The Nurse who owns PrimalLife sent me an email threatening legal action, in which she demonstrated a clear misunderstanding of math and science.

 

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June 20, 2022 — Monday — Well… this has been an exciting day!

This morning I woke up to a flurry of activity around the PrimalLife Dirty Mouth tooth paste article I published last night (in the wee hours today, actually — 6/20/22)! Many of my readers were in touch, with various communications they have had with the company (both recently, and over the past several years) in which they requested information about the presence or absence of toxic heavy metals in the toothpaste product in question (PrimalLife’s Dirty Mouth Toothpowder) — and most got evasive answers (at best).

One reader shared the following communication with me — in which the company representative for PrimalLife actually sent her the COA (Certificate of Analysis) for the bentonite clay base that the product used at the time of her inquiry. Here is the email from her exchange, dated June 17, 2022 (keep reading below the relevant image from this exchange):

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In the email above there were links to two pages of a COA for the clay. I clicked those links and downloaded the information. This document (from Lone Star Botanicals) is, suspiciously, not dated — COAs are ALWAYS dated, and normally have more identifying information (although the lot number noted may be helpful): Continue reading below the two images — each is a clickable image if you need to see it larger to read it.

That noted, I was actually both “happy” — in a manner of speaking — and simultaneously incredibly dismayed when I read the Certificate of Analysis (COA) report shown in the images above. I was “happy” (for lack of a better word) because the 9 ppm range (9.681 ppm) findings for Lead, which are clearly noted in this document, are quite consistent with Lead Safe Mama, LLC’s findings (originally reported here).

Additional considerations:

• The Antimony and Cadmium levels are different (however, this is not surprising — as toxic heavy metal content in mined-soil-based products will normally vary somewhat from batch to batch — within a certain anticipated range.
• It looks like a reasonable range of variation in heavy metals to expect here — specifically for Cadmium and Antimony (on this particular clay product, batch to batch, given the levels of various metals found in this one COA as compared to the findings I published in my original post — linked here) might be within the +/-20 ppm range. This would explain my sample testing positive for Antimony and Cadmium at levels close to 20 ppm (20,000 ppb) when the sample tested for their COA did not have levels reflective of my findings.
• These are speculative considerations. More information is needed to definitively draw these conclusions as a margin of error is not noted on the COAs above.
• Looking at the low threshold of detection of any test (in addition to the margin of error) in order to evaluate accuracy is also critical. 
• I will write a separate article comparing the two sets of test results more specifically so these considerations can be better understood.

Mostly, I was sick to my stomach and dismayed about this confirmation of my findings because this meant that the company is AWARE of the heavy metals levels in their product (at least the Lead, given this one report) and that they continue to promote the product as healthful, in spite of that knowledge. This meant that customers were trusting the branding and marketing claims of the manufacturer — yet those were in no way reflective of the actual scientific reality of the product, specifically the science around the potential range of total heavy metals content and the potential human health impact implications of that.

There are other glaring problems with the faux-“scientific” theories promoted by this company (including around language asserting a lack of bioavailability and “ionic charge” of the heavy metals in the clay); this, however, is far from unique or original but rather echoes the shared delusional gospel recited by other purveyors of bentonite clay-based products I have spoken to. I will address this in another article with a more narrow range of focus — so please do stand by for that piece to be published shortly.

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This morning I sat down to write an article stating the above — that PrimalLife’s own internal testing documents — which they have shared with customers who happen to be Lead Safe Mama readers, readers who then shared those response with me — clearly showed that not only does the product have Lead but, consistent with my testing, contains Lead in the range of 9,000 parts per billion (which is simply a translation of the 9 parts per million [ppm] noted in the COA, translated into the units of parts per billion [ppb] — the even-finer-grain unit of measure used to quantify toxicants in food, beverages, supplements, and other potentially-ingested products).

Shortly after I began to write, I received an email from the owner of PrimalLife Organics… threatening legal action against me and alleging that I “do not understand the math” behind the numbers(!). Note: I was on the competitive math team in high school — and LITERALLY got my varsity letter in high school (awarded for people engaged in competitive sports) in math. Yes — you heard that right, I have a varsity letter in competitive math! Lol (Continue reading below the picture of my varsity letter from 1987!)

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Here is a screenshot of the email that the owner/ CEO of Primal Life Organics sent to me earlier today (as I said, I got her email shortly after I started writing this article). I have spent the rest of today — as it now approaches 9:00 p.m. — completing this article and my response to her email. Below the screenshot, I have also included a text block with the full language from her email, so that it is fully-searchable by anyone who is curious.

