GiveBetter x USA

Center for Environmental Health

Chemical testing, enforcement and safer purchasing

Research time: 13 min on GPT-6 Astra Light
  • Research — reviewed programs, finances and impact evidence.

Updated: 2026-09-14

Summary

What do they do? CEH tests products, pursues chemical-law enforcement and helps institutions buy safer alternatives. Its work can change manufacturers' behavior beyond California, and recent receipt-paper agreements address several potentially harmful substitutes together. An extremely uncertain judgment estimate prices prospective receipt-exposure acceleration at full recipient cost; the clinical health prior is explicit and other prevention pathways remain unpriced.

Why we’re interested in this organization:

  • Product testing and detailed settlement terms provide more inspectable mechanisms than general awareness campaigns.

  • Class-wide restrictions on receipt additives can reduce the risk of replacing one concerning chemical with another.

  • There are plausible nationwide manufacturing spillovers and complementary local pollution-remediation pathways.

Our main reservations:

  • A settlement count or chemical-content exceedance does not establish absorbed dose, disease reduction or QALYs.

  • Already committed reformulation and existing legal obligations weaken the link from a new donation to future changes.

  • The strongest recent numerical claims describe market reach, while geographical, clinical and funding additionality remain unresolved.

What do you get for your dollar? $2192.9M per better life: ten additional quality-adjusted life years in USA. Judgment-based partial-health. Prospective receipt-exposure acceleration only; full recipient cost, extremely uncertain clinical prior, not whole-portfolio health..

The prospective cohort and counterfactual factors imply 250 additional exposure-reduced worker-years before geography, not100000beneficiaries directly credited. Expected net health-area prior p*k-h=.00008 QALY per worker-year before3percent discount; no lifetime extension.

1. What do they do?

CEH combines litigation, product testing, safer purchasing and community pollution work. Its 2024 return allocates about $1.06 million to consumer-product litigation, $0.64 million to green chemistry, $0.31 million to industrial-pollution work, and the remainder to other programs and support. The return describes soil screening and safe-gardening/landscaping help around a battery-recycling facility, as well as product and industrial cases. Original return

The annual report records 315-plus products tested and 33 companies with legal agreements. These are concrete activities but heterogeneous units: a small product reformulation and a major manufacturing change do not have equal health value. Safer foodware and institutional-purchasing support are additional branches, not automatic QALYs from waste avoided. Annual report

2. Monitoring and information sharing

The August 2026 receipt announcement reports agreements with 163 companies representing 7% of the US retail market. Market share is not the share of residents, cashiers, receipts or health risk affected. Announcement

The court-filed amended Domtar judgment, entered August 11, 2026, is more informative: its operative reformulation clause covers products for use in California; the recitals describe an expected nationwide transition. The filing stamp and clerk's service certificate verify entry, not actual compliance. Compliance monitoring should establish dates, sales destinations, chemical migration and worker/customer exposures—not merely signed agreements. Entered judgment DOJ registry

The next useful evidence is a product-by-product panel of pre/post formulation, use frequency, geography and biomarkers, with a comparator and actual implementation date. For local remediation, measure contaminated areas made inaccessible, sustained blood-lead/exposure changes and health-relevant follow-up. Repeat tests should distinguish enforcement success from changes already required or planned.

3. Qualitative assessment

Human studies support a receipt-exposure route, but do not identify a QALY return. In one study, urinary BPS rose after shifts among 33 cashiers handling BPS receipts; it was an exposure study, not a disease-prevention trial. Thayer et al. A separate small controlled/observational project found no statistically clear shift-related signal and emphasized measurement and sample limitations, not proof of safety. NIOSH research

A 2024 NHANES analysis found broad exposure declines and substitution patterns: BPA decreased while BPS increased. Similar trends inside and outside California and concurrent scientific/regulatory attention complicate causal attribution to Proposition 65, let alone CEH. It supports the plausibility of national formulation effects, not a measured CEH share of national disease burden. Primary analysis

I also tested a more direct chromium/contact-dermatitis route. A recent Danish study of 4,830 patch-tested patients found stable chromium-allergy trends after the EU leather limit; clinic prevalence is not general-population incidence. That does not invalidate CEH's specific agreements, but it prevents assuming every compliant leather product removes a predictable dermatitis burden. Clinical study

My judgment favors a small positive but extremely uncertain prospective exposure-acceleration health yield. I assign a20percent probability to clinically meaningful benefit and a small conditional health area, while retaining an expected substitution burden. These are transparent priors, not evidence that chemical warning exceedances cause a known quantity of disease. Effects differ by dose, route, age and replacement material; a warning threshold is not an estimated probability of disease. Regulatory burden, regrettable substitutions, unnecessary avoidance and diverted resources are possible downsides.

