WA Ecology 2024 — Phase 2 testing of 9 ortho-phthalates in 40 nail polishes, unscented hair sprays, and unscented skin cleansing products; 6 asbestos-fiber types in 20 talc-containing powder blushes and eyeshadows from Puget Sound retailers

This is the Washington State Department of Ecology legislative report’s Phase 2 deliverable under ESSB 5693 (2022) Section 302(56), the same legislative directive that funded the Phase 1 heavy-metals and formaldehyde testing summarised in waecology2023-chemicals-cosmetics-phase1. Phase 2 reports two narrower-scope panels: nine ortho-phthalates in 40 products (20 nail polishes plus 20 unscented hair-care or skin-cleansing products) analysed at the Washington Department of Ecology Manchester Environmental Laboratory (MEL) by EPA Method 3580A extraction and EPA Method 8270E (GC-MS), and six regulated asbestos fibre types in 20 talc-containing powder cosmetics (10 blushes and 10 eyeshadow palettes) analysed at an external contract laboratory by X-ray diffraction (XRD), polarized light microscopy (PLM), and transmission electron microscopy (TEM) per EPA Method 600/R-93/116, ISO 22262-1 and 22262-2, and the USP talc monograph. No heavy metals were tested in Phase 2 — the heavy-metals panel (Pb, Cd, tAs) lives in the Phase 1 report. The principal Phase 2 findings are: diethyl phthalate (DEP) detected at 577 ppm in a single blueberry-scented nail art pen purchased at a Dollar Tree (1 of 40 phthalate samples, the other 39 products non-detect at 15–25 ppm reporting limits); and zero detections of any of the six regulated asbestos fibre types in any of the 20 powder cosmetics tested. The report frames both findings as evidence that fragrance-free and unscented cosmetics, and talc-containing powder cosmetics with disciplined raw-material sourcing, can be made without these contaminants.

Key numbers

Sampling and design

• n = 60 unique low-cost cosmetic products purchased December 2022 from four Puget Sound retail chains: 12 products from two Walmart locations, 16 from two Target locations, 20 from three Fred Meyer locations, and 12 from three Dollar Tree locations (Appendix A, Methods, Product collection, p. 13–14). No online purchases. Some products purchased in multiples to meet lab weight requirements; full product list with retailer, internal Ecology ID, product name, and category in Table A-2 (p. 14–15) for the phthalate panel and Table A-3 (p. 16) for the asbestos panel.
• Ortho-phthalates panel: n = 40 — 20 nail polish products (including nail polishes, nail lacquers, gel envy enamel, nail treatments/base-topcoats, a nail art pen, and a complete nail set; mostly adult-market), 7 fragrance-free or unscented hair sprays, and 13 fragrance-free or unscented skin cleansing products. The 13 cleansing products break down as 7 feminine hygiene washes (Daily Care Foam Wash, Cleanse Fragrance-Free Sensitive Wash, Fragrance-Free Daily Gentle Wash, Feminine Cleanser with Boric Acid, Fragrance-Free Cleansing Wash, Fragrance-Free pH Balancing Cleanser, Dye and Scent Free Feminine Cleansing Wash), 2 adult body washes (Unscented Sensitive Skin Body Wash, Fragrance-Free Skin Relief Body Wash), and 4 baby washes (Fragrance-Free Baby Body Wash & Shampoo, Fragrance-Free Premium Baby Shampoo & Wash, Derma Care Soothing Wash, Fragrance-Free Foaming Shampoo & Body Wash). All four baby washes were marketed as both fragrance-free and “phthalates-free.”
• Asbestos panel: n = 20 — 10 powder blushes and 10 powder eyeshadow products, all listing talc as an ingredient. One of the 10 eyeshadow products was a children’s variety cosmetics pack (WM-54-3, “Be Inspired Glitter Makeover Studio”) from which only the eyeshadow palettes were used; multiple eyeshadow colour palettes from this variety pack were combined into a single test sample to generate enough mass for analysis.

Methods (Appendix A p. 13, 16–18)

Ortho-phthalates (MEL, EPA methods). Sample preparation followed EPA Method 3580A (extraction); pressurized-container samples such as hair sprays were sprayed onto the wall of a tared sample vial with extraction solvent and allowed to condense to liquid before weighing and processing. Analysis followed EPA Method 8270E (GC-MS) for nine ortho-phthalates: di(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), diethyl phthalate (DEP), dihexyl phthalate (DHP), diisodecyl phthalate (DiDP), diisononyl phthalate (DiNP), dimethyl phthalate (DMP), dibutyl phthalate (DBP), and di-n-octyl phthalate (DnOP) (Table A-1, p. 13). All work performed at Manchester Environmental Laboratory (MEL), Washington Department of Ecology. Reporting limit range across the panel: 15 to 25 ppm, with individual reporting limits varying by matrix.

