Dear Serenity… A Response to Serenity Carr’s email re: Lead Safe Mama, LLC’s findings of Lead, Cadmium, Mercury, & Arsenic in Serenity Kids® Puffs

    

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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 five product recalls (FDA and CPSC).
• 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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Affiliate link to the test kit used by Lead Safe Mama, LLC for the laboratory food test results we publish:
https://amzn.to/3UIPcHP

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Advertising and affiliate income help us cover the costs of the work we do here (independent consumer goods testing and childhood Lead-poisoning prevention advocacy). We have removed ads from most of our more widely-read articles (like this one!) to make them easier for you to read. In addition to supporting this work by starting any shopping you might be doing with clicks on our Amazon affiliate links, if you would like to support our independent consumer goods testing and childhood Lead-poisoning prevention advocacy work by making a contribution (which will also help us keep our more widely-read articles ad-free), click here. Thank you! 

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Serenity’s public statement on Instagram to customers in response to LeadSafeMama, LLC’s findings:

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Serenity’s public statement on their website in response to Lead Safe Mama, LLC’s findings. Click on each of the images to see them in full-size (to make it easier to read).

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Here’s the full text from Serenity’s public statement (on their website), shown in the three screenshots above:

Thank you for reaching out to us regarding the recent article from Lead Safe Mama that mentioned the use of organic cassava flour in our Grain Free Puffs. As a mom who has fed these products to my five-year-old daughter since she was a baby, I share your deep concern about contamination in our food supply. In fact, this is a primary reason why I started Serenity Kids. I would like to provide some more information about this issue so you can make the best choices for your little one. 

Sadly, the reality is that heavy metals are prevalent in our food system. Some naturally occur, and some come from decades of pollution and chemical farming. But while most produce can be found to contain heavy metals, we test ours regularly and have suppliers who use soil remediation methods to find foods with the lowest achievable levels of contaminants and prioritize them for babies. We carefully vet all of our suppliers to ensure we are using the cleanest possible ingredients so that we can feel good about the safety of our foods.

The Lead Safe Mama article raised concerns about cassava, a root vegetable like sweet potatoes, carrots, and beets. Cassava contains many valuable nutrients, but like all vegetables grown in the ground, it is more susceptible to heavy metal contamination. The root vegetable ingredients that we source and use in our pouches and Grain Free Puffs are tested to maintain what we believe are the lowest achievable levels. In fact, most sweet potatoes purchased at a grocery store have higher levels of heavy metals than our products, including our Grain Free Puffs.

Our Grain Free Puffs, and all of our products, exceed the health and safety standards for heavy metals addressed by California’s Prop 65 law, which is among the strictest food safety and quality programs for babies worldwide. The lead limits referenced by Lead Safe Mama were those proposed in the the Baby Food Safety Act of 2021, which was not adopted because the FDA and scientific community determined them to be unachievable due to the prevalence of heavy metals in our food supply. The FDA has been working through its Closer to Zero action plan to assess the presence of lead and other heavy metals in foods intended for babies and young children and is working to set achievable action levels.

Parts per billion (ppb) is a measurement used to measure contaminants in food. One ppb is like one drop of water in a swimming pool. While I’d rather not feed any heavy metals to my daughter, it reassures me when I visualize that measurement. 

 I do want to personally commend Tamara Rubin, founder of Lead Safe Mama, for her tireless advocacy on behalf of children’s nutrition and health. While I think there is additional information needed to make a fully informed decision, I believe that my child and all children are better off as a result of her activism. Serenity Kids joins Tamara in advocating for stronger FDA food safety regulations for infants and toddlers.

We remain committed to making children healthier by offering high quality, nutrient-dense foods that are safe for consumption and help children grow happy, healthy, and strong.

Feel free to reach out to us with any more questions you have.

With Gratitude, 

Serenity Carr

Co-founder and CEO, Serenity Kids

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Tamara Rubin’s Response
Published: March 31, 2024 — Sunday

Dear Serenity,

Thank you for your email in response to our testing of your products. I apologize that it has taken me several days to get back to you; my children have been quite ill this week — Avi, my 19 year old, is severely immunocompromised (from being acutely Lead poisoned when he was 7 months old), and he gets quite sick very easily. When Avi is ill it is usually a pretty dramatic event, and taking care of him when he is that sick demands most of my energy.

