Full exchange with Crocodile Creek over Lead Safe Mama, LLC’s findings of Lead in their children’s stainless water bottles

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April 8, 2023 — Saturday

Back at the end of February (Feb. 27 and 28, 2023), I had an exchange with the CEO of Crocodile Creek, the manufacturer of the Crocodile Creek insulated stainless steel water bottles for children. Earlier that month (roughly seven weeks ago, based on the date of the above screenshot from Instagram) I uploaded a quick post noting I had tested a Crocodile Creek insulated stainless steel water bottle when I was visiting a friend in California and that it tested positive for 63,000 ppm Lead on the bottom — possibly indicating a near solid-Lead sealing dot (or- likely at best 60/40 Lead solder, which is 60% Lead and is typical for this sort of application), which was only covered by a silver-colored sticker (please check out the images above).

Note: XRF readings for the Lead-content of sealing dots on insulated stainless steel bottles are typically artificially lower than the actual amount of Lead present due to the fact that the size of the reading area of the XRF instrument is larger than the sealing dot. While taking the reading the scope (reading window) of the XRF instrument therefore covers some amount of the steel of the bottle (the edge surrounding the sealing dot) and the XRF reading is often also “diluted” by other materials (the metals content of any coatings, stickers, etc. covering the sealing dot) when the reading is taken, you can read more about that here.

I have been meaning to share the full communication thread I had with the company and decided to sit down tonight and put that all together to create this post. In preparing this post for publishing — to share the e-mail thread (which is included in full below) — I also wanted to do my due diligence and see where things stood with the company now in terms of the (logically anticipated) recall for that product. Below are all of the things I learned, followed by the original email exchange. There are images included in this post as documentation of each of the following points as well.


What I learned tonight:

  1. Seven weeks after posting about this issue on the Lead Safe Mama, LLC Instagram page — and more than five weeks after communicating (in detail) about the issue with the manufacturer — there is NO SIGN OF A PUBLIC “PENDING RECALL” notice OR ANY OTHER NOTICE on the Consumer Product Safety Commission website. See the image above.
  2. There is also NO NOTICE ABOUT A RECALL OR PENDING RECALL anywhere on the Crocodile Creek website. See images of their website below — including the results of a search for the word “recall.”
  3. Crocodile Creek has expressly advertised their stainless steel bottles as “Lead-Free” — a point that is still shown on their website as of publishing this article. See the screenshot below of their website.
  4. The company has apparently removed the Lead-contaminated Insulated Stainless Steel children’s water bottles from its website.
  5. I was still able to find at least one example of their (likely Lead-contaminated) insulated stainless steel water bottles available for sale on Amazon* (link: https://amzn.to/3GsV81s).
  6. They have apparently removed all of the stainless steel water bottles from the Crocodile Creek Amazon store (so the one noted for sale above in point five may have been overlooked somehow).
  7. With a quick scan of the company’s Instagram page, it seems like they may have removed images of their Lead-contaminated stainless steel water bottles.
  8. I could not find any notice of the issue anywhere on their website or social media channels (Instagram or Facebook), so it would appear they have not yet done anything to notify their customers or the general public about the issue through any appropriate public channels.
  9. Their website states that they have “Safety Test Certifications from third party accredited laboratories” for their products (image below), though I believe this may be yet another example of a CPSC-accredited lab that neglected to properly inspect and evaluate a product before issuing a compliance certificate. Of course, at this stage, this is speculation … but there does seem to be a trend happening here.
  10. I have not heard back from anyone at Crocodile Creek since February 28, 2023.

That’s all I could come up with for the moment. I expect (an educated guess) that by now they have confirmed my findings and likely have a recall in progress, but have not yet “pulled the trigger.” While their initial response (see below) seemed great (and, based on the removal of the product from their website and Amazon company store, it does seem like they are on track in the direction of doing the right thing), the fact that they have not yet made any public announcement is extremely disappointing.

Please read our full exchange from February below. Each image (with a pink border) is followed by a text block with the text from the e-mail for those using a text reader. There are nine e-mails in this exchange. Note: in email #3, while it might appear “self-serving” to make a specific request asking them to credit our business and community properly when they do announce a recall, we asked this because crediting our business properly establishes our scientific findings as “legitimate.” We now find this a necessary inclusion, as our testing is so often the first and primary prompt for subsequent investigation and a product recall but is rarely credited properly as such. Typically, in fact, it isn’t credited at all — often with some subsequent entity following up on our reporting, taking, and/or giving credit for the work of Lead Safe Mama, LLC and our online community.