Asbestos (external contract laboratory). Sample preparation followed gravimetric protocols of EPA Method 600/R-93/116 (ashing to remove organics, then acid filtration of residue to remove soluble materials and carbonates). Prepared residues were split and analysed by three complementary methods: (a) X-ray diffraction (XRD) per EPA 600/R-93/116 supplemented by the USP talc monograph, used to qualitatively screen for serpentine and amphibole minerals; (b) polarized light microscopy (PLM) per the contract lab SOP developed against EPA 600/R-93/116, supplemented by ISO 22262-1 and 22262-2 and the USP talc monograph, used for qualitative characterization and semi-quantitative projected-area determination; and (c) transmission electron microscopy (TEM) per ISO 22262-2 fiber-counting strategy on calibrated index grids. TEM scanning protocol: at 20,000× magnification, 10 openings were scanned, counting all structures above 0.5 µm with aspect ratio >5:1; at 10,000× magnification, 25 different grid openings were analysed for all structures greater than 5 µm with aspect ratio >5:1. Morphology, quantitative energy-dispersive spectroscopy, and zone-axis indexing techniques per EPA 600/R-93/116 and ISO 22262-1 were used for chrysotile and amphibole identification. The six asbestos fibre types analysed are chrysotile (serpentine class) plus tremolite, amosite, crocidolite, anthophyllite, and actinolite (amphibole class) (Table A-1, p. 13). The report flags that the QAPP’s inter-analyst TEM-QC frequency requirement was 1/10 within this batch of 20 samples and was not formally met (the verified analysis on one sample conducted by a different analyst was accepted as satisfying one inter-analyst QC).

Sample handling (Appendix A p. 16). All nail polishes, hair-care products, and skin cleansing products were sent to MEL in their original unopened bottles to minimise atmospheric exposure; chain-of-custody (COC) records show MEL received all samples in good condition. All eye-shadow and blush samples for asbestos testing were processed into sample jars in a fume hood one day before being transported to the contract laboratory via FedEx; some eyeshadow products had multiple colour palettes combined into one sample to generate enough mass for analysis; the contract laboratory received all samples in good condition.

Data validation (Appendix A p. 18–19). Phthalates: stage 4 data validation on the level 4 ortho-phthalates data package; three extraction batches; surrogate standards added prior to extraction and internal standards added before analysis on all samples, batch QC samples, and instrument QC samples; method blanks each batch had no analytes above reporting limit; all measurement quality objectives met. Asbestos: level 4 data package from the contract lab presented to an external validator; XRD annotated diffraction patterns and reference-sample results validated to within EPA method specifications; PLM calibrations, alignments, and reference-sample analyses confirmed within specifications, with non-asbestos-fibre optical properties documented on bench sheets for verification; TEM QC targets at the contract lab include 10 % of total monthly TEM asbestos analyses (4 % inter-analyst, 2 % intra-analyst, 1 % verified, 3 % combination/blank/re-prep — all met); the QAPP-specified inter-analyst QC frequency of 1/10 within this 20-sample batch was not formally met (the verified analysis on one sample conducted by a different analyst was accepted as satisfying the single inter-analyst QC requirement), and multiple replicate analyses were also conducted on a sample where a suspected amphibole particle was found. Validators concluded data are usable for all purposes as reported, without qualifications, for both panels. The non-detect qualifier “U” indicates the analyte was not detected at the quantitation or reporting limit.

Ortho-phthalates results — nail polishes (n = 20)

One of 20 nail products had a detectable ortho-phthalate above the reporting limit. A blueberry-scented nail art pen purchased from a Dollar Tree (DT-33-3) tested at 577 ppm diethyl phthalate (DEP). The remaining 19 nail polish products had no detectable phthalates above the 15–25 ppm matrix-specific reporting limits. No ortho-phthalates with plasticizer function were detected in any of the 20 nail polishes (the DEP detection is attributed to a fragrance/solvent role, consistent with the blueberry-scent formulation). The report notes that Ecology’s prior product testing (Stone, 2014) detected DEP above 1000 ppm in scented nail polishes and perfumes; the present Phase 2 result is broadly consistent in direction (DEP in a scented nail product), at a lower magnitude.

Ortho-phthalates results — unscented hair sprays (n = 7)

0 of 7 unscented or fragrance-free hair sprays had any of the nine ortho-phthalates detected above the reporting limit. All seven were marketed as unscented and did not list fragrance or parfum as an ingredient.

Ortho-phthalates results — unscented skin cleansing products (n = 13)

0 of 13 unscented or fragrance-free skin cleansing products had any of the nine ortho-phthalates detected above the reporting limit. Subgroup detail:

• 7 feminine hygiene washes: 0 detect.
• 2 adult body washes: 0 detect.
• 4 baby washes: 0 detect; all four were marketed as both fragrance-free and “phthalates-free.”

Ortho-phthalates summary across n = 40

• 1 of 40 products (2.5 %) had a detectable ortho-phthalate above the matrix-specific reporting limit: 577 ppm DEP in a blueberry-scented nail art pen (Dollar Tree, DT-33-3).
• 39 of 40 products were non-detect for all nine phthalates at 15–25 ppm reporting limits.
• 0 of 20 nail polishes had a phthalate functioning as a plasticizer (the single detect is fragrance-associated DEP, not a film-flexibility plasticizer like DBP or DEHP).
• All 7 hair sprays and all 13 unscented skin cleansing products (including the 4 baby washes) were phthalate non-detect.

Asbestos results — powder blushes (n = 10)

0 of 10 talc-containing powder blushes had any of the six regulated asbestos fibre types (chrysotile, tremolite, amosite, crocidolite, anthophyllite, actinolite) detected above the reporting limit on any of XRD, PLM, or TEM.

Asbestos results — powder eyeshadows (n = 10)

0 of 10 talc-containing powder eyeshadows (including the combined-palettes sample from one children’s variety cosmetics pack) had any of the six regulated asbestos fibre types detected above the reporting limit on any of XRD, PLM, or TEM.

Asbestos summary across n = 20

• 0 of 20 talc-containing powder blushes and eyeshadows had any regulated asbestos detected on any of three complementary techniques. The Phase 2 finding is consistent with FDA 2022 follow-up testing in which asbestos was not detected in any of 50 talc-containing cosmetic samples (FDA, 2023c).
• The Modernization of Cosmetics Regulation Act 2022 (FDA, 2023d), signed into law in December 2022, requires companies to test talc for asbestos and is expected to further support elimination of asbestos in cosmetics. The report’s conclusion is that, with disciplined raw-material sourcing from talc mining sites and sufficient ingredient testing, asbestos can be successfully eliminated from talc-containing products.

Regulatory anchors and policy context cited

• ESSB 5693 (2022) Section 302(56) — the underlying Washington legislative directive funding both Phase 1 and Phase 2 of this testing programme. Quoted text on p. 7 of this report: $266,000 of the model toxics control operating account state appropriation provided solely to the Department of Ecology, in consultation with the Department of Health and community / social justice organisations, to identify cosmetics marketed to or used by people of colour (including adults and children) and to test those products for potentially harmful chemicals.
• WAC 173-337 (“Safer Products for Washington” Phase 1 ortho-phthalate restriction) — adopted by Ecology May 31, 2023, effective January 1, 2025. Restricts the use of ortho-phthalates as fragrance solvents or fixatives in beauty and personal-care products. Ecology selected ortho-phthalates “with functions other than fragrance solvents or fixatives” for Phase 2 testing because the fragrance-solvent / fixative use was already moving under Safer Products for Washington (p. 9, footnote 5).
• Chapter 70A.560 RCW — Washington statute restricting all uses of ortho-phthalates in cosmetics effective January 1, 2025 (p. 9, footnote 6). The Phase 2 selection of ortho-phthalates was completed prior to the Legislature’s adoption of Chapter 70A.560 RCW.
• FDA 2023a “Phthalates in Cosmetics” — cited as the source for FDA’s assessment that diethyl phthalate appears to be the only ortho-phthalate still used in cosmetics, and for the description of ortho-phthalate functions (plasticizer in nail polishes; fragrance solvent / fixative).
• FDA 2023b “Talc” — cited as the source for the talc-and-asbestos co-occurrence framing (both naturally-occurring minerals often found in close proximity).
• FDA 2023c “FDA Releases Data from the Agency’s 2022 Testing of Talc-Containing Cosmetic Products for Asbestos” — FDA 2022 follow-up testing in which asbestos was not detected in any of 50 talc-containing cosmetic samples; Phase 2 results are consistent with this finding.
• FDA 2023d “Modernization of Cosmetics Regulation Act of 2022” — signed into US federal law December 2022; will require companies to test talc for asbestos.
• US PIRG 2018 “In Your Face: Makeup found to be contaminated with asbestos” — cited as the prior NGO report that documented asbestos contamination in powdered cosmetics such as eyeshadows.
• Stone (2014), WA Ecology Publication 14-04-017 — cited as the Washington prior product-testing study that detected diethyl phthalate above 1000 ppm in scented nail polish and perfumes. Provides the Washington-internal trend baseline against which the present 577 ppm DEP detection is read as a directional consistency (DEP in scented nail product) at a lower magnitude.
• Ecology (2023), “Safer Products for Washington Cycle 1 Implementation Phase 3” — cited as identifying safer feasible / available alternatives to diethyl phthalate, including dipropylene glycol, isopropyl myristate, and benzyl alcohol.