4. What do you get for your dollar?

Full recipient expense was $4,045,100 in 2024, including management, fundraising and investment-management fees. The original return does not show event or inventory costs to restore. 2024 return The comparable 2023 and 2022 totals are $5,130,659 and $5,438,516, giving a $4,871,425 mean. The higher IRS totals relative to audited operating expense reconcile to $22,661 and $27,923 investment fees, respectively. 2023 return 2022 return Audit

For scale only, dividing all 2024 costs by 33 agreements is about $123,000 per agreement, or by 315 tested products about $12,800 per product. Neither is a marginal service price or a clinical outcome. The latest 163-company settlement cohort covers different timing and must not be divided into a single historical budget as though it were annual throughput.

At $4.05 million annual expense, a price of $1 million per 10 USA QALYs requires 40.45 net attributable USA QALYs; $100,000 requires 404.51. If a verified additional exposure reduction benefited 100,000 USA worker-years after all counterfactual and funding adjustments, those thresholds would require 0.000405 or 0.004045 QALYs per worker-year—about 3.5 or 35.5 quality-adjusted hours. Those are break-even requirements, not claimed benefits. A valid estimate needs both the additional exposure-years and a causal dose-to-health function.

The finite best-judgment receipt-acceleration branch yields 0.018447 USA QALYs per full $4,045,100 recipient cost, or about $2.19 billion per 10. The100000-worker planning cohort is reduced by .1 chance of acceleration, .25 CEH contribution, .5 funding response, .8 compliance and .25 year of earlier exposure reduction. The seven-percent retail-market claim is not used to infer population reach. A20 percent clinical-benefit prior times .0005 conditional QALY per exposure-reduced worker-year, less .00002 expected burden, is the weakest link. These choices were not solved backward from a favorable price. Only the remaining transition-period acceleration is credited; completed legal wins and future recurring monitoring effects are not automatically credited. Other product, lead, industrial-pollution and purchasing pathways remain unpriced. Outside counsel and corporate compliance resources add social cost beyond the recipient denominator.

Model, assumptions and sensitivity

Full annual recipient expense on comparable accrual Form990 basis, all programs and support including investment fees; no subtraction of settlement revenue. External legal, corporate compliance and public enforcement resources require separate social-cost analysis.

USA50states+DC resident outcomes only. California legal scope can generate nationwide manufacturing spillovers but does not establish their realized extent. Each product/site pathway needs outcome-weighted resident allocation; 7% retail market is not g.

C=4045100 full annual recipient cost. E=N*dp*a*b*e*t additional exposure-reduced worker-years; Qall=E*(p*k-h)/1.03; QUSA=Qall*g. N prospective handling-worker cohort, dp probability of earlier actual reformulation/uptake versus existing commitments, a CEH contribution conditional on coalition change, b funding response, e actual compliance/use, t acceleration years. p probability of clinically meaningful dose-related benefit; k conditional one-year QALY area per reduced worker-year; h expected replacement/disruption burden. No benefits after modeled acceleration; no lifetime disease multiplier or credit for historic agreements.

C
4045100 USD annual full recipient expense (observed). 2024 Form990 PartIX includes investment management fees and no netted event/COGS cost restoration required. [ceh-99024]
agreements2024
33 companies with agreements (observed). Annual report count; heterogeneous legal outputs, not patient outcomes. [ceh-annual24]
products2024
315 products tested, rounded lower reported count (observed). 315-plus new/active-case product tests; not units sold or exposures reduced. [ceh-annual24] [ceh-99024]
receiptCompanies2026
163 companies in announced settlement group (observed). Self-reported current output; not annualized throughput or unique health beneficiaries. [ceh-receipts26]
receipt_N
100000 see formula (judgment). 100000prospective frequent-handler workers is an order-of-magnitude planning cohort, not7percent of population or a measured beneficiary count. Test10000–1000000. [ceh-receipts26] [ceh-domtar-judgment26] [ceh-cashiers]
receipt_dp
0.1 see formula (judgment). Only.1probability of a meaningful acceleration beyond already committed transition; not probability the existing judgment exists. [ceh-receipts26] [ceh-domtar-judgment26] [ceh-cashiers]
receipt_a
0.25 see formula (judgment). CEH.25contribution when coalition-level implementation changes; dp itself is coalition-level, avoiding duplicate net attribution. [ceh-receipts26] [ceh-domtar-judgment26] [ceh-cashiers]
receipt_b
0.5 see formula (judgment). .5marginal responsiveness after settlement recoveries, reserves and donors. [ceh-receipts26] [ceh-domtar-judgment26] [ceh-cashiers]
receipt_e
0.8 see formula (judgment). .8actual uptake/compliance conditional on change, not signed agreement count. [ceh-receipts26] [ceh-domtar-judgment26] [ceh-cashiers]
receipt_t
0.25 see formula (judgment). .25year maximum current-transition acceleration, roughly the remaining2026quarter; no repeated annual rollout credit. [ceh-receipts26] [ceh-domtar-judgment26] [ceh-cashiers]
receipt_g
0.95 see formula (judgment). .95USAresident fraction in a hypothetical worker cohort, not measured nationwide spillover from California-only terms. [ceh-receipts26] [ceh-domtar-judgment26] [ceh-cashiers]
receipt_p
0.2 see formula (judgment). .2subjective probability that this exposure reduction produces clinically meaningful health benefit. Studies establish exposure, not clinical effect; most prior mass allows no such benefit. [ceh-receipts26] [ceh-domtar-judgment26] [ceh-cashiers]
receipt_k
0.0005 see formula (judgment). .0005conditional QALY per reduced worker-year, about4.4quality-adjusted hours. An explicitly weak health-area prior, not a measured endocrine disease dose-response or derived warning threshold. Test.0001–.002. [ceh-receipts26] [ceh-domtar-judgment26] [ceh-cashiers]
receipt_h
0.00002 see formula (judgment). .00002expected QALY burden per changed worker-year from substitute/disruption risk, about10.5quality-adjusted minutes; normative allowance, not measured harm. [ceh-receipts26] [ceh-domtar-judgment26] [ceh-cashiers]

