The American Cleaning Institute (ACI) submitted comments to the California Office of Environmental Health Hazard Assessment (OEHHA) urging the use of the best available science for the agency’s First Public Review Draft - Public Health Goal (PHG) for 1,4-Dioxane in Drinking Water.
ACI emphasized that OEHHA’s proposed cancer safety goal of 0.04 ppb is based on studies and an approach that doesn’t line up with the wider international scientific consensus on how the chemical can impact human health. Because PHGs form the scientific basis for California drinking water Maximum Contaminant Levels (MCLs), ACI stressed the importance of a transparent and accurate scientific foundation.
“California’s drinking water standards must be anchored in the strongest, most current science available,” said Marie Gargas, Senior Director, Regulatory and International Affairs, American Cleaning Institute. “We urge OEHHA to fully consider the global body of evidence and peer-reviewed studies supporting that 1,4-dioxane operates through a non-genotoxic, threshold-based mode of action for carcinogenicity.”
ACI asked that OEHHA:
- Reconsider Reliance on Flawed Sources: ACI highlighted data quality concerns with one set of reported findings in particular, noting that other authorities, including Health Canada, have described deficiencies and questioned its reliability. Such work should not be relied upon to derive a cancer-based PHG, especially given the weight of evidence from robust studies readily available.
- Incorporate New Data and Analyses: ACI urged OEHHA to include recent peer-reviewed studies and analyses which provide evidence and support a pathway for 1,4-dioxane’s carcinogenic activity following a non-linear, threshold mode of action rather than a low-dose linear model.
- Global Regulatory Consensus: Authorities around the world - including the World Health Organization, Health Canada, and the European Chemicals Agency - have assessed the science, considered different mechanistic pathways, and determined that a threshold approach is appropriate for 1,4-dioxane. WHO and Health Canada have adopted drinking water values of 50 µg/L (50 ppb).
ACI also requested that OEHHA:
- Conduct a review of current consumer products and revise assumptions on human exposure.
- Update its regulatory comparison table to include New York State’s 1 ppb MCL and ambient water quality guidance values.
1,4-Dioxane is not an intentionally added ingredient, but a byproduct of the manufacturing process for some surfactants that may be contained in cleaning products and detergents, and which companies continue to work diligently to remove.
The American Cleaning Institute® (ACI – www.cleaninginstitute.org) is the Home of the U.S. Cleaning Products Industry® and represents the $60 billion U.S. cleaning product supply chain. ACI members include the manufacturers and formulators of soaps, detergents, and general cleaning products used in household, commercial, industrial and institutional settings; companies that supply ingredients and finished packaging for these products; and chemical distributors. ACI serves the growth and innovation of the U.S. cleaning products industry by advancing the health and quality of life of people and protecting our planet. ACI achieves this through a continuous commitment to sound science and being a credible voice for the cleaning products industry.