---

This is an ad-free article.

Advertising and affiliate income help Lead Safe Mama, LLC 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 a click on our affiliate links, if you would like to support the independent consumer goods testing and childhood Lead-poisoning prevention advocacy work of Lead Safe Mama, LLC by making a contribution (which will also help us