Best estimate — explicit partial-health judgment: Cost: $4.0M; USA QALYs: 0.01844660194174757; all-population QALYs: 0.019417475728155338. {"N":100000,"dp":0.1,"a":0.25,"b":0.5,"e":0.8,"t":0.25,"g":0.95,"p":0.2,"k":0.0005,"h":0.00002}. Finite prospective judgment, not observed throughput or confidence limits.

Weak joint judgment stress: Cost: $4.0M; USA QALYs: 4.611650485436893e-7; all-population QALYs: 4.854368932038835e-7. {"N":10000,"dp":0.02,"a":0.1,"b":0.1,"e":0.5,"t":0.1,"g":0.95,"p":0.05,"k":0.0001,"h":0}. Finite prospective judgment, not observed throughput or confidence limits.

Favorable joint judgment stress: Cost: $4.0M; USA QALYs: 30.688948725728153; all-population QALYs: 30.998938106796114. {"N":1000000,"dp":0.3,"a":0.5,"b":0.75,"e":0.95,"t":0.25,"g":0.99,"p":0.6,"k":0.002,"h":0.000005}. Finite prospective judgment, not observed throughput or confidence limits.

No additional net health: Cost: $4.0M; USA QALYs: 0; all-population QALYs: 0. No incremental implementation or no clinical benefit; no incremental harm.

Illustrative net health loss: Cost: $4.0M; USA QALYs: -1; all-population QALYs: -1. One net USA QALY lost through disruption, displaced care or adverse substitution; stress test, not an observed estimate.

Remaining portfolio health unpriced: Cost: $4.0M; USA QALYs: unknown; all-population QALYs: unknown. Other non-overlapping pathways could add or subtract health; no invented portfolio uplift.

Counterfactual: d0 is exposure with existing laws, supplier plans, competitors, consumer pressure and other enforcement but without the incremental supported CEH work. N is unique users/worker-years, not market share times population. Already committed reformulation receives no automatic marginal credit.

Attribution: a separates CEH's contribution from public agencies, partner groups, litigation counsel and manufacturers; b adjusts donation replacement by legal recoveries, reserves, grants and other donors. Court settlement may be strong evidence of a mechanism without identifying the incremental donor effect.

This is an extremely uncertain but genuine best-judgment partial-health estimate. No primary study identifies a BPS-to-QALY slope: p and k explicitly encode a small clinical-benefit prior, and harm can dominate. Wider or zero priors are reasonable. The estimate is not a statistically calibrated expectation, safety certification or measured CEH effect.

Sensitivity

  • At 10,000 / 100,000 / 1,000,000 net additional USA worker-years, k required for $1 million per 10 is .0040451 / .00040451 / .000040451; multiply by ten for $100 thousand per 10.
  • If only 10% of a gross exposure cohort is additional after donor, manufacturer and partner counterfactuals, required per-worker health gain rises tenfold.
  • Using 2022–24 mean expense instead of latest annual expense raises both frontier requirements by about 20.4%.
  • Any positive net harm H adds one-for-one to required USA QALYs. Substitution is not assumed harmless merely because a listed chemical disappears.
  • Illustrative dermatitis branch: at .02 QALY per prevented episode (judgment, not measured here), 2,023 / 20,226 net additional USA episodes would be needed for $1 million / $100 thousand per 10; chromium-regulation evidence does not establish those episode counts.
  • Receipt transition expected by Dec2026 limits the defensible acceleration horizon; post-transition monitoring must show prevented relapse/noncompliance or new cases rather than reuse the original historic win.

