Stone 2012 — WA Ecology QAPP for parabens and nine metals in children’s cosmetic and personal care products (WSDOE 12-07-021)

This is the formal Quality Assurance Project Plan (QAPP) issued by the Washington State Department of Ecology’s Hazardous Waste and Toxics Reduction (HWTR) Program and Waste 2 Resources (W2R) Program (Stone 2012, Publication 12-07-021, February 2012) to scope a planned product-testing programme of parabens (four esters) and nine potentially hazardous metals — antimony (Sb), arsenic (tAs), cadmium (Cd), cobalt (Co), copper (Cu), lead (Pb), mercury (tHg), molybdenum (Mo), and zinc (Zn) — in children’s cosmetic and personal care products purchased from Washington retailers. The study was authorised in response to the upcoming Children’s Safe Product Act (CSPA, Chapter 70.240 RCW, passed 2008) Reporting Rule (finalised June 2011, with manufacturer reporting beginning August 2012 for the largest manufacturers of Tier 1 children’s products), and funded by the Washington State Attorney General’s Office. Six of the nine metals (Sb, tAs, Cd, Co, Mo, tHg) are CSPA Chemicals of High Concern to Children (CHCC). Lead is included because it is regulated under federal Consumer Product Safety Commission (CPSC) 16 C.F.R. § 1303 surface-coating restrictions for children’s products and was part of the original CSPA. Copper and zinc are included because of Puget Sound water-quality concerns (Ecology 2011 toxic-chemical assessment).

This QAPP contains no original analytical measurement data. Its evidentiary contribution is (i) the documentary record of Washington State practical quantitation limits (PQLs) and federal CPSC action levels for the targeted metals (Table 1, p. 8–9); (ii) the planned analytical procedures including portable XRF screening (Niton XL3t with EPA SW-846 Method 6200 / ASTM F2617-08 adaptations) and laboratory confirmation (EPA Method 3052 microwave digestion followed by EPA Method 6020 ICP-MS for nine metals; cold-vapour atomic absorption (CVAA) for mercury; HPLC-MS for parabens, Tables 5 and 6, p. 12–13); (iii) the planned measurement quality objectives, including laboratory-control-sample recoveries (85–115 % for metals; 70–130 % for parabens), matrix-spike recoveries (75–125 %), duplicate relative percent difference (±20 %), and method-blank limits (Table 8, p. 14); and (iv) the project budget ($45,500 total for 100 paraben analyses, 50 metals analyses, and sample collection). Eventual measurement data from the planned procurement is reported separately in stone2021-wa-metals-childrens-consumer-products (Publication 14-04-014, Revised June 2021) and in the related Phase 1 and Phase 2 chemicals-in-cosmetics reports.

Key numbers

Project scope (Abstract p. 4; Project Description p. 7)

• Planned procurement: approximately 200 children’s cosmetic and personal care products over two sampling events (spring 2012; after 1 August 2012).
• Planned laboratory metals analysis: approximately 50 component or product samples, budget allowing (Sampling Process Design p. 7).
• Planned paraben analysis: approximately 100 samples, budget allowing.
• Funding: Washington State Attorney General’s Office (Abstract p. 4).

Target analytes — metals (Table 1, p. 8–9; CSPA + federal benchmarks)

The nine metals targeted are antimony, arsenic, cadmium, cobalt, copper, lead, mercury, molybdenum, and zinc. Six (Sb, tAs, Cd, Co, Mo, tHg) are CSPA Chemicals of High Concern to Children. Lead, copper, and zinc are additions: lead under federal CPSC 16 C.F.R. § 1303 surface-coating restrictions, and copper / zinc under Puget Sound water-quality concerns (Ecology 2011).