Amazon links are affiliate links. If you purchase something after clicking on one of our Amazon links we may receive a small percentage of what you spend at no extra cost to you. In this case, we are sharing the link only to show the product is still available for purchase “in the wild” — we do not want you to purchase this product.


Text from email #1, above:

Hello Tamara,

Someone brought to our attention that you reported one of our stainless water bottles as having a very high lead content.

We’re surprised to hear this as we’ve always been very committed to safety and test our products thoroughly to make certain they conform to all the appropriate safety regulations and requirements for children.

If possible, could you let us know how you arrived at that information.  We are of course, also investigating with our factory to confirm all of the correct procedures and testing are in place.

Thank you for being out there and helping all of us make sure our products are safe to children.

Best regards,

Mel Brown

Mel Brown

CEO/Founder/Creative Director
Crocodile Creek
The Art of Play



Text from email #2, above:

Hi Mel! (& Peter, Rafael & Steve!)

It’s nice to see a real person reach out on something like this… someone in a position to make a difference and fix the problem. Readers, followers and supporters of the work of Lead Safe Mama, LLC really appreciate seeing that!
 
Here’s the basic info on the sealing dot issue:
 
Here’s a profile on my work written by Consumer Reports this month (they have actually covered my work on this issue (consumer products with Lead) three times this month):
 
My work has actually been covered by every major National news network this month – as well as a lot of minor ones and international ones. Here’s one other story (from CBS National): 
 
This piece discusses the testing methodologies we use:
 
Here’s a piece about our business model:
 
Here’s the “About” page on our website – it needs updating (I’m working on that this week), but it gives you a general sense of our work. We had 5,300,000 page views in 2022 alone  – with about 1.6 million readers from over 200 countries / locations (per Google Analytics)  – most of our readers are environmentally focused parents and grandparents wanting the best for their children (from an environmental perspective.)
 
We’ve been responsible for four Lead-related product recalls in the past 12 months:
– NUK Glass Baby Bottles
– Green Sprouts Insulated Stainless Bottles
– Bindle Bottle
– Jumping Jumparoo
 
There is also another recall pending for a child’s insulated stainless steel cup product with an issue similar to the issue with your products.
 
Here’s the documentary film I made on the subject – it has music donated by The Who and Tom Waits and footage from my presentation with Bernie Sanders in Flint in 2016 and my interview with Noam Chomsky.
 
I encourage you to watch the full film – as you will have a better understanding of the seriousness of the concern after watching it.
 
I am excited for you to fix this problem. Please let me know if you have any questions.
 
Where are you located? I am at the Grand Canyon today with my children. We are on a month-long road trip around the country – working with / visiting / helping families of Lead poisoned children. We’re wrapping up week two. We are headed to Utah and then Idaho from here. If you are on our route we could maybe meet up in person. 
 
Here’s our current route: 
 
I often work with companies in a consulting capacity to help them fix issues like this.
 
I look forward to hearing from you after you have taken a look at the above links and watched the film. I am happy to answer any questions too.
 
Please keep me updated on your progress in fixing the problem.
 
Tamara Elise Rubin
Lead Safe Mama, LLC


Text from email #3, above:

If you do end up making a public statement / issuing a public statement / publicizing a voluntary recall for this product (as would be appropriate under the circumstances) , we would sincerely appreciate it you refer to us as: Lead Safe Mama, LLC

Or if space permits: Lead Safe Mama, LLC, a woman owned-small business (with a focus on childhood Lead-poisoning prevention and consumer goods safety advocacy) out of Portland, Oregon
 
And listing / linking our website as:
 
And any public thanks for bringing your attention to this issue should be made to: “The Lead Safe Mama community – a parent advocacy community made up of tens of thousands of concerned parents, grandparents and others around the world”
 
Thank you.
Tamara Elise Rubin
Lead Safe Mama, LLC


Text from email #4, above:

Tamara

Thanks for all of the information.

We’ll review it and also talk to our suppliers and do everything possible to remedy the situations and decide about next steps

Best regards,
Mel Brown

Mel Brown
Co-CEO/Founder/Creative Director
Crocodile Creek
The Art of Play



Text from email #5, above:

Hello again…

As I said, we’ll be investigating the issue thoroughly in a variety of ways..