Unresolved inputs

  • Verified current enforcement/implementation portfolio and next-dollar spending, with fee-recovery and donor replacement.
  • Clinical dose-response and QALY consequences for actual receipt BPS/substitute exposures; alternatively a complete validated lead, chromium or pollution-remediation pathway.
  • Incremental quantities sold/used, worker/consumer exposures and duration versus existing supplier/legal changes.
  • Outcome-weighted USA share, repeated users and cross-chemical/outcome double counting; net replacement and social-resource harms.
  • Current compliance and post-reformulation exposure evidence. Court entry on August 11, 2026 is verified; implementation and actual nationwide spillovers are not.

5. Funding and previous grants

The 2024 return reports $3.82 million revenue, including $1.71 million in awards and settlements; net assets were $3.47 million, with $2.20 million unrestricted. Cash was $1.38 million and investments $2.59 million, but liabilities and restrictions prevent treating all assets as available expansion funding. Return Operating scale fell relative to 2022–2023. The official finance page still lists 2023 as its newest audit, while the IRS provides the newer 2024 return. Financials

Legal recoveries can help fund enforcement but can also replace donations. Payments to outside attorneys and corporate compliance expenditures are not all included in CEH's own expense, so this is not a full social-resource model. A current case-development or compliance-monitoring plan with unfunded costs would improve next-dollar assessment.

The Domtar document records the defendant's assertion that reformulation efforts began in early 2024, before it was added to the case in July 2025, and an expectation of nationwide phenol-free offerings by December 2026. These are assertions and commitments, not a proven no-CEH counterfactual; nevertheless, new donations cannot simply receive credit for all of that transition. Incremental enforcement, acceleration or future cases must be specified. Primary settlement text

Annual expenses

Organization-level spending, including programs, administration and fundraising. The research list averages three comparable, consecutive full fiscal years when available.

  • FY 2022: $5.4M; Center for Environmental Health, EIN 94-3251981, 12-month period, Accrual Form 990 full recipient expense, including investment management fees. Source
  • FY 2023: $5.1M; Center for Environmental Health, EIN 94-3251981, 12-month period, Accrual Form 990 full recipient expense, including investment management fees. Source
  • FY 2024: $4.0M; Center for Environmental Health, EIN 94-3251981, 12-month period, Accrual Form 990 full recipient expense, including investment management fees. Source

6. Sources

  1. 2024 original Form 990, Parts I, III, VIII–XII. Center for Environmental Health / IRS, hosted by ProPublica. Published: not stated; retrieved: 2026-09-14.
  2. 2023 original Form 990. Center for Environmental Health / IRS, hosted by ProPublica. Published: not stated; retrieved: 2026-09-14.
  3. 2022 original Form 990. Center for Environmental Health / IRS, hosted by ProPublica. Published: not stated; retrieved: 2026-09-14.
  4. 2023 audited financial statements with 2022 comparatives. Center for Environmental Health / Crosby & Kaneda. Published: not stated; retrieved: 2026-09-14.
  5. Financial disclosure index. Center for Environmental Health. Published: not stated; retrieved: 2026-09-14.
  6. 2024 annual report. Center for Environmental Health. Published: not stated; retrieved: 2026-09-14.
  7. Receipt-paper settlement announcement. Center for Environmental Health. Published: 2026-08-19; retrieved: 2026-09-14.
  8. Corrected proposed amended consent judgment, New Receiptco Opco (Domtar), sections 1–4. California DOJ settlement registry / parties to CGC-25-623997. Published: 2026-07-15; retrieved: 2026-09-14.
  9. Prop65 notice 2025-01392, settlement registry. California Department of Justice. Published: not stated; retrieved: 2026-09-14.
  10. Trends in NHANES Biomonitored Exposures following Proposition 65. Knox et al. / Environmental Health Perspectives. Published: 2024-10-21; retrieved: 2026-09-14.
  11. Bisphenol A, Bisphenol S, and BPSIP in Urine and Blood of Cashiers. Thayer et al. / Environmental Health Perspectives. Published: not stated; retrieved: 2026-09-14.
  12. Receipt-handling exposure research final report. NIOSH-funded research / CDC Stacks. Published: not stated; retrieved: 2026-09-14.
  13. Trends in Contact Allergy to Chromium Following the 2015 EU Leather Regulation. Kursawe Larsen et al. / Contact Dermatitis. Published: not stated; retrieved: 2026-09-14.
  14. Filed amended consent judgment, New Receiptco Opco (Domtar), CGC-25-623997. San Francisco Superior Court / California DOJ. Published: 2026-08-11; retrieved: 2026-09-14.