GiveBetter x USA

Toxic-Free Future

Chemical research, safer markets and public-policy advocacy

Research time: 12 min on GPT-6 Astra Light
  • Research — reviewed programs, finances and impact evidence.

Updated: 2026-09-14

Summary

What do they do? Toxic-Free Future combines product research, retailer pressure, Washington policy and national chemical-safety advocacy. Its current work includes defending federal protections and helping states and companies choose safer chemicals. A partial model of federal TCE and PFAS protections gives roughly $126 million per 10 USA QALYs, with very wide uncertainty and other recipient pathways still unpriced.

Why we’re interested in this organization:

  • A long-running mix of technical research, market campaigns and policy coordination can influence the same exposure pathway at several points.

  • Federal risk models provide explicit clinical outcomes, allowing a cautious numerical assessment beyond chemical quantities or campaign reach.

  • Current coalition activity and original recipient financial disclosures make scope and costs inspectable.

Our main reservations:

  • The numerical estimate covers two narrow branches; the remaining portfolio is unestimated, so this is not a reliable ranking of the entire recipient.

  • Future influence on implementation or rollback is subjective; existing laws, firms and many other advocates are important counterfactuals.

  • Chemical detection does not establish disease risk, and two corrections to a high-profile exposure example warrant careful quantitative review.

What do you get for your dollar? $125.8M per better life: ten additional quality-adjusted life years in USA. TCE and PFAS timing health only; other impacts unestimated.

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.

1. What do they do?

TFF runs Mind the Store, Washington's Toxic-Free Legacy work, the fiscally sponsored Safer States alliance and federal advocacy. The 2024 return records $0.52 million, $0.53 million, $0.90 million and $0.30 million of respective program expenses. The assessment includes all of them and support costs—not just the federal branch used in the numerical model. Original return

Retailer grading, product testing and technical comments are mechanisms for changing exposure, not health outcomes themselves. State product restrictions can influence national supply chains, but a Washington prohibition does not automatically cover every American. Retailer project State implementation

2. Monitoring and information sharing

In July 2026, TFF publicized a 250-organization letter organized by an alliance of more than 85 groups defending TSCA. This verifies active work and substantial partners, not a measured policy effect or an equal share of the result. Current coalition

The TCE rule is already in force. EPA describes postponed exemption conditions pending judicial review and specific extended deadlines, including nuclear-fuel processing and wastewater disposal; it also discusses enforcement priorities. A donor cannot receive credit for the entire original ban. Current EPA status

Track specific decisions at risk, alternative policy text, compliance dates, affected worker exposures and TFF's documented contribution. For market campaigns, verify actual formulations and sales, not simply promises or report-card scores. A prospective unfunded work plan is missing.

The higher-impact alternative is PFAS drinking-water implementation. EPA's May 2026 proposal would let eligible systems request two extra years, to 2031, while retaining PFOA/PFOS limits. It includes interim measures above 12 ppt; comments closed July 20. TFF and Safer States publicly opposed the proposal. Avoiding all long-term PFAS mortality is not the relevant counterfactual. EPA proposal status TFF response

3. Qualitative assessment

The TCE pathway has a real causal toxicology/risk-assessment bridge: the federal rule models avoided cancers. It is not an organization trial and remains sensitive to exposure estimates and future implementation. It does not quantify all non-cancer outcomes. The model below deliberately leaves other chemical benefits unpriced rather than assigning a health value to pounds removed. Final rule

Cancer survival varies substantially: current five-year relative survival is about 79% for kidney/renal-pelvis cancer, 74% for non-Hodgkin lymphoma and 22% for liver/intrahepatic-bile-duct cancer. These are not TCE-attributable case-mix estimates and are not lifetime fatality probabilities. They support a broad QALY judgment rather than treating every cancer as a death. Kidney Lymphoma Liver

TFF also has a concrete history campaigning against methylene-chloride paint strippers; EPA documents fatal acute poisonings. That is another credible pathway, but past fatalities and bans cannot simply be credited to a new donation. Campaign EPA

Scientific disclosure is a mixed signal. TFF acknowledged corrections in December 2024 and July 2025 to the exposure example in its black-plastics study, with the second lowering estimated utensil exposure. Product-contamination findings may remain meaningful, but the errors reinforce the need to check dose and clinical consequences independently. No black-plastic health benefit is counted here. Corrections

For PFAS, EPA models serum exposure, birth-weight effects, cardiovascular risk factors and renal cancer. Its summaries give approximately 1,300 developmental deaths, 3,700 cardiovascular deaths and 2,000 kidney-cancer deaths prevented over the long model horizon—not per year. I exclude bladder-cancer co-removal and nonfatal illness here. The original analysis spans 2024–2105; the delay proposal extends its comparison to 84 years. I halve the transported clinical yield and explicitly discount future timing; these are judgments, not EPA estimates. Native outcomes Clinical model

4. What do you get for your dollar?

Full 2024 expense is $2,689,041, including $209,491 management and $221,723 fundraising. The original return shows no netted fundraising-event or inventory expense requiring restoration. Comparable 2023 and 2022 totals are $2,790,134 and $2,298,941: a $2,592,705 mean. 2024 2023 2022

For a two-year support horizon, cost is $5.38 million. EPA's published rule figures imply about 4.16 potential cancer cases avoided per full-equivalent year of reduced exposure, averaged across its analytical period. The TCE-only central is 0.036 expected USA QALYs. Adding a separate PFAS timing branch gives 0.428 expected USA QALYs, or roughly $126 million per 10. The joint favorable scenario is about $581,000; zero benefit and net harm are also possible. These are judgment scenarios, not statistical confidence limits.

This is not a comprehensive valuation of TFF. Other chemicals, state policy, market effects and PFAS benefits beyond the specific delay branch could dominate; they are not adequately quantified. At this cost, $1 million or $100,000 per 10 would require 53.78 or 537.81 net USA QALYs across the portfolio. The combined partial model does not meet those thresholds centrally.

The PFAS calculation credits only the present-value difference between an earlier and a two-year-later health stream, not the entire regulation. Its central contribution is about 0.392 USA QALYs, dominated by subjective policy influence, actual delay avoided and clinical transport. Neither EPA's monetized benefits nor an arbitrary dollar-to-QALY conversion enters the calculation.

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.

Model, assumptions and sensitivity

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.

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.

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.

C
5378082 USD, two full annual recipient budgets (judgment). Judgment extrapolation to two years at the observed annual recipient expense: 2×2024 total expense; two-year support horizon is judgment. [tff-99024]
F
4.162337662337662 potential cancers avoided per full-equivalent exposure year (observed). 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. [tff-tce-rule]
m
1 clinical/exposure model transport multiplier (judgment). Central retains EPA average; .5–2 scenario tests risk/implementation variation. Future affected uses may differ. [tff-tce-rule] [tff-tce-status]
q
3 discounted QALYs per potential cancer case prevented (judgment). 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. [tff-kidney] [tff-nhl] [tff-liver]
T
5 full-equivalent future exposure years (judgment). Count a bounded policy-persistence horizon, not indefinite benefits.2–10 scenarios. [tff-tce-status]
r
0.03 annual QALY discount rate (judgment). Discount future exposure years in addition to latency already incorporated in q.
e
0.025 expected coalition-preserved share of full-rule benefit (judgment). Equivalent to .10 incremental probability×.25 affected clinical scope. Existing ban and narrow current delays rule out credit for all original benefits. [tff-coalition26] [tff-tce-status]
a
0.05 TFF share of incremental coalition causal contribution (judgment). Coordination role warrants a positive but small judgment; not1/250 equal division and not sole credit. [tff-coalition26] [tff-victories25]
b
0.5 funding additionality (judgment). Reserve and donor replacement discount. No documented marginal funding gap. [tff-99024]
g
0.995 USA50states+DC resident health share (judgment). Domestic federal occupational scope, small exclusion allowance; not headquarters geography. [tff-tce-rule]
H
0 all-population QALYs of downside (judgment). Central0 is provisional, not measured safety; adverse scenario1, and positive H subtracts before geography.
otherPathways
null net QALYs from other recipient work (unknown). State/corporate work, other chemicals, non-cancer TCE, PFAS nonfatal and non-timing outcomes unpriced; no aggregate claim.
PFASDeaths
7000 modeled deaths over long original regulatory horizon (observed). Rounded1,300 developmental+3,700 cardiovascular+2,000 kidney deaths. EPA forecast, not annual counts or measured outcomes. Excludes2,600 bladder co-removal deaths. [tff-pfas-native] [tff-pfas-ea]
qi
25 QALYs per avoided developmental death at event date (judgment). Lifetime3%-discounted health of an infant; broad10–30 range. Not an EPA utility input. [tff-pfas-native]
qa
5 QALYs per avoided adult death at event date (judgment). Broad1–10 discounts age, competing mortality and health quality; not equal to all remaining years. [tff-pfas-native]
d
0.3 future-event present-value timing factor (judgment). 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. [tff-pfas-ea]
mp
0.5 PFAS clinical-model transport (judgment). Haircut for observational dose-risk links, risk-factor mediation and clinical transport; .1–1 range. Not scientific posterior probability. [tff-pfas-ea]
u
0.5 effective share of modeled two-year delay (judgment). 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. [tff-pfas-proposal]
pp
0.1 incremental probability of avoiding PFAS delay through coalition work (judgment). Active opposition to a live proposal supports considering an effect, not measuring it; .01–.3 scenarios with0 possible. [tff-pfas-response] [tff-pfas-status]
ap
0.03 TFF share of incremental PFAS coalition influence (judgment). Small share reflects national advocacy plus Safer States but many agencies, litigators and partners; .001–.1 range. [tff-pfas-response]

Partial TCE plus PFAS timing central: Cost: $5.4M; USA QALYs: 0.427528976206512; all-population QALYs: 0.4296773630216201. 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.

Favorable joint assumptions: Cost: $5.4M; USA QALYs: 92.52461187652189; all-population QALYs: 92.98955967489637. 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.

Weak marginal influence and clinical yield: Cost: $5.4M; USA QALYs: 0.0000030492603278519957; all-population QALYs: 0.0000030645832440723574. 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.

No additional policy effect: Cost: $5.4M; USA QALYs: 0; all-population QALYs: 0. 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.

Illustrative net policy/substitution harm: Cost: $5.4M; USA QALYs: -0.995; all-population QALYs: -1. 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.

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.

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.

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.

Unresolved inputs

  • 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.

5. Funding and previous grants

Revenue was $3.59 million in 2024, mostly contributions. Net assets were $4.88 million, including $3.18 million without donor restrictions. Cash and savings totaled $1.41 million, alongside $2.90 million publicly traded investments. These balances suggest financial resilience but do not establish additional hiring or unfunded implementation capacity. Return

The official finance index lists older returns and says audited statements are available on request; no outreach was undertaken. The newer original 2024 IRS return supplies the comparable recipient figures. Financials

Flexible donations may replace other donors or finance reserves, while advocacy partners and agencies provide complementary resources. The model discounts funding additionality rather than assuming every dollar expands effective work. Corporate compliance and public enforcement costs are outside the recipient budget; the analysis is not a social cost-benefit calculation. Essential-use and replacement-material risks may create health downsides, which must not be erased by calling all regulation beneficial.

EPA itself flags that assuming all systems use the PFAS exemption can overstate delay: some will treat early because of state rules, customer demand or existing plans. Interim filters, real construction bottlenecks, affordability and public technical assistance also matter. The model includes a further 50% effective-delay allowance, with zero-effect and harm scenarios. Proposal analysis

Annual expenses

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

  • FY 2022: $2.3M; Toxic-Free Future, EIN 91-1214158, 12-month period, Accrual Form 990 full recipient expense; no netted event or inventory costs. Source
  • FY 2023: $2.8M; Toxic-Free Future, EIN 91-1214158, 12-month period, Accrual Form 990 full recipient expense; no netted event or inventory costs. Source
  • FY 2024: $2.7M; Toxic-Free Future, EIN 91-1214158, 12-month period, Accrual Form 990 full recipient expense; no netted event or inventory costs. Source

6. Sources

  1. 2024 original Form 990, Parts III and VIII–XII. Toxic-Free Future / IRS, hosted by ProPublica. Published: 2025-11-13; retrieved: 2026-09-14.
  2. 2023 original Form 990. Toxic-Free Future / IRS, hosted by ProPublica. Published: 2024-11-14; retrieved: 2026-09-14.
  3. 2022 original Form 990. Toxic-Free Future / IRS, hosted by ProPublica. Published: 2023-11-14; retrieved: 2026-09-14.
  4. Financial reports index. Toxic-Free Future. Published: not stated; retrieved: 2026-09-14.
  5. 2025 victories. Toxic-Free Future. Published: not stated; retrieved: 2026-09-14.
  6. 250 organizations urge Senate to preserve chemical safety protections. Toxic-Free Future / Alliance for Health and Safe Chemicals. Published: 2026-07-23; retrieved: 2026-09-14.
  7. Safer Products for Washington project, implementation and comments. Toxic-Free Future. Published: not stated; retrieved: 2026-09-14.
  8. Retailer Report Card. Toxic-Free Future. Published: not stated; retrieved: 2026-09-14.
  9. Two corrections to black-plastics exposure example. Toxic-Free Future. Published: 2025-07-03; retrieved: 2026-09-14.
  10. Final TCE rule, Federal Register 89 FR 102568, p102615. US Environmental Protection Agency / Government Publishing Office. Published: 2024-12-17; retrieved: 2026-09-14.
  11. Current TCE risk management and compliance status. US Environmental Protection Agency. Published: 2026-05-05; retrieved: 2026-09-14.
  12. Kidney and renal pelvis cancer statistics, 2016–2022 survival. National Cancer Institute SEER. Published: not stated; retrieved: 2026-09-14.
  13. Non-Hodgkin lymphoma statistics, 2016–2022 survival. National Cancer Institute SEER. Published: not stated; retrieved: 2026-09-14.
  14. Liver and intrahepatic bile duct cancer statistics, 2016–2022 survival. National Cancer Institute SEER. Published: not stated; retrieved: 2026-09-14.
  15. Methylene chloride campaign history. Toxic-Free Future. Published: not stated; retrieved: 2026-09-14.
  16. Final ban on most methylene chloride uses. US Environmental Protection Agency. Published: 2024-04-30; retrieved: 2026-09-14.
  17. Proposed PFOA/PFOS extension rule, current status. US Environmental Protection Agency. Published: 2026-07-23; retrieved: 2026-09-14.
  18. 2026 compliance-extension proposal and counterfactual analysis. US Environmental Protection Agency / Federal Register. Published: 2026-05-20; retrieved: 2026-09-14.
  19. Response to proposed PFAS rule changes. Toxic-Free Future and Safer States. Published: 2026-05-18; retrieved: 2026-09-14.
  20. PFAS rule benefits and costs, Table3 native outcomes. US Environmental Protection Agency. Published: not stated; retrieved: 2026-09-14.
  21. Final PFAS economic analysis, clinical methods and2024–2105 horizon. US Environmental Protection Agency. Published: not stated; retrieved: 2026-09-14.