Washington State practical quantitation limits and federal CPSC action levels documented in Table 1:

The State PQLs are drawn from the CSPA Rule Reporting Guidance (http://www.ecy.wa.gov/programs/swfa/cspa/pdf/cspaguide_pql.pdf, accessed 3 January 2012). The CPSC values shown for Sb, tAs, Cd, and tHg are ASTM F963-11 Standard Consumer Safety Specification for Toy Safety action levels and apply to soluble portions of surface coatings (i.e., they are leachate-based toy criteria, not total-metal cosmetic-impurity limits). The CPSC 16 C.F.R. § 1303 lead value (90 ppm) applies to surface coatings of consumer goods and children’s products, with non-soluble portions limited to 100 ppm as of August 2011 (Table 1 footnotes p. 9).

Target analytes — parabens (Table 2, p. 9)

Four paraben esters of para-hydroxybenzoic acid (CAS 99-96-7):

• Methyl paraben (CAS 99-76-3)
• Ethyl paraben (CAS 120-47-8)
• n-Propyl paraben (CAS 94-13-3)
• Butyl paraben — two isomers reported separately:
  • n-Butyl paraben (CAS 94-26-8)
  • iso-Butyl paraben (CAS 4247-02-3)

The European Union identified all four parabens on Washington’s Chemicals of High Concern to Children (CHCC) list as Category 1 potential endocrine disruptors (Stone and Delistraty 2010); the parabens listing on the CHCC list pre-dated REACH and is the subject of ongoing EU re-evaluation (Background p. 5–6).

Niton XL3t portable XRF screening limits (Table 5, p. 12)

XRF screening was conducted with a Niton XL3t portable XRF following ASTM F2617-08 (Standard Test Method for Identification and Quantification of Cr, Br, Cd, Hg, and Pb in Polymeric Material Using Energy Dispersive X-Ray Spectrometry) and EPA SW-846 Method 6200 (Field Portable X-Ray Fluorescence Spectrometry for the Determination of Elemental Concentrations in Soil and Sediment), with adaptations for cosmetic and personal-care-product matrices. LOQs (polyethylene blank, 8 mm aperture, 180-second total analysis time) per Table 5:

XRF readings were planned for at least 30 seconds on smooth (or near-smooth) areas at least 2 mm thick; items thinner than 2 mm were to be folded onto themselves until 2 mm depth was reached. A second longer measurement (up to 180 seconds) was planned for any screening reading that violated criteria (Analytical Procedures p. 11–12).

Laboratory reporting limits and methods (Table 6, p. 13)

EPA Method 3052 (microwave-assisted acid digestion) was selected to achieve complete dissolution of plastic matrices; the QAPP notes that hydrofluoric acid is not necessary for most plastic matrices and is not recommended, and that nitric and/or hydrochloric acids are adequate (Table 6 footnote, p. 13). The metals reporting limit of 1.0 ppm was set by raising soil-method reporting limits by a factor of 10 (Table 8 footnote, p. 14). The mercury reporting limit (0.1 ppm) is tighter because of the State PQL at 0.5 ppm.

Measurement quality objectives (Table 8, p. 14)

XRF screening was used as a screening tool only, with no measurement quality objectives outlined for screening data; XRF efficacy as a metals screening tool was previously demonstrated in Ecology Publication 12-03-009 (Measurement Quality Objectives p. 14).

Quality control tests (Table 9, p. 15)

For metals and parabens, planned QC tests were one per batch each of: laboratory control sample, matrix spike, matrix-spike duplicate, laboratory duplicate, split duplicate (sample-availability dependent), and method blank. Surrogate recovery was specified only for PBDEs and is not relevant to the metals or paraben targets of this QAPP.

Sample collection and preparation (p. 11)

• All field and laboratory staff handling products were to wear powder-free nitrile gloves.
• Stainless steel implements were to be cleaned in sequence: hot water scrub with Liquinox soap, 10 % nitric acid rinse, deionised water rinse.
• Products were to be separated into three fractions: (1) packaging (retained for analysis under a separate QAPP under Washington’s toxics-in-packaging legislation, Chapter 70.95G RCW; not covered under CSPA), (2) cosmetic or personal care product contents, (3) the container holding the product. Fractions 2 and 3 were to be XRF-screened; components with appreciable metals were to be sent to Manchester Environmental Laboratory (MEL) for confirmatory ICP-MS / CVAA analysis. Fraction 2 (product contents) samples were to be sent to a contract laboratory for paraben analysis (State Contract 1807).