Some very quick, very preliminary research by our team today found this information on the web

    1. Touching lead is not the problem. It becomes dangerous when you breathe in or swallow lead. Can you absorb lead through skin?
    2. Lead can be absorbed into your body by inhalation (breathing) and ingestion (eating). Lead (except for certain organic lead compounds not covered by the standard, such as tetraethyl lead) is not absorbed through your skin
  1.  

Is there research that you could point us to that suggests the above is not correct and touching lead is in fact also a problem.

Again, we’re continuing to investigate and research at our end.

Thank you.

Best regards

Mel Brown

Mel Brown
Co-CEO/Founder/Creative Director
Crocodile Creek
The Art of Play



Text from email #6, above:

Hi again Mel,

The CPSC (United States Consumer Product Safety Commission) requires that the substrate of ANY COMPONENT of an item intended for use by children not test positive for more than 100 ppm Lead. 

You have Leaded “sealing dot” with levels in the substrate exceeding 60,000 ppm Lead – in a water bottle manufactured / designed and sold expressly as an item intended for use by children.
 
Transference of Lead to a child using the product or any other potential for child’s exposure as a result of damage to the bottle when used as intended (should the bottom cap come off when it is thrown by a child for example) is concerning – however this concern is irrelevant. 
 
The product is likely illegal per the Consumer Product Safety Improvement Act of 2008 simply because of the significant (and dangerous) amount of Lead (found in the substrate of a component of an item intended for use by children) which far exceeds the CPSC substrate limit of 100 ppm.
 
We learned recently that CPSC accredited labs have been overlooking the testing of this component in similar insulated stainless steel products. If your product was in any way certified by any lab or agency to be Lead-free, that lab or agency was likely negligent in their duties / protocol and you may want to look into that.
 
Tamara Elise Rubin
Lead Safe Mama, LLC


Text from email #7, above:

Thanks Tamara…

Mel

Mel Brown
Co-CEO/Founder/Creative Director
Crocodile Creek
The Art of Play



Text from email #8, above:

One more thought, Mel (and again, please watch the film for a crash course on the issue – it answers most background questions)…

The primary concern is hand-to-mouth activity if a child uses your bottles and the leaded sealing dot is not covered by the bottom sticker. It is therefore an ingestion hazard. The question of whether or not there is a skin absorption hazard is not relevant.

My XRF reading was through your product’s bottom sticker – so the reading for the component substrate is likely diluted and the substrate at that point could be as high as 500,000 ppm Lead or higher when tested separately (not through the “sticker”). Lead-based solder that is 50% to 60% Lead is common (in fact, typical) with Leaded sealing dots on insulated stainless bottles.
 
Combine this with the fact that many children tend to rub on dots or dimples like that (on the bottom of their bottles) as they are drinking from the bottle and we have a problem. It is super common for kids to rub these bottom sealing dots (once they are exposed) as a fidget.
 
The real problem (the health risk)comes if the Leaded sealing dot is exposed – and then the child does something like eating an apple afterwards without washing their hands, or sucking on their fingers (for example) as a habit, or even something as simple and innocuous as eating potato chips after touching the bottom of the bottle (with the sealing dot exposed because the sticker has come off) and then licking the salt from their fingers after eating the chips. In any of these cases the child would be ingesting the microparticulate Lead dust on their fingers with that normal and expected / anticipated activity.
 
When I first discovered Pura Kiki bottles (used by babies and toddlers) had this same issue (in 2016/2017) it was brought to my attention because the bottom cap came off a bottle (with normal use as intended by a child – because children can be expected to throw things and seals can be expected to be damaged in normal use given the intended target-market / intended user for these products – young children). This particular child was Lead poisoned – with a likely primary source of exposure being the exposed sealing dot from the bottom cap coming off of their insulated stainless steel Pura Kiki bottle.
 
In this particular case the child was doing age-appropriate activities (for a toddler) like mashing their bottle (with no cap or cover over the leaded sealing dot) into their oatmeal – and then eating the oatmeal. The mother didn’t think this was a problem because she didn’t expect the product could be unsafe in any way, let anyone have a bare exposed hunk of Lead on the bottom.
 
So this can cause significant issues for children. My own children have permanent brain damage from Lead exposure. There is no safe level of Lead exposure for children and it just takes a microscopic amount of Lead (literally an invisible amount) to poison a child. You can read more about that on this link: https://tamararubin.com/2019/03/the-sugar-packet-analogy-how-much-lead-dust-does-it-take-to-poison-a-child/
 
Hopefully all of that gives you some context and clarification – but again, please watch the film.
 