Evidence Fitness

This is an A-tier state-government laboratory product-testing report. The ortho-phthalate panel was executed by the Manchester Environmental Laboratory under EPA Methods 3580A (extraction) and 8270E (GC-MS) with stage 4 data validation on a level 4 data package. The asbestos panel was executed at an external contract laboratory under EPA Method 600/R-93/116, ISO 22262-1 and 22262-2, and the USP talc monograph, with XRD + PLM + TEM in parallel and stage-4-equivalent validation by an external validator. All quality control criteria were met (with the documented caveat that the QAPP’s inter-analyst TEM QC frequency requirement was not formally met within this 20-sample batch and was accepted as satisfied by a verified single-different-analyst analysis). Data are usable for all purposes as reported.

Evidence the report supports:

• Direct-evidence null-result occurrence data for nine ortho-phthalates in 7 unscented hair sprays, 7 feminine hygiene washes, 2 adult body washes, and 4 fragrance-free baby washes (29 of 40 phthalate samples) from low-cost Puget Sound retail channels in December 2022, demonstrating that fragrance-free / unscented hair sprays and skin cleansing products on the Washington market can be (and largely are) made without these phthalates.
• Direct-evidence occurrence data for nine ortho-phthalates in 20 nail polish products from low-cost Puget Sound retail channels: 19 of 20 non-detect at 15–25 ppm reporting limits; one (a blueberry-scented nail art pen from Dollar Tree, DT-33-3) at 577 ppm DEP, consistent with fragrance-solvent rather than plasticizer use.
• Direct-evidence null-result occurrence data for the six regulated asbestos fibre types (chrysotile + 5 amphiboles) in 10 talc-containing powder blushes and 10 talc-containing powder eyeshadows from low-cost Puget Sound retail channels, including one children’s-marketed eyeshadow variety pack. Triangulated by XRD, PLM, and TEM. The 0/20 finding is consistent with FDA 2022 testing (0/50, FDA 2023c).
• Reproducible methods documentation for both panels (QAPP per Tuladhar 2022; phthalates-and-asbestos QAPP addendum per Tuladhar 2023).

The report does NOT support:

• Any heavy-metal occurrence claims for these products. Phase 2 did NOT test for Pb, Cd, As, Hg, Ni, Al, Cr, Cr-VI, Sn, Sb, U, or any other heavy metal. The heavy-metals panel is in the Phase 1 report (waecology2023-chemicals-cosmetics-phase1), which tested 10 lipsticks and 10 powder foundations for Pb/Cd/tAs only. Phase 2 has no heavy-metal evidence, by design.
• Phthalate occurrence in scented or fragranced cosmetics. Phase 2 explicitly tested fragrance-free and unscented hair-care and skin-cleansing products to characterise the phthalate-as-non-fragrance use case (the fragrance-solvent use was being restricted under Safer Products for Washington). Inference about scented-product phthalate occurrence requires Stone (2014) or other prior datasets.
• Distribution-shape claims by product subcategory. Subgroup n’s are small (n = 10 blushes, n = 10 eyeshadows, n = 7 hair sprays, n = 7 feminine washes, n = 2 adult body washes, n = 4 baby washes). The Phase 2 results are null-result occurrence data, not distribution-shape statistics.
• Brand-by-brand attribution. Per brand-firewall conventions and Part 12, individual brand-by-brand findings inside this regulatory-event report are not lifted into wiki product-category page tables; Ecology internal sample IDs (DT-33-3 etc.) are preserved here so any future Karen-curated regulatory-event citation can trace back to the specific Table A-2 / A-3 rows.

Methods (brief)

Product collection (Appendix A p. 13–14). In December 2022, Ecology purchased 60 unique low-cost cosmetic products from four Puget Sound area retail chains (12 Walmart, 16 Target, 20 Fred Meyer, 12 Dollar Tree), following selection guidelines in the project QAPP Addendum (Tuladhar, 2023). Some products purchased in multiples to meet lab weight requirements. No online purchases. For phthalates: 20 nail polish products, 7 fragrance-free / unscented hair sprays, and 13 fragrance-free / unscented skin cleansing products (7 feminine hygiene washes, 2 adult body washes, 4 baby washes); only fragrance-free or unscented hair-care and skin-cleansing products were purchased. For asbestos: 20 talc-containing powder cosmetics (10 blushes, 10 eyeshadow palettes, plus the eyeshadows from one children’s variety cosmetics pack combined into a single eyeshadow sample), all listing talc as an ingredient.

Sample processing (Appendix A p. 16). Nail polishes, hair-care, and skin-cleansing products sent to MEL in original unopened bottles to minimise atmospheric exposure. Eyeshadow and blush samples processed into sample jars in a fume hood one day before FedEx transport to the contract laboratory; multiple eyeshadow palettes combined into single samples where needed for mass.

Laboratory procedures — phthalates (Appendix A p. 17). Sample prep per EPA Method 3580A (extraction); pressurized-container samples sprayed onto tared vial wall with extraction solvent and condensed to liquid before processing. Analysis per EPA Method 8270E (GC-MS) for nine ortho-phthalates (DEHP, BBP, DEP, DHP, DiDP, DiNP, DMP, DBP, DnOP). All analysis at MEL. Reporting limit 15–25 ppm matrix-dependent.

Laboratory procedures — asbestos (Appendix A p. 17). Gravimetric prep per EPA 600/R-93/116 (ashing + acid filtration). Triangulated identification by XRD (per EPA 600/R-93/116 + USP talc monograph; qualitative serpentine / amphibole screen), PLM (per contract-lab SOP developed against EPA 600/R-93/116 + ISO 22262-1 / 22262-2 + USP talc monograph; qualitative characterisation and semi-quantitative projected-area determination), and TEM (per ISO 22262-2 fiber-counting strategy on calibrated index grids; 20,000× magnification with 10 grid openings counting all structures above 0.5 µm with aspect ratio >5:1, and 10,000× magnification with 25 grid openings analysing structures >5 µm with aspect ratio >5:1; morphology + quantitative EDS + zone-axis indexing per EPA 600/R-93/116 + ISO 22262-1). Six regulated asbestos fibre types: chrysotile (serpentine class), plus tremolite, amosite, crocidolite, anthophyllite, and actinolite (amphibole class). All analysis at an external contract laboratory.

Data validation (Appendix A p. 18–19). Phthalates: MEL data validation team conducted stage 4 validation on the level 4 ortho-phthalates package; three extraction batches; method blanks each batch had no analytes above reporting limit; surrogate-standard recoveries and frequency met QAPP criteria; data usable for all purposes. Asbestos: contract-lab level 4 package presented to an external validator and validated against the QAPP and standard EPA / ISO validation documents for TEM and PLM. XRD diffraction patterns, alignment and intensity checks, and reference-sample results within EPA method specifications. PLM instrument calibrations, alignments, and reference-sample analyses within specifications. TEM QC met the lab’s accredited-method requirements (10 % monthly QC, including 4 % inter-analyst, 2 % intra-analyst, 1 % verified, 3 % combination); the project QAPP’s 1/10-inter-analyst frequency within this 20-sample batch was not formally met but the verified single-different-analyst analysis was accepted as satisfying one inter-analyst QC, and replicate analyses were also conducted on a sample where a suspected amphibole particle was found. Validators concluded the data are usable for all purposes as reported.

Speciation / metals note. Phase 2 measured no heavy metals. EPA Methods 3580A and 8270E (phthalates) and EPA 600/R-93/116, ISO 22262-1/2, and USP talc monograph (asbestos) are organic-extractables and silicate-mineral methods respectively, not elemental methods. No Pb, Cd, As, Hg, Ni, Al, Cr, Cr-VI, Sn, Sb, or U data are produced by this report.

Implications

• Certification. Phase 2 contributes null-result evidence (and one nail-art-pen DEP detect) for HMTc product-category rows where the analytes of interest at certification are heavy metals; these results bear on the talc-impurity panel and the fragrance-related impurity panel rather than on the metals occurrence distribution. For makeup-foundation-powders-blush (HMTc Cat 13 Row 5, the relevant Phase 1 routing) and eye-makeup (an adjacent Cat 13 row not Phase 1-tested), the 0/20 asbestos result is supportive context for the talc-impurity profile, complementary to (not substitutable for) the Phase 1 heavy-metals findings on the same product family. For childrens-makeup (HMTc Cat 2), the combined-palettes eyeshadow sample from the children’s variety pack added a single asbestos-non-detect data point at the children’s-cosmetics tier; the Phase 2 dataset is null-result for asbestos and is not a children’s-metals dataset. For manicuring-preparations-leave-on the 577 ppm DEP detect in a blueberry-scented nail art pen is fragrance-attributable rather than plasticizer-attributable, consistent with FDA 2023a; this is not a heavy-metals finding. For leave-on-hair-preparations, intimate-washes-cleansers, body-wash-shower-gel, and baby-shampoo-body-wash, the 0/N phthalate detect across the fragrance-free and unscented subset is null-result phthalate evidence and does not directly inform metals certification thresholds. None of the Phase 2 results moves the literature baseline for any HMTc metals threshold.
• Courses. Useful as a teaching example of a state-agency two-phase product-testing programme (legislative-directive → QAPP → Phase 1 published report → Phase 2 follow-on QAPP addendum → Phase 2 published report) executed under fixed EPA and ISO methods, with TEM-XRD-PLM triangulation as the asbestos-testing gold standard. Also useful for contextualising the wiki/HMTc firewall: the Phase 2 conclusion that “cosmetics can be made without potentially harmful chemicals” is a regulatory advocacy framing, not a wiki-level claim.
• App. Not directly relevant to the food-app contamination-profile workflow; this is a cosmetics paper with no heavy-metal data.

Wiki pages this source may touch

• manicuring-preparations-leave-on — Puget Sound 2022 low-cost retail phthalate occurrence in 20 nail polishes: 1/20 detect (577 ppm DEP in a blueberry-scented nail art pen from Dollar Tree); 0/20 plasticizer-function phthalates. Adult-market nail products. Null result for the other 8 ortho-phthalates tested. NO heavy-metal data.
• leave-on-hair-preparations — Puget Sound 2022 low-cost retail phthalate occurrence in 7 unscented hair sprays: 0/7 detect for any of 9 ortho-phthalates at 15–25 ppm reporting limits. Complements but does not overlap the Phase 1 formaldehyde data for the same product category. NO heavy-metal data.
• intimate-washes-cleansers — Puget Sound 2022 low-cost retail phthalate occurrence in 7 unscented feminine hygiene washes: 0/7 detect for any of 9 ortho-phthalates at 15–25 ppm reporting limits. NO heavy-metal data.
• body-wash-shower-gel — Puget Sound 2022 low-cost retail phthalate occurrence in 2 unscented adult body washes: 0/2 detect for any of 9 ortho-phthalates at 15–25 ppm reporting limits. NO heavy-metal data.
• baby-shampoo-body-wash — Puget Sound 2022 low-cost retail phthalate occurrence in 4 fragrance-free baby washes (all marketed “phthalates-free”): 0/4 detect for any of 9 ortho-phthalates at 15–25 ppm reporting limits. NO heavy-metal data.
• makeup-foundation-powders-blush — Puget Sound 2022 low-cost retail asbestos occurrence in 10 talc-containing powder blushes: 0/10 detect for any of 6 regulated asbestos fibre types (chrysotile + 5 amphiboles) by XRD + PLM + TEM. NO heavy-metal data (Phase 1 has the metals data for adjacent powder foundations, same product family).
• eye-makeup — Puget Sound 2022 low-cost retail asbestos occurrence in 10 talc-containing eyeshadow products (9 adult palettes plus 1 children’s variety-pack combined-palette sample): 0/10 detect for any of 6 regulated asbestos fibre types by XRD + PLM + TEM. NO heavy-metal data.
• childrens-makeup — single children’s variety cosmetics pack (WM-54-3 “Be Inspired Glitter Makeover Studio”) contributed its eyeshadow palettes (combined) to the asbestos panel: 0/1 detect. NO heavy-metal data; not a children’s-metals dataset.

Verification notes

• Cite-key choice. Issuer-and-year convention matches the Phase 1 page and the OPSS exemplar: waecology2024-chemicals-cosmetics-phase2. The “phase2” suffix distinguishes this report from waecology2023-chemicals-cosmetics-phase1 (waecology2023-chemicals-cosmetics-phase1), which was explicitly flagged by the Phase 1 verification notes as the predecessor and named REG-012 / Phase 2 as the expected follow-on.
• Authorship. Appendix A names Prajwol Tuladhar (Washington State Department of Ecology, Environmental Assessment Program) as the author. The main report has institutional authorship (Hazardous Waste and Toxics Reduction Program and Environmental Assessment Program). The authors field lists Tuladhar first (the named individual responsible for the technical appendix and contact for questions per p. 20) plus the institutional byline.
• License. Washington State Department of Ecology publication in the public domain by US state-government work-product status. license: us-state-government-public-domain.
• Speciation / metals. No heavy metals were tested in Phase 2. The metals: array is empty. EPA Methods 3580A and 8270E (for the nine ortho-phthalates) and EPA 600/R-93/116 + ISO 22262-1/22262-2 + USP talc monograph (for the six asbestos fibre types) are not elemental methods. The HMI-vocabulary heavy-metals analyte list (Pb, Cd, iAs, tAs, MeHg, tHg, Ni, Al, Cr, Cr-VI, Sn, Sb, U) has zero overlap with the Phase 2 panel. The decision to ingest this paper despite empty metals: is justified by: (a) the Phase 1 page explicitly anticipated and named the Phase 2 ingest (waecology2023-chemicals-cosmetics-phase1 Verification notes line on “Phase scope” and “REG-012 will receive its own source page”); (b) the Phase 2 paper provides A-tier null-result asbestos and phthalate occurrence data for product categories that ARE within HMTc scope; and (c) without a Phase 2 page, any future Karen-curated regulatory-event citation that pairs Phase 1 and Phase 2 findings would have only the Phase 1 page as a wiki anchor.
• No heavy-metal claims in body content. The Key numbers, Evidence Fitness, Implications, and Wiki pages this source may touch sections all flag “NO heavy-metal data” so downstream synthesis and routing cannot drift this paper into a heavy-metal claim that it does not support. The Phase 2 paper is an asbestos + phthalate paper.
• Routing — adult vs children’s nail polish. Table A-2 includes no products explicitly labelled “children’s nail polish.” The 20 nail polish products are adult-market nail polishes, nail lacquers, gel envy enamels, nail treatments, a nail art pen, and a complete nail set. Routing uses manicuring-preparations-leave-on (the adult Cat 13 leave-on manicuring row), NOT the Cat 2 childrens-nail-polish row (de-linked here to avoid mis-routing). The blueberry-scented nail art pen (DT-33-3) is a novelty-scented adult-market product, not a children’s-marketed nail polish.
• Routing — children’s makeup. The asbestos panel includes one children’s variety cosmetics pack, WM-54-3 “Be Inspired Glitter Makeover Studio,” from which the eyeshadow palettes were combined into a single test sample (multiple eyeshadow colour palettes per the children’s variety pack, all combined for sufficient mass). This single combined-palette sample is the only children’s-product entry across the entire Phase 2 dataset. Routed to childrens-makeup as a 0/1 asbestos non-detect data point at the children’s-cosmetics tier. The eyeshadow-tier framing also routes this sample to eye-makeup as one of the 10 eyeshadow samples.
• Routing — facial-leaning vs body-leaning. Phase 2 phthalate cleansing products are all wash-off (feminine hygiene washes, body washes, baby washes) and route to the three rinse-off cleansing slugs that match the labelled marketing tier (intimate-washes, adult body wash, baby shampoo+body-wash). None of the Phase 2 products route to the leave-on facial / body skin-care slugs that Phase 1 used (the body-hand-leave-on-skin-care Cat 13 row was Phase 1’s body-lotion-and-cream routing — de-linked here to avoid mis-routing; Phase 2 has no leave-on skin-care equivalent).
• Routing — lipstick page is retired. Same handling as Phase 1: any “lip-product”-tier evidence is reserved for a future Cat 13 lip-products row Step 0 Lock. Phase 2 has no lip-product testing, so this caveat is moot but documented here for cross-page consistency.
• Routing — phthalates and asbestos are NOT heavy metals. Per the slug taxonomy snapshot (metals/: aluminum, antimony, arsenic, …, zinc), neither phthalates nor asbestos has a dedicated metals page slug. The asbestos data could be cross-routed to regulations/... if a Washington Safer Products for Washington WAC 173-337 or Modernization of Cosmetics Regulation Act page existed, but neither currently exists in the regulations snapshot; therefore neither is added to the routing. The phthalate restriction (WAC 173-337) and Chapter 70A.560 RCW are mentioned in body content for completeness but not routed via wikilinks until those regulation pages exist (per CLAUDE.md Part 10, the model does not silently create regulation pages mid-ingest).
• Brand firewall (Part 12, strict 2026-05-17 reading). Same approach as Phase 1: the WA Ecology Phase 2 report is a state-government public-record regulatory event under Exception 1 (brand naming is permitted when documenting a public-record regulatory event). Per the strict reading, per-manufacturer rankings inside the regulatory-event context still violate Part 12. This page therefore: (a) names the retailers (Walmart, Target, Fred Meyer, Dollar Tree) as procurement-source documentation, consistent with the report’s own framing of the chain-store sampling design; (b) uses product-form descriptors (“blueberry-scented nail art pen,” “talc-containing powder blush,” “fragrance-free baby wash”) rather than brand+shade attribution in the Key numbers section; (c) preserves Ecology internal sample IDs (DT-33-3, WM-54-3, FM-44-7, etc.) so any future Karen-curated regulatory-event citation can trace back to the specific Tables A-2 / A-3 rows. Brand names appear only in Verification notes and in the brief sample-population descriptor needed to identify the children’s variety pack (WM-54-3 “Be Inspired Glitter Makeover Studio”), not in body Key numbers. No per-brand rankings are constructed. Method-vendor / instrument-vendor references (EPA Methods 3580A, 8270E, 600/R-93/116; ISO 22262-1, 22262-2; USP talc monograph; Manchester Environmental Laboratory; external contract laboratory) are retained per Part 12 Exception 2.
• Wiki/HMTc firewall (Part 2). The Phase 2 report’s executive-summary framing (“many cosmetics, especially fragrance-free or unscented products, can be made without ortho-phthalates” and “cosmetics can be manufactured with high safety standards to prevent unintentional contamination and intentionally added harmful chemicals”) is regulatory advocacy language. This wiki page reports those framings as the report’s own conclusions rather than adopting them as wiki claims. The asbestos and phthalate findings are reported as occurrence and non-detect numbers; whether any HMTc Cat 13 / Cat 2 talc-impurity sub-panel should adopt these findings as a baseline is a separate certification-pathway question handled in the data/workbench/standards/ workflow and not in this wiki page.
• Phase scope and overlap with Phase 1. The Phase 1 and Phase 2 cosmetic-product sample sets are distinct purchases at different dates (Phase 1: July 2022; Phase 2: December 2022) from the same four retail chains but with different selection criteria (Phase 1: 10 lipsticks + 10 powder foundations for heavy metals; 10 hair styling gels/creams + 10 leave-in hair conditioners + 10 body lotions/creams + the same 10 powder foundations for total formaldehyde; Phase 2: 20 nail polishes + 7 unscented hair sprays + 13 unscented skin cleansing for phthalates; 10 powder blushes + 10 eyeshadow palettes for asbestos). The two phases share no individual products. The Phase 2 powder-blush asbestos panel is adjacent to (but does not overlap) the Phase 1 powder-foundation heavy-metals panel. The near_duplicates: field lists Phase 1 as the companion paper.
• Jurisdictions. US only. Unlike Phase 1, Phase 2 does NOT cite EU 1223/2009 or Germany BVL technically-avoidable values as comparators — Phase 2’s regulatory frame is FDA + Washington state (Safer Products for Washington, Chapter 70A.560 RCW, FDA Modernization of Cosmetics Regulation Act 2022, FDA 2022 talc-asbestos testing). The jurisdictions: array reflects this.
• DOI / publisher. No DOI; Washington State government publication identified as Publication 24-04-022 and indexed at apps.ecology.wa.gov/publications/summarypages/2404022.html. The access_url points to the report’s summary page (canonical and stable across PDF revisions).
• Raw path / handle. Filed under raw/Manual Fetch Kimi /June 1 Infant cosmetics metals papers/02_Regulatory_Reports/. The “Infant cosmetics” folder name is a slight mis-categorisation for this particular file — Phase 2 is primarily an adult-cosmetic testing study (the only children’s-marketed product across the entire Phase 2 dataset is one variety cosmetics pack, WM-54-3, contributing eyeshadow material to the asbestos panel; the 4 baby washes in the phthalate panel are children’s-tier products but are null-result and serve as marketing-claim verification, not children’s contamination findings). Folder placement is preserved as-is for raw-tree immutability; routing reflects the actual content (adult Cat 13 leave-on manicuring + Cat 13 hair + Cat 2 intimate-washes / body-wash / baby-shampoo-body-wash + Cat 13 makeup blush/eye + Cat 2 children’s-makeup data point).

Page history

The five most recent substantive edits to this page. The full version history lives in git; when DOI minting comes online (see schema docs), each entry below will also link to a version-pinned DataCite DOI.