Project budget (Table 7, p. 13)

Organisation and schedule (Tables 3–4, p. 10)

• Project Manager (author): Alex Stone, Senior Chemist, HWTR-HQ. Writes the QAPP, oversees field sampling and transport to the laboratory, conducts QA review of data, analyses and interprets data, writes the draft and final reports.
• Section Manager (Project Manager): Ken Zarker, HWTR-HQ. Reviews and approves the QAPP.
• Section Manager (Clients): Carol Kraege, W2R.
• Clients: Joshua Grice and John Williams, W2R Program. Provide internal review and approve the final QAPP.
• HWTR Quality Assurance Officer: Samuel Iwenofu, HWTR-SWRO. Reviews and approves the QAPP.
• Planned schedule: Fieldwork complete March 2012; laboratory analyses complete June 2012; draft to supervisor September 2012; draft to client/peer reviewer October 2012; final (all reviews done) November 2012; final report due on web January 2013.

Regulatory context cited

• Children’s Safe Product Act (CSPA), Chapter 70.240 RCW (passed 2008; Reporting Rule finalised June 2011; manufacturer reporting begins August 2012). Requires manufacturers to report the presence of six toxic metals (Sb, tAs, Cd, Co, Mo, tHg) in all components of children’s products, including cosmetics and the containers holding them. Lead is included in this QAPP because it is part of the original CSPA and is now regulated by CPSC under 16 C.F.R. § 1303 (p. 6).
• CSPA tiered reporting structure (p. 8): Tier 1 = products intended to be put in a child’s mouth, applied to skin, or any mouthable product for a child under three (highest priority). Tiers 2–4 = products with prolonged direct skin contact, short-duration direct skin contact, and no intended skin contact, respectively. The QAPP restricts product analysis to Tier 1 unless sufficient samples cannot be obtained.
• Federal Consumer Product Safety Commission (CPSC) 16 C.F.R. § 1303 — lead in surface coatings of consumer goods and children’s products: 90 ppm (non-soluble portions limited to 100 ppm August 2011).
• CPSC ASTM F963-11 — Standard Consumer Safety Specification for Toy Safety (federal action levels for Sb, tAs, Cd, tHg in toy surface coatings; leachate-based).
• Washington’s toxics-in-packaging legislation, Chapter 70.95G RCW — restricts the sum of Hg, Cd, Pb, and Cr-VI to 100 ppm in packaging (cross-referenced in the QAPP for the packaging fraction analysed under a separate QAPP).
• REACH Regulation (EC) No. 1907/2006 — referenced as the framework under which EU CHCC paraben listings are being re-evaluated (Background p. 5–6).

Companion QAPPs (Ecology 2012a–d in the final report)

This QAPP (Publication 12-07-021) is one of four parallel QAPPs that scoped the children’s-product testing programme reported in stone2021-wa-metals-childrens-consumer-products (Publication 14-04-014, Revised 2021). The other three QAPPs (parabens / phthalates / VOCs / formaldehyde / packaging analytes) are cited collectively as ‘Ecology 2012a–d’ in the final report. This document is the parabens-and-metals QAPP component of that set.

