response","tff-pfas-status"]},{"name":"ap","value":0.03,"unit":"TFF share of incremental PFAS coalition influence","basis":"judgment","rationale":"Small share reflects national advocacy plus Safer States but many agencies, litigators and partners; .001–.1 range.","sourceIds":["tff-pfas-response"]}],"scenarios":[{"id":"central","label":"Partial TCE plus PFAS timing central","costUSD":5378082,"allPopulationQalys":0.4296773630216201,"editionQalys":0.427528976206512,"assumptions":"F=4.162337662337662; m=1; T=5; Y=4.579707187194534; e=0.025; a=0.05; b=0.5; q=3; H=0; g=0.995. Full recipient costs retained; other pathways unpriced. PFAS qi=25, qa=5, d=0.3, mp=0.5, u=0.5, pp=0.1, ap=0.03, b=0.5; B=9150; shift=0.05740409086624565; PFAS all-population Q=0.3939355735696108. Add to TCE and subtract H once."},{"id":"favorable","label":"Favorable joint assumptions","costUSD":5378082,"allPopulationQalys":92.98955967489637,"editionQalys":92.52461187652189,"assumptions":"F=4.162337662337662; m=2; T=10; Y=8.530202836775828; e=0.15; a=0.2; b=0.8; q=8; H=0; g=0.995. Full recipient costs retained; other pathways unpriced. PFAS qi=30, qa=10, d=0.6, mp=1, u=1, pp=0.3, ap=0.1, b=0.8; B=57600; shift=0.05740409086624565; PFAS all-population Q=79.35541521349799. Add to TCE and subtract H once."},{"id":"poor","label":"Weak marginal influence and clinical yield","costUSD":5378082,"allPopulationQalys":0.0000030645832440723574,"editionQalys":0.0000030492603278519957,"assumptions":"F=4.162337662337662; m=0.5; T=2; Y=1.9134696955415214; e=0.0005; a=0.01; b=0.1; q=1; H=0; g=0.995. Full recipient costs retained; other pathways unpriced. PFAS qi=10, qa=1, d=0.1, mp=0.1, u=0.1, pp=0.01, ap=0.001, b=0.1; B=187; shift=0.05740409086624565; PFAS all-population Q=0.0000010734564991987938. Add to TCE and subtract H once."},{"id":"zero","label":"No additional policy effect","costUSD":5378082,"allPopulationQalys":0,"editionQalys":0,"assumptions":"F=4.162337662337662; m=1; T=5; Y=4.579707187194534; e=0; a=0.05; b=0.5; q=3; H=0; g=0.995. Full recipient costs retained; other pathways unpriced. PFAS qi=25, qa=5, d=0.3, mp=0.5, u=0.5, pp=0, ap=0.03, b=0.5; B=9150; shift=0.05740409086624565; PFAS all-population Q=0. Add to TCE and subtract H once."},{"id":"adverse","label":"Illustrative net policy/substitution harm","costUSD":5378082,"allPopulationQalys":-1,"editionQalys":-0.995,"assumptions":"F=4.162337662337662; m=1; T=5; Y=4.579707187194534; e=0; a=0.05; b=0.5; q=3; H=1; g=0.995. Full recipient costs retained; other pathways unpriced. PFAS qi=25, qa=5, d=0.3, mp=0.5, u=0.5, pp=0, ap=0.03, b=0.5; B=9150; shift=0.05740409086624565; PFAS all-population Q=0. Add to TCE and subtract H once."}],"sensitivity":["Price is inversely proportional to e,a,b,m and q and declines with protected years. No policy effect or full donor replacement gives zero quantified benefit.","The central e=.025 is not an observed probability. Crediting the entire preexisting ban would materially overstate next-dollar impact.","At two-year cost, $1 million/$100 thousand per 10 requires 53.78082/537.8082 USA QALYs. Combined central .42753 leaves about 53.35/537.38 additional net QALYs needed.","TCE-only frontier: at q=3 and g=.995, $1 million/$100 thousand requires 18.02/180.17 fully additional cancer cases. This cannot establish total recipient effectiveness.","Using the 3-year expense mean reduces cost by about 3.6%. Using only the federal program denominator would be outside ordinary recipient scope.","A loss of .42968 all-population QALYs erases combined central benefit. For TCE alone the corresponding figure is .03574.","TCE affected uses may differ from EPA's20-year average. PFAS needs year-specific mortality and actual exemption uptake. The .30 event discount is explicit judgment, not recovered simulation.","PFAS dominates centrally: .39394 of .42968 all-population QALYs. The shift factor is1−1/1.03²=.057404; removing it would wrongly credit the entire long-term rule."],"missingInputs":["Prospective unfunded recipient work plan and measured incremental donor capacity.","Case-specific coalition influence and scope of policy protection at risk, net of existing law and independent company/agency behavior.","Cancer-type/age/latency distribution for TCE-attributable modeled cases to replace the broad clinical QALY judgment.","Exposure-to-clinical models for PFAS, state and retailer work plus non-cancer TCE outcomes, overlap and replacement harms.","PFAS year-by-year health stream, exemption uptake, actual filter use, treatment capacity and incremental TFF influence; replace broad timing/clinical judgments with these inputs."]