With this “extra time” to think of how I might respond to your email to me (as well as how I might respond to your public response to your customers, which has similar language), I have been able to give this some measured thought…

I am writing to you mom-to-mom, first and foremost — and second, as business-owner-to-business-owner…and finally, I am writing to you addressing you in your capacity as a role model for other mothers. I’ll try to separate those concepts here, although they are fundamentally “woven-together” in both of our circumstances.

My first response to your reaction to the findings of Lead, Cadmium, Arsenic, and Mercury in your Clean Label Certified “Purity Award”-awarded children’s puff products was outrage.

Expressing my outrage to you, however, won’t get us anywhere, won’t move the needle forward, and won’t enlighten you in any way, so I am really (herewith) doing my best to write to you in a way that might be helpful to you, that might educate you, that might help you (and your business) make different (better) decisions moving forward (for your customer base) — and that might encourage you to write a follow-up public statement — apologizing to your customer base for the misunderstanding that (apparently) your marketing and PR people intentionally crafted to convince people to be excited about your products, in spite of the fact they test positive for toxicants (at levels that are seen by the scientific and medical community to be unsafe for consumption by babies and toddlers).

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So, first… mom-to-mom…

Serenity — if, in fact (as you say in your email to me — the full text of which is below) you feed these toxicants-contaminated products to your own children, I would HIGHLY ENCOURAGE you to talk to your doctor about getting your kiddos tested (immediately) for heavy metals. 

I don’t know how many children you have, nor how old those children are [other than your 5-year-old]… however, given the child pictured in your advertising materials is older (no longer a baby), a heavy metals panel with a urine and/or hair test might be very useful for you. If your children (or anyone else in your family who has been consuming your heavy metal contaminated products on a regular basis) tests positive for the toxic metals in question (Lead, Mercury, Cadmium, or Arsenic), that will — I hope — serve as a fundamental eye-opening turning point in your approach to dealing with this situation.

People tend to avoid taking action when their bottom line might be impacted by that action (not questioning your sincerity, but $52,000,000 unavoidably tends to exert a lot of “adhesive pressure” on an already-formed opinion… increasing it’s resistance to being dislodged by contrary factual/ science-based evidence) — but parents DO tend to take action when their babies test positive for heavy metals! 

Given their age and body mass, your babies may not test positive (for Lead or other metals) using standard Blood Lead Level tests (BLL testing, administered by most pediatricians) from consuming these foods — as the low threshold of detection on BLL tests may not always be effective in demonstrating exposure from food-based sources. Please understand the following for context:

• The average BLL of a baby (or toddler) in the United States today is in the range of 0.5 to 0.6 micrograms of Lead per deciliter (µg/dL) of blood.
• In our experience, persistent/ chronic food-based exposures tend to result in BLL’s in the range of 1.0 to 3.9 µg/dL in younger children.
• Older children (and adults) have a greater body mass than infants, and thus won’t typically exhibit the same detectable Blood Lead Level that a smaller human might from an equal/ comparable exposure.
  • Said another way, an infant and a 5-year-old child might have the same exposure amount and same exposure pathway (for Lead, for example, each eating two servings of Lead-contaminated snack puffs four times per week), but the infant’s BLL from that exposure will generally be higher than the BLL of the older child in this scenario.
  • In fact, a smaller child in a comparable exposure scenario might exhibit a high/ detectable BLL (with standard testing methodologies) when an older child with greater body mass might not have a detectable BLL at all (using standard blood testing methodologies).
  • This does not mean the older child was not exposed, it just means that more sensitive testing methodologies need to be used to quantify the extent of their exposure. You can read more about that here.
• The “half-life” of Lead-in-blood is also in the range of 30 to 45 days — so if a child stopped or paused the consumption of a Lead-containing product — and was not tested until later, the exposure may not be detected (as testing was not done at the peak of exposure while the Lead was still circulating in the blood rather than after it had been permanently deposited in bones, as well as brain and organ tissue). This is also discussed in my documentary film (in my interview with Doctor Leonardo Trasande) — linked here.
• The availability of more precise Blood Lead Level (BLL) testing — down to measurements of zero point 1 microgram of Lead per-deciliter of blood (0.1 µg/dL) and lower — has actually been deliberately reduced/ made less-accessible (following documented pressure from industrial special interest groups).
  • As a result, commonly-available BLL testing now typically has a low threshold of detection of “less than 1.0” or “less than 2.0” (or even in some cases, “less than 3.3!”).
  • So while a doctor or nurse may tell you that your child is “negative” or “low” for Lead, that assessment is within the context of the low threshold of detection in the available testing methodology used.
  • If a child has a test result of “less than 2.0,” for example, they still may have a detectable/ measurable BLL exposure in the range of 1.0 to 1.9 µg/dL — which is significantly higher than the average American child, but below the level of detection for the testing methodology used.
• Important context: Science has established that the average BLL of humans before the Industrial revolution was 0.016 µg/dL (read more about that here).
  • What this means is that a level of 1.6 µg/dL — while possibly generating a “negative” result from your doctor (being below the threshold of detection for your doctor’s current testing methodology) — is still 100 times the average pre-industrial revolution “background” levels for humans!
• Also important – and a key point, really: There is NO safe level of Lead exposure for humans (this scientific fact has been unequivocally proven, and all federal agencies acknowledge the science, agreeing on the importance of understanding and underscoring this as a starting point in eliminating childhood Lead-poisoning).
  • Serenity, your — charitably — astonishingly-misguided assertion that the presence of the extremely potent neurotoxicants in question (Lead, Cadmium, Arsenic & Mercury) in your children’s snacks in the low ppb (parts per billion) range is “…like a drop of water in a swimming pool” is at best reflective of profound ignorance of the science.
  • Regardless of current FDA or Prop 65 limits, the consensus within the scientific and medical community is that the regular (chronic/ daily/ weekly) ingestion of Lead, Cadmium, and Mercury are extremely harmful at the concentrations (levels) found in the Serenity Kids products we tested.
  • Significant impacts of Lead exposure — at even very low levels — have been conclusively demonstrated by current scientific study. (This article, and this article, discuss the impacts of low-level exposure, clearly indicating the reasons that elimination of heavy metals from our diet is an important piece of the puzzle toward optimal health and cognitive function for our children.)

Given the inherent timeline–critical limits of BLL testing, to get a sense of “lifetime” exposure and impacts, a hair or urine test for metals can be a useful indicator of past exposure — especially for a young child, given their short life to date, combined with their small body mass (their past exposure is less likely to be fully “hidden” in their bones and tissues). You can read more about that here.

Serenity — I highly encourage you to get a full panel of metals for everyone in your family (possibly with hair, urine, and blood testing so you can compare the range of results) to rule out potential current exposure — and to get a sense of past/ historic exposure.

Separately, it is very important for you to know something that you seem to have casually (and irresponsibly) dismissed in your email to me (and in your public statement to your customers): the impact of aggregate Lead exposure is cumulative.

If you watch my documentary film you will understand this better. Nearly all of the Lead your body has ever been exposed to is still in your body (or your baby’s body). Lead bio-mimics Calcium, and (particularly in young babies who are still forming and growing quickly), biological structures that use and need Calcium will take up Lead if it is present — in place of Calcium. For my younger son (Avi — who was poisoned at 7 months old) his brain was intensely developing when he was poisoned; that’s why his brain injury is so significant of an impact. In the case of my older son (who was three years old at the time they were poisoned), his permanent teeth — another high-calcium structure — were developing at that moment in time and were severely impacted (in addition to neuro-cognitive impacts and other physiological impacts), causing life-long profound challenges with constant, numerous cavities, despite his consistent attention to a stellar diet and excellent preventative dental care.