Methods (brief)

This is a regulatory programme planning document; it produces no original analytical data. The methods specified are forward-looking (what would be done) rather than retrospective (what was done). The substantive methodological prescriptions in the QAPP are:

• Two-stage analytical workflow. Step 1: portable XRF screening of all product, product-content, and container components using a Niton XL3t (or equivalent) following ASTM F2617-08 for polymeric materials and EPA SW-846 Method 6200 for soil/sediment matrices, adapted for cosmetic and personal care product matrices. Components with appreciable metals concentrations (defined as ≥ 50 % of the State PQL action level for that metal) were to advance to laboratory confirmatory analysis. Step 2: laboratory analysis at Manchester Environmental Laboratory (MEL) using EPA Method 3052 microwave-assisted acid digestion (nitric and/or hydrochloric acids; no hydrofluoric acid for most plastic matrices) followed by EPA Method 6020 ICP-MS for all nine metals, with cold-vapour atomic absorption (CVAA) as an alternative for mercury.
• Paraben analysis. Samples selected by product label or product-database evidence of likely paraben content were to be sent to a contract laboratory under State Contract 1807 for HPLC-MS analysis at a reporting limit of 30.0 ppm. The HPLC-MS method and extraction protocol were to be approved by the Project Manager.
• Quality control regime. Per-batch laboratory control samples, matrix spikes, matrix-spike duplicates, laboratory duplicates, split duplicates, and method blanks; documented MQO acceptance windows (85–115 % LCS recovery for metals; 70–130 % for parabens; 75–125 % matrix-spike recovery; ±20 % RPD for duplicates; method blanks ≤ 1.0 ppm for nine metals, ≤ 0.1 ppm for mercury, ≤ 30.0 ppm for parabens). XRF data were screening-only with no quality objectives.
• Sample preparation discipline. Components separated using pre-cleaned stainless-steel tools (hot water + Liquinox soap, 10 % nitric acid rinse, deionised water rinse); operators wearing powder-free nitrile gloves; per-product photo and descriptive notes documenting product presentation and intended age group; separation into three fractions (packaging, product contents, container) for separate analytical workflows.
• Data verification. Project Manager review of all laboratory data packages including case narratives, calibration data, matrix-spike recoveries, internal standard recoveries, ion abundance ratios, duplicates, laboratory control samples, and data qualifier appropriateness. MEL and any contract laboratory data verification reports based on these reviews.

The methods specified in this QAPP closely match those reported as ‘as conducted’ in the eventual published 14-04-014 report (see stone2021-wa-metals-childrens-consumer-products) and were carried forward into the later Phase 1 and Phase 2 chemicals-in-cosmetics studies at waecology2023-chemicals-cosmetics-phase1 and waecology2024-chemicals-cosmetics-phase2.

Evidence Fitness

This is an A-tier US-state-government regulatory programme planning document — the formal Quality Assurance Project Plan authored by the responsible Senior Chemist at the Washington State Department of Ecology HWTR-HQ Program and approved by the Section Manager, the Clients (W2R Program), and the HWTR Quality Assurance Officer. The document is binding on the agency for the design and execution of the planned product-testing programme. Evidence the QAPP supports:

• Documentary record of the regulatory action-level framework Washington applied to children’s cosmetic and personal care product testing in 2012, including (i) the six CSPA Chemicals of High Concern to Children for metals (Sb, tAs, Cd, Co, Mo, tHg), (ii) the additional inclusion of Pb (federal CPSC overlap), Cu and Zn (Puget Sound water-quality concerns), (iii) the WA State PQL action levels of 0.5–1.0 ppm for all CSPA CHCC metals, and (iv) the federal CPSC ASTM F963-11 action levels (Sb 60, tAs 25, Cd 75, tHg 60 ppm) and CPSC 16 C.F.R. § 1303 surface-coating lead value (90 ppm; non-soluble portions ≤ 100 ppm) cited in the QAPP as comparison benchmarks.
• The planned two-stage analytical workflow (XRF screening then ICP-MS / CVAA confirmation) subsequently executed in the 14-04-014 final report and in the Phase 1 and Phase 2 chemicals-in-cosmetics reports.
• The documented measurement quality objectives (85–115 % LCS recovery; 75–125 % matrix-spike recovery; ±20 % RPD; method blanks ≤ 1.0 ppm metals, ≤ 0.1 ppm Hg, ≤ 30.0 ppm parabens) applied to subsequent measurement reports.
• The CSPA Reporting Rule context (Tier 1 prioritisation rule; manufacturer reporting begins August 2012 for the largest manufacturers of products intended for mouth or skin contact or any mouthable product for a child under three; phased schedule for other manufacturers).
• The portable XRF LOQs documented for a Niton XL3t (Sb 25, tAs 3, Cd 15, Co 15, Cu 15, Pb 4, tHg 6, Zn 15 ppm; Cr and Mo manufacturer-unspecified) at 180-second total analysis time on an 8 mm aperture with polyethylene blank.

The QAPP does NOT support:

• Any product-testing occurrence data. No samples were analysed within this document; the planned procurement and analytical work were carried out separately and reported in 14-04-014 and the Phase 1 / Phase 2 reports.
• A safety-based threshold determination for cosmetic Sb / tAs / Cd / Co / Cu / Pb / tHg / Mo / Zn exposure. The State PQL action levels documented in Table 1 are CSPA Reporting Rule practical-quantitation thresholds, not toxicologically derived exposure limits.
• A determination on whether the ASTM F963-11 toy-safety leachate-based limits should apply to cosmetics. The QAPP notes (p. 9) that the ASTM F963-11 and 16 C.F.R. § 1303 criteria are designed for soluble portions of surface coatings and that “XRF screening, however, is for total metals” — the document records that the leachate-vs-total mismatch was acknowledged at the planning stage. Reporting against the F963-11 / 16 C.F.R. § 1303 totals was a screening-comparison choice, not a determination of regulatory applicability.
• EU CHCC paraben endocrine-disruption listings as a settled finding. The QAPP cites Stone and Delistraty (2010) for the EU Category 1 endocrine-disruptor listing and notes (p. 5) that this listing pre-dated REACH and is currently being re-evaluated; the QAPP frames the parabens analysis as compliance-evaluation rather than as a definitive endocrine-disruption study.

Implications

• Certification. This QAPP is the regulatory-design documentary anchor for the Washington 2012 children’s cosmetic and personal care product testing programme; it establishes the State PQL action levels (0.5–1.0 ppm for the CHCC metals) and the federal benchmark comparison values used in the subsequent measurement reports. For any HMTc threshold-setting workflow concerning children’s cosmetic / personal care product Pb / Cd / tAs / tHg / Sb / Co / Mo / Cu / Zn, the action levels documented here are CSPA practical-quantitation thresholds rather than health-based exposure limits and should be treated as regulatory-context data rather than as a literature-baseline percentile input. The eventual measurement data from this planning programme is reported at stone2021-wa-metals-childrens-consumer-products and the Phase 1 / Phase 2 reports; those measurement reports are the appropriate sources for downstream pooling.
• Courses. A clear worked example of a US-state-agency QAPP linking a state statutory framework (CSPA Reporting Rule, Chapter 70.240 RCW) to a two-stage analytical workflow (XRF screening with documented LOQs, then ICP-MS / CVAA confirmation with documented MQOs) and to overlapping federal benchmarks (CPSC ASTM F963-11 toy-safety leachate criteria; CPSC 16 C.F.R. § 1303 surface-coating Pb). Useful for teaching how XRF total-metals screening criteria are reconciled (or noted not to be reconciled) with federal leachate-based regulatory criteria, and how an agency-approved QAPP shapes the eventual measurement programme.
• App. Not directly relevant to a future cosmetics-app contamination-profile workflow; the QAPP contains no occurrence data. The downstream measurement reports (14-04-014; Phase 1; Phase 2) are the operative occurrence-data sources.

Wiki pages this source may touch

• antimony — CSPA CHCC metal; State PQL 1.0 ppm; federal CPSC ASTM F963-11 toy action level 60 ppm cited as comparison benchmark.
• arsenic-total — CSPA CHCC metal; State PQL 1.0 ppm; federal CPSC ASTM F963-11 toy action level 25 ppm cited as comparison benchmark.
• cadmium — CSPA CHCC metal; State PQL 1.0 ppm; federal CPSC ASTM F963-11 toy action level 75 ppm cited as comparison benchmark.
• cobalt — CSPA CHCC metal; State PQL 1.0 ppm; no federal benchmark cited.
• copper — added to the QAPP scope because of Puget Sound water-quality concerns; no State PQL or federal action level cited.
• lead — federal CPSC 16 C.F.R. § 1303 surface-coating limit 90 ppm; non-soluble portions ≤ 100 ppm as of August 2011; not a CSPA-reportable analyte at the time of this QAPP but included because of federal-regulatory overlap.
• mercury-total — CSPA CHCC metal; State PQL 0.5 ppm; federal CPSC ASTM F963-11 toy action level 60 ppm cited as comparison benchmark.
• molybdenum — CSPA CHCC metal; State PQL 1.0 ppm; no federal benchmark cited.
• zinc — added to the QAPP scope because of Puget Sound water-quality concerns; no State PQL or federal action level cited.
• children-personal-care — umbrella scope for the planned procurement.
• childrens-makeup — CSPA Tier 1 children’s cosmetic targeted by the planned procurement.
• childrens-lip-balm-plain — children’s cosmetic targeted by the planned procurement.
• childrens-lip-balm-mineral-bearing — children’s cosmetic targeted by the planned procurement.
• childrens-nail-polish — children’s cosmetic targeted by the planned procurement.
• face-paint — children’s cosmetic targeted by the planned procurement (mouthable per CSPA Tier 1).
• baby-lotion-cream — children’s personal care targeted by the planned procurement.
• baby-shampoo-body-wash — children’s personal care targeted by the planned procurement.
• baby-oil — children’s personal care targeted by the planned procurement.
• stone2021-wa-metals-childrens-consumer-products — the downstream final report (Publication 14-04-014, Revised 2021) carrying the measurement data planned by this QAPP, citing ‘Ecology 2012a–d’ as the four parallel QAPPs.
• waecology2023-chemicals-cosmetics-phase1 — subsequent Washington chemicals-in-cosmetics report using the same XRF-then-ICP-MS workflow scaffold.
• waecology2024-chemicals-cosmetics-phase2 — subsequent Washington chemicals-in-cosmetics report (Phase 2) using the same workflow scaffold.
• waecology2024-interim-policy-lead-cosmetics — Washington Toxic-Free Cosmetics Act interim policy on lead in cosmetics (operative from 2025); regulatory framework that supersedes the CSPA-only context of this 2012 QAPP for cosmetic lead impurities specifically.

Verification notes

Ingested 2026-06-02 by Claude Opus 4.7 from raw/Manual Fetch Kimi /June 1 Infant cosmetics metals papers/02_Regulatory_Reports/REG-015_WA_Ecology_2012_QAPP_Parabens_Metals_Childrens_Cosmetics.pdf (SHA-256 5b1d4a91…8cff9; 420 KB; 20 pages). Source-page numbers (Abstract p. 4, Background p. 5–6, Project Description p. 7, Sampling Process Design p. 7–9, Tables 1–9 p. 8–15, References p. 17–18, Appendices p. 19–20) verified against the PDF. Cross-referenced stone2021-wa-metals-childrens-consumer-products (Publication 14-04-014, Revised 2021) which cites this QAPP as one of the ‘Ecology 2012a–d’ planning documents.

The QAPP discusses the parabens analytical workflow (HPLC-MS at 30.0 ppm RL) but the parabens findings are out of scope for Heavy Metal Index; only the metals workflow is reflected in the metals: frontmatter. Parabens are retained in the body as context because the QAPP is a single QA-approved planning document covering both analytical streams and the parabens analysis shares the same sample-collection and product-selection design.