},"sources":[{"id":"tff-99024","title":"2024 original Form 990, Parts III and VIII–XII","publisher":"Toxic-Free Future / IRS, hosted by ProPublica","url":"https://projects.propublica.org/nonprofits/organizations/911214158/202523179349310762/full","published":"2025-11-13","retrieved":"2026-09-14"},{"id":"tff-99023","title":"2023 original Form 990","publisher":"Toxic-Free Future / IRS, hosted by ProPublica","url":"https://projects.propublica.org/nonprofits/organizations/911214158/202423199349313782/full","published":"2024-11-14","retrieved":"2026-09-14"},{"id":"tff-99022","title":"2022 original Form 990","publisher":"Toxic-Free Future / IRS, hosted by ProPublica","url":"https://projects.propublica.org/nonprofits/organizations/911214158/202343189349306929/full","published":"2023-11-14","retrieved":"2026-09-14"},{"id":"tff-financials","title":"Financial reports index","publisher":"Toxic-Free Future","url":"https://toxicfreefuture.org/financial-reports/","published":null,"retrieved":"2026-09-14"},{"id":"tff-victories25","title":"2025 victories","publisher":"Toxic-Free Future","url":"https://toxicfreefuture.org/wp-content/uploads/TFF_Victories2025_Final.pdf","published":null,"retrieved":"2026-09-14"},{"id":"tff-coalition26","title":"250 organizations urge Senate to preserve chemical safety protections","publisher":"Toxic-Free Future / Alliance for Health and Safe Chemicals","url":"https://toxicfreefuture.org/press-room/250-organizations-urge-senate-put-americans-health-before-chemical-industry-profits/","published":"2026-07-23","retrieved":"2026-09-14"},{"id":"tff-cycle2","title":"Safer Products for Washington project, implementation and comments","publisher":"Toxic-Free Future","url":"https://toxicfreefuture.org/key-project/safer-products-for-washington/","published":null,"retrieved":"2026-09-14"},{"id":"tff-retail","title":"Retailer Report Card","publisher":"Toxic-Free Future","url":"https://toxicfreefuture.org/retailer-report-card/","published":null,"retrieved":"2026-09-14"},{"id":"tff-correction","title":"Two corrections to black-plastics exposure example","publisher":"Toxic-Free Future","url":"https://toxicfreefuture.org/update-study-correction-does-not-impact-conclusion/","published":"2025-07-03","retrieved":"2026-09-14"},{"id":"tff-tce-rule","title":"Final TCE rule, Federal Register 89 FR 102568, p102615","publisher":"US Environmental Protection Agency / Government Publishing Office","url":"https://www.govinfo.gov/content/pkg/FR-2024-12-17/pdf/2024-29274.pdf","published":"2024-12-17","retrieved":"2026-09-14"},{"id":"tff-tce-status","title":"Current TCE risk management and compliance status","publisher":"US Environmental Protection Agency","url":"https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-management-trichloroethylene-tce","published":"2026-05-05","retrieved":"2026-09-14"},{"id":"tff-kidney","title":"Kidney and renal pelvis cancer statistics, 2016–2022 survival","publisher":"National Cancer Institute SEER","url":"https://seer.cancer.gov/statfacts/html/kidrp.html","published":null,"retrieved":"2026-09-14"},{"id":"tff-nhl","title":"Non-Hodgkin lymphoma statistics, 2016–2022 survival","publisher":"National Cancer Institute SEER","url":"https://seer.cancer.gov/statfacts/html/nhl.html","published":null,"retrieved":"2026-09-14"},{"id":"tff-liver","title":"Liver and intrahepatic bile duct cancer statistics, 2016–2022 survival","publisher":"National Cancer Institute SEER","url":"https://seer.cancer.gov/statfacts/html/livibd.html","published":null,"retrieved":"2026-09-14"},{"id":"tff-mc-campaign","title":"Methylene chloride campaign history","publisher":"Toxic-Free Future","url":"https://toxicfreefuture.org/federal-policy/epa-ban-toxic-methylene-chloride/","published":null,"retrieved":"2026-09-14"},{"id":"tff-mc-epa","title":"Final ban on most methylene chloride uses","publisher":"US Environmental Protection Agency","url":"https://www.epa.gov/newsreleases/biden-harris-administration-finalizes-ban-most-uses-methylene-chloride-protecting","published":"2024-04-30","retrieved":"2026-09-14"},{"id":"tff-pfas-status","title":"Proposed PFOA/PFOS extension rule, current status","publisher":"US Environmental Protection Agency","url":"https://www.epa.gov/sdwa/proposed-pfoa-and-pfos-compliance-extension-rule","published":"2026-07-23","retrieved":"2026-09-14"},{"id":"tff-pfas-proposal","title":"2026 compliance-extension proposal and counterfactual analysis","publisher":"US Environmental Protection Agency / Federal Register","url":"https://www.federalregister.gov/documents/2026/05/20/2026-10086/extending-the-compliance-deadline-for-the-pfoa-and-pfos-maximum-contaminant-levels","published":"2026-05-20","retrieved":"2026-09-14"},{"id":"tff-pfas-response","title":"Response to proposed PFAS rule changes","publisher":"Toxic-Free Future and Safer States","url":"https://toxicfreefuture.org/press-room/epa-announces-rollback-of-protections-for-toxic-pfas-forever-chemicals-in-drinking-water/","published":"2026-05-18","retrieved":"2026-09-14"},{"id":"tff-pfas-native","title":"PFAS rule benefits and costs, Table3 native outcomes","publisher":"US Environmental Protection Agency","url":"https://www.epa.gov/system/files/documents/2024-04/pfas-npdwr_fact-sheet_cost-and-benefits_4.8.24.pdf","published":null,"retrieved":"2026-09-14"},{"id":"tff-pfas-ea","title":"Final PFAS economic analysis, clinical methods and2024–2105 horizon","publisher":"US Environmental Protection Agency","url":"https://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P101DTYY.TXT","published":null,"retrieved":"2026-09-14"}]}