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Here’s the text — copied and pasted from that email.
Please continue reading below this text block:

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So, ahhh… where to start?!

Well, if you have good reading skills, and if you understand fairly basic arithmetic — multiplication, percentages, etc., there is truly no explanation needed! If you are good at math, and don’t yet quite understand what I am talking about, please re-read her email above (read it slowly —  perhaps out loud, maybe without kids underfoot — and it should instantly become painfully/ shockingly obvious!).

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#Woah. Right? Amazing. 
I am actually nearly speechless regarding the staggering level of confusion and/or ignorance fueling that embarrassing rant — by a nurse, no less, a professional in the medical field — in this one. short. email.

So in my moment of stunned speechlessness (earlier this afternoon), I decided to make a short video, which I uploaded to YouTube, Instagram, and TikTok. Here is that video; it is just one minute — please do listen to the whole thing (thank you!) — and continue reading below the video.

 

 

 

 

 

 

View this post on Instagram

 

 

 

 

 

 

 

 

 

 

 

 

A post shared by Lead Poisoning Prevention (@leadsafemama)

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Then, to follow-up on this, I decided to make a second video — in case the first one was somehow not clear enough:

 

 

 

 

 

 

View this post on Instagram

 

 

 

 

 

 

 

 

 

 

 

 

A post shared by Lead Poisoning Prevention (@leadsafemama)

Each of these videos is one of my teenage Lead-poisoned children discussing (briefly and clearly) how to convert parts per million (ppm) to parts per billion (ppb). In case someone here is still not clear (or wants to see this in writing vs. hearing it on a video) — as this point of confusion does come up every now and then in this work, a while ago (December of 2021) I created this article with a little graphic to help (click the image to read the full article — then continue reading below the image):

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Prior to this, in March 2017 I wrote a previous post discussing this — specifically, as it relates to the conversion for toothpaste! Here’s that article, if you are interested. For those who need still more information (or assurances), click the image below for a live link to a ppm to ppb conversion calculator:

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Does anything more really need to be said? 

While one could certainly argue that really, nothing more needs to be said — there is a fundamental catastrophe of misunderstanding embodied in the email above, sent to me by Trina today.

As I do have compassion and empathy for all human beings, it is never my intention to “take a person down,” nor to dishonor them as a fellow struggling human — it is always my intention to send out an educational olive branch in the name of science… However, I have chosen to write what needs to be said as an email directly to Trina (below). I also sent this email to Trina upon publishing this article (with a link to this full article)… so that she is properly informed, along with anyone else who lacks understanding of, or has confusion about these fundamental questions and concerns.

It is unfortunately likely intrinsically and unavoidably painful for Trina to be made aware of both this sort of basic error (she calculated the ppb to ppm conversion in the wrong direction), and the profoundly disturbing implications it carries — doubly-so with the added embarrassment of having expressed, publicly, insistent righteous indignation over one’s mistake. But take a moment to consider that this reflexive outrage (by company owners who learn unpleasant science-based truths about their products) is both all-too-common and actually understandable. If one takes a moment to actively imagine the “powerful current” rapidly pulling one toward defensive confusion, denial, and panic-induced offensive accusation, aspersion, and threats — if you were to mentally trade places, it is certainly a very difficult predicament for any business owner to find themself in.

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Here is my e-mail to Trina in response to her e-mail above:

June 20, 2022 — Monday
8:40 p.m.

Trina, Hello.

Obviously there is a fundamental misunderstanding (on your part) about the conversion of parts per million (ppm) to parts per billion (ppb). While this is a common misunderstanding among those who are not in the medical fields (or who are not otherwise scientifically or mathematically literate), I would definitely expect a greater level of comprehension from someone like yourself – both a registered nurse, and business owner. Reading this email from you this afternoon was quite startling and well, concerning!… 

Given the threatening nature of your e-mail (threatening legal action against me if I refuse to remove the science-based accurate information I posted about your product from my website), I am going to keep this e-mail as brief as possible.

Once you have had a chance to digest what I have said and to better understand it – and once you are ready to issue an apology to your customers and to Lead Safe Mama readers (which is a population that has significant overlap), I will publish that apology / public statement in the exact form and with the exact language that you share with me.

You have clearly misunderstood a conversion of ppm to ppb, in a way that also clearly illustrates you may have been unaware of the risk and potential harm to which you have subjected your customer base.

#1.) As noted above (see link in e-mail), you and your company have been aware — OR CERTAINLY SHOULD HAVE BEEN (from the COA that you shared with a customer – above) — that your product (in the specific batch tested) tested positive for both Lead and Cadmium. The Lead level on that report is clearly noted as roughly 9.7 [9.681] parts per million.

#2.) This translates to roughly 9,700 [9,681] parts per billion [as noted in my original post, food toxicity – and toxicity for Lead for items that may otherwise be ingested – is measured in parts per billion].

#3.) Experts agree there is no safe level of Lead exposure for humans. From water to dried fruit, the official range of toxicity thresholds for Lead is between 1 and 100 parts per billion, levels over which, Lead is considered present at unsafe levels.

#4.) In your e-mail, you clearly indicated your misunderstanding of the subject — both in your initial point, and in your reiteration of that same point (the 7 to 7,000 sentence.) You therefore (apparently) misunderstood the COA report you received. You have – apparently unknowingly (based on your statements today) – been selling a product with very high levels of Lead (levels consistent with the range of levels I found in the independent testing I did).

#5.) To address the discrepancies in Antimony and Cadmium levels, one must look at multiple factors. It is concerning that your COA report (again, shown above) does not appear to have any date(!) — but thankfully, it does at least have a lot number, which should be helpful. The point to know is that when you are talking about a naturally-occurring soil-based product that is mined or dug from the earth, toxicants levels will typically vary from batch to batch. This is especially true when these toxicants are present in the ranges of 10 to 20 parts per million (10,000 to 20,000 ppb) — which, from a total volume content perspective (the percentage of total volume of the soil that is comprised of these metals) is a very small number (even though from the health hazard/impact perspective, this is still an extraordinarily large quantity, for a neurotoxic or carcinogenic heavy metal).

I would like to recommend the following course of action for you and your company:

1. Stop selling your clay-based products immediately
2. Test multiple batch samples of your products (from different product dates and different source lots), to determine the range of toxicants you might have (to compare to the Antimony and Cadmium levels I found in the product I bought that was sold to me direct from your online store last month — in May of 2022).
3. Please request that all COA’s provided to you by your suppliers are dated (as is the norm), as well — so consumers can try to determine which COA might correspond to their own product purchase, based on production dates (especially if the lot number is not noted on every bottle — which it does not appear to be — see the image below of the product I purchased which has no number next to the words “Lot #”.)
4. Issue an apology to your customers for misunderstanding the science (and the math).
5. Recommend that your customers see a doctor, and that they consider getting tested for metals (with a urine, blood or hair test)
6. Promise to do better.
7. Resolve to find clean-sourced ingredients
8. Hire a science advisor to help your company interpret and understand the science so as to ensure that this sort of mistake is never repeated
9. Refund any purchase to customers who request them.
10. I know you might hate me right now — but a public apology to me and to my readers for the aggressive tone of your e-mail (and subsequent communications and comments on Instagram) might go a long way in repairing your relationship with your customer base.

Those are my thoughts for the moment.

In the name of replicable science,

Tamara Rubin
Owner — Lead Safe Mama, LLC
Mother of Lead-poisoned children

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For those new to the Lead Safe Mama website:

Tamara Rubin is a multiple-federal-award-winning independent advocate for childhood Lead poisoning prevention and consumer goods safety, and a documentary filmmaker. She is also a mother of Lead-poisoned children (two of her four sons were acutely Lead-poisoned in 2005).

• Tamara owns and runs Lead Safe Mama, LLC — a unique community collaborative woman-owned small business for childhood Lead poisoning prevention and consumer goods safety.
• Since 2009, Tamara has been conducting XRF testing (a scientific testing method) using the exact instrumentation employed by the U.S. Consumer Product Safety Commission to test consumer goods for toxicants (specifically heavy metals — including Lead, Cadmium, Mercury, Antimony, and Arsenic).
• Since July of 2022, the work of Lead Safe Mama, LLC has been responsible for 5 product recalls (FDA and CPSC).
• All test results reported on this website are science-based, accurate, and replicable.
• Items that Lead Safe Mama, LLC reports on are tested multiple times to confirm the results published (for each component tested).
• Recent notable press… There has been too much to mention already in 2024! Please check out our press page to see some of the amazing coverage of our work so far this year!

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