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:
- 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.
- 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.”
- 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.
- The company has apparently removed the Lead-contaminated Insulated Stainless Steel children’s water bottles from its website.
- 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).
- 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).
- 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.
- 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.
- 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.
- 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:
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.
The Art of Play
Text from email #2, above:
Hi Mel! (& Peter, Rafael & Steve!)
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
Text from email #4, above:
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
The Art of Play
Text from email #5, above:
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
- Touching lead is not the problem. It becomes dangerous when you breathe in or swallow lead. Can you absorb lead through skin?
- 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
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.
The Art of Play
Text from email #6, above:
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.
Text from email #7, above:
The Art of Play
Text from email #8, above:
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.
Text from email #9, above:
Thank you again for all the information. As I mentioned we will be thoroughly investigating from our end
The Art of Play