Tamara Elise Rubin
Lead Safe Mama, LLC


Text from email #9, above:

Tamara

Thank you again for all the information. As I mentioned we will be thoroughly investigating from our end

Best regards

Mel Brown

Mel Brown
Co-CEO/Founder/Creative Director
Crocodile Creek
The Art of Play







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13 Comments

  1. Beyond frustrating! My 15 month old son with elevated lead was using one of these water bottles until I got rid of it last week and bought a hyrdoflask.

  2. Thankfully no. But it is the flimsiest little sticker and there was wear/tear on it. After I read your article about sealing dots my gut just told me get rid of it!

  3. I am shook. Them trying to excuse the lead component because “lead isn’t absorbed through skin”. They advertise as “lead-free”. Clearly they’re not! Good job Tamara! Will def never buy anything from them, ever!

  4. I just saw the same crocodile creek stainless bottles for sale in store at Whole Foods today, July 10, 2023! BTW, please investigate Thermos Foogo stainless toddler cups. Ours had an exposed black soldering dot. Though purchased 9 years ago, the very SAME style cup (different colors) is on amazon for sale today. The plastic bottom end cap came off after the dishwasher (and dropping). I have wiped the bottom of the cup with dish towels right over the black soldering dot, and placed said towel right back on counter top for kids to dry their hands after washing (so they could eat with “clean hands”). This has been going on for 8 or 9 years now, 2 kids have used the bottle. I just got the black smudges cleaned out of the cabinet. All our drinking cups went there and rubbed across the streaks. You see, when the kids reach up high to get their own cups from the cabinet, they stretch up high and drag the cups down. They are now 10 and 5 year old. Dyslexia, adhd challenges, etc. I can purchase the new cup from amazon for you if desired.

  5. We just discovered this information and have discarded all our Simple Modern water bottles as well due to sealing dots. I had no clue that there was any lead in out stainless steel bottles. We. Got rid of all the children’s water bottles as many of the brands we had have lead sealing dots some that has a smidge if glue holding the small plate on and of course the kids toss their bottles all the time. We are ordering new ones based on your recommendations. It is a sad in this day and age that anyone would think this is a needed component in anything. Thank you for all your hard work and due diligence on our behalf.
    Grandma Goose Bumps

  6. I am so glad I came across this. I had noticed the sticker on the bottom of the Crocodile Creek water bottle I had *just* bought and thought it looked odd. Truly I don’t know why I keep searching the internet about this water bottle but I did find it odd I couldn’t find the water bottle I had just bought at Whole Foods, on Amazon or Crocodile Creek’s own site. I bought a cute floral one from Whole Foods *last week*!! I just called Whole Foods and will be returning and also printing out this article to give to the supervisor of their department that sells these.

    Thank you so much for this important work!!

  7. Hi good thing i came across this website. I bought crocodile water bottle at whole foods just this month for my 4 yrs old son and 1 yr old coz i thought this water bottle is clean and lead free but after I checked the bottom I saw the round black color covered with a silver sticker I got disappointed because they advertised it as lead free but not. And very mad because my two sons been using it for few weeks that I didn’t know it has lead. After I found out I immediately returned it to the store. Why they keep selling this water bottle?

  8. Hi Tamara,
    I came across your article when I was looking for a replacement cap (my daughter has chewed the cap) for the bottle. I purchased it about a month ago (October 2023) in Amsterdam, the Netherlands, and it is this bottle which I see is now back on the Crocodile Creek website: https://www.crocodilecreek.com/collections/stainless-steel-water-bottles/products/stainless-bottle-unicorn-galaxy?variant=43994258374884

    Do you know if this is a newer model, and the earlier ones were recalled? I can’t see the difference anywhere.

    Thanks for your time, Sophie

  9. Thank you for all you do! I just got this water bottle at my local Whole Foods (Wilmington, NC). I brought it home and not until I washed and saw the bottom I started questioning its safety. I googled for lead in these bottles and it took me to your website.

  10. Same story: I bought my son this water bottle at Whole Foods in March of 2024. Last time I checked, they’re still selling them. There is clearly a sticker covering a lead sealing dot at the bottom, and I bought the bottle because it’s advertised as lead-free. Crocodile Creek’s response (“Lead can’t be absorbed through the skin, so it’s not our problem, right?”) is vile.
    Anyway, thank you so much for testing these bottles, Tamara. I know it’s expensive to rent XRF machines, and you’re performing an act of true charity for every parent in the country when you test consumer products like these—especially those marketed towards children!

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