In short, mom-to-mom, please do some homework to better understand this concern and how the potential exposures may have have impacted your own family. The best place to start: Watch my documentary film. The film is 92 minutes long and answers most of the broader questions about Lead poisoning — it was designed to be a crash course on the issue. I often do presentations for doctors, nurses, and educators through which these professionals get continuing education credits for watching the film and participating in a post-screening discussion of the issue — the science presented in the film is very solid. Please follow up with me directly if you have any questions after watching my film. While I am concerned for potential long-term exposure to your customer’s kids, I am also concerned about the potential toxicant exposure experienced by your own kids (based on both your public statements and your letter to me personally).

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Business-Owner-to-Business-Owner

First, I want to acknowledge what may be an elephant-in-the-room between you and me (business-owner-to-business-owner). Per our original article published last week, we chose to test these products of yours (and purchased them at a local Portland, Oregon grocery store for testing) back in December of 2023. We had no idea that our testing and reporting would coincide (roughly) with a business announcement sharing that you had just raised $52,000,000 in capital to grow and expand your business. The timing is unfortunate and interesting, to say the least. I only found this out after publishing our article. I did some googling about investors in your business — after I learned (from a comment made by a reader) that someone I know may have invested in your business, I wanted to confirm this. That’s how I came across this article:

In a perfect world, this fifty two million dollars should give you the power to increase your capacity for being responsible for your words and actions. The $52,000,000 should also afford you the opportunity to respond to this testing by making a truly clean product.

Unfortunately, you have made a LOT of mistakes in your public messaging/ PR — to the point where it may be time to hire a new PR person (as your current PR team obviously have no comprehension of what is at stake, nor of the intellectual capacity of your customer-base).

Your letter to me (as well as your public statements) fundamentally assumes your customer base is not intelligent and won’t understand science. The 34 screenshots of responses from your customers (below) demonstrate otherwise.

People have chosen your products to feed their babies because they are smart and took you at your word in evaluating the merits of your products. You let your customers down (both with the ACTUAL toxicant profile of your products and with your public response).

The images below (and the one above) are examples of your PR (propaganda really) that you engage in “rigorous heavy-metal testing” and that you “test for over 200 contaminants.” These public statements indicate several (very upsetting) possibilities:

1. These statements indicate that IF, in fact, you do engage in the rigorous testing you say you do, that you are (and have been) fully aware of the toxicant profile for your puffs products that was discovered by the testing done by Lead Safe Mama, LLC (that we reported on last week), and you have not been making this information available to your customers.
2. Alternately, your PR / marketing statements may indicate that if instead (at any point) you assert you were (to this point) ignorant of the toxicant profile of your puffs products (as discovered and published by Lead Safe Mama, LLC), the testing that you have been identifying as “rigorous” is actually insufficient (and not at all rigorous).
3. Finally, the public statement that you “test for over 200 contaminants” is clearly exposed as PR/ greenwashing in the context of the testing Lead Safe Mama, LLC completed. Your customers ASSUME (as you have essentially directed them to assume) that when you say you TEST for over 200 contaminants that your products are FREE of these contaminants. You have, however, chosen your words for these statements very carefully, never stating that while you test for those 200 contaminants your products are free of those contaminants. Your customers feel very misled by this particular element of the greenwashing you have engaged in.
4. Your PR spin on the above statements is especially egregious (given the findings of Lead Safe Mama, LLC) as your customers’ responses (see the 34 images with yellow borders below as examples) CLEARLY indicate that they believed what your marketing department WANTED them to believe (even though that was obviously not true): Your customers believed that when you say you TEST for 200 contaminants, in fact, this means your baby food products are FREE of those 200 contaminants.

In addition to your own marketing spin being incredibly problematic and non-transparent, your misguided association with the Clean Label Project (combined with your willingness to accept their “Purity Award” classification when, presumably, it would seem highly likely that you knew your products test positive for multiple heavy metals — given the extensive testing you say you do in your marketing materials) has further misled and confused (deceived?) your customer-base into thinking your product is actually FREE FROM the toxicants (heavy metals) of concern in baby foods these days.