Per Part 12 brand-firewall discipline: no manufacturer or brand names are reported in the QAPP body (the document is forward-looking and identifies only categorical product types and the contract-laboratory framework). The QAPP explicitly states on p. 15 (under Report) that “categorical descriptions of the products screened with the XRF (i.e., brands, product names, etc. will not be included)” in the eventual measurement report, which is consistent with the wiki’s brand-firewall approach. Per Part 14 speciation conventions: arsenic and mercury are reported as totals throughout the QAPP (tAs and tHg in HMI vocabulary) because the analytical method (EPA 3052 microwave digestion followed by EPA 6020 ICP-MS) yields total metals; the QAPP does not perform iAs / MeHg speciation. Per the scientific-method vendor/material exception to Part 12 (locked 2026-05-17): the Niton XL3t XRF analyser model, EPA Method 3052, EPA Method 6020, ASTM F2617-08, ASTM F963-11, CPSC 16 C.F.R. § 1303, and the Liquinox detergent are retained as method-vendor/material identifiers necessary for scientific reproducibility.

Audit notes (Claude audit subagent, 2026-06-02):

• ✅ Audit verdict PROMOTE. All five checks clean. Two non-blocking ⚠️ polish suggestions verified against the source and applied here for full forensic traceability.
• PDF Table 6 footnote (‘Method 3025’ → ‘EPA Method 3052’). The Table 6 footnote on PDF p. 13 literally reads “Method 3025 provides complete digestion of the plastic matrix that allows the most representative numbers for total metals. Use of hydrofluoric acid (HF) is not necessary for most plastic matrices and is not recommended. Nitric and/or hydrochloric acids as identified in the method are adequate to effect complete dissolution of most plastic matrices.” Every other reference in the QAPP (the body of Table 6 itself, Analytical Procedures p. 11–12, the Laboratory section p. 13) cites EPA Method 3052. The reference to “Method 3025” in the footnote is almost certainly a PDF typo for Method 3052 (microwave-assisted acid digestion); the wiki treats it as such, but the typo is noted here so a future reader cross-checking the wiki against the source PDF can reconcile the apparent discrepancy.
• PDF Abstract vs Tables 1 / 6 — chromium vs cadmium discrepancy. The PDF Abstract on p. 4 lists the nine metals as: Antimony, Arsenic, Chromium, Cobalt, Copper, Lead, Mercury, Molybdenum, Zinc (no cadmium). The PDF Background section (p. 6, “the 9 metals consist of the 6 potentially toxic metals in the CSPA (antimony, arsenic, cadmium, cobalt, molybdenum, and mercury) and copper, zinc and lead”) and the binding analytical scope in Tables 1 (p. 8) and 6 (p. 13) list: Sb, As, Cd, Co, Cu, Pb, Hg, Mo, Zn (no chromium). The wiki frontmatter metals: field and the Key numbers metals tables follow the binding analytical scope (Sb, tAs, Cd, Co, Cu, Pb, tHg, Mo, Zn). Chromium appears in the QAPP only as an XRF screening element in ASTM F2617-08 (the Niton XL3t reports Cr but its LOQ is “not specified by manufacturer”); Cr is not in EPA Method 6020 lab confirmation per Table 6. The Abstract listing of “Chromium” is a source-internal typo; the wiki correctly follows Tables 1 / 6 as the binding scope. Flagged here so a future reader cross-checking against the Abstract can reconcile.
• False-positive: matrices: [cosmetic-personal-care]. The audit subagent’s copy of the taxonomy snapshot did not include the matrices vocabulary (the snapshot lists only ingredients / products / metals / regulations). The cosmetic-personal-care matrix slug is in use across multiple already-audited-PROMOTE cosmetics sources, including waecology2023-chemicals-cosmetics-phase1, waecology2024-interim-policy-lead-cosmetics, and others; the slug is valid. False positive — no change required.

Page history

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