In addition to all of the above, you did not take a practical approach to address and resolve the issues that have been raised with Lead Safe Mama, LLC’s testing results. Did you see the response from Lesser Evil? Here’s the link to their response and my response back. Lesser Evil clearly articulated an interest in learning more about the concern — which is ALWAYS the first step in resolving an issue. They asked for photos of the packaging. You did not. They asked for batch information so they could see if our findings were a batch specific issue. You did not. This further characterizes your public statements (on your website and social media) and your letter to me as dismissive and solely-intended as a PR move, not an attempt to investigate and address a real concern (a concern that your customers are truly wanting you to investigate further).

The reaction of your customer base (a sampling of which is in — again — noted in the 34 images below) really articulated how your letter made me react (as a business person)… “AHA — she saw I published the Lesser Evil response, so she wrote me a greenwashing, dismissive, bullshit PR response in the hopes that I would publish it on my website and that people would not be smart enough to see through the greenwashing, PR spin and BS.” Serenity — business-owner-to-business-owner, this was a TERRIBLE strategy — (again) I think you should fire whoever is in charge of your PR.

 

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Perhaps you can use a good portion of the $52,000,000 infusion of cash you just raised to actually make the clean product you have promised your customers you were already making.

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As a role model for other mothers

Finally Serenity, I invite you (I implore you) to read the comments from your customer base, (see several screenshots below, and please also check out the comment threads on the Lead Safe Mama Instagram page and the Lead Safe Mama Facebook page).

Your customers are not stupid.

Your customers trusted you.

Your customers saw you as a role model, doing the right thing (doing what was necessary) to feed babies healthier, nutrious choices.

Regardless of your intent, you have let people down — both with your original actions (producing and selling toxicant-contaminated products), and with your response to the publication of Lead Safe Mama, LLC’s findings of metals in your products. I invite you to read the above, watch my film, read the comments from your community — and reevaluate your response.

After you take the time to better educate yourself on the subject matter of concern (Lead-poisoning — and also the combined impacts of simultaneous exposure to other toxicants), please consider writing a new response — one that addresses the concern (of toxicant exposure to young children) in a non-dismissive, authentic way. The two themes I share most often in my work are “Know Better, Do Better” (again this is not just a theme, this is an invitation) and “First, Do No Harm.” 

Your customers expect more from you — you set up those expectations with your actions and your language.

Now is the time for you to meet those expectations with some updated (authentic, personal, non-spun, written-by-you-personally) public statements that address the reality on the ground for these families (not some corporate, greenwashing spin drafted by your PR department, but something authentic and proactive that indicates you now Know Better, and you are going to Do Better — outlining the steps you are going to take to meet those ends).

Here’s our suggested course of action:

• Apologize for the heavy metals-contamination of your products (without dismissing the levels, suggesting that they are insignificant or unavoidable, or reiterating that the levels are “legal”).
• Ask for the batch information and other details so you can do further testing OR confirm (in writing, publicly) with your customer-base that you were aware of the levels we found (if they are consistent with the levels found in the “rigorous testing” you do).
• Remove the Clean Label Project Purity Award references from your product packaging, marketing and online presence — at least until you can confirm you are producing a baby food product that has levels of metals that fall far below the scientific recommendations for levels of concern in these products.
• STOP blaming “the soil” — look for sources of contamination in your factory (in the processing/ machinery/ packaging equipment) and eliminate those sources of contamination (they are often found in brass bearings and other components on machines — so that is a good place to start).
• Remove cassava as a base ingredient for your baby foods and see what the toxicant profile looks like without cassava as an ingredient — or if that is not immediately possible (alternately, at the very least), source cassava with a toxicant profile that falls below the 2021 Baby Food Act’s proposed levels (the levels that are safe for children from a science and health-based/ medical perspective).

Those are just some suggestions — from me and from your customer base (the moms who used to trust you).

Don’t forget to scroll down to read the comments from members of YOUR customer base/ YOUR community.

I can and will help you through this process, if you want.

As a business, you need to recover from your dismissive, inauthentic, non-science-based public statement — and that is not going to be a quick and easy path.

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

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Serenity’s letter to me is below the images, with feedback from the community.

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For Lead Safe Mama community members who would like to read Serenity’s email to me from the other day (the email that the above is in response to), here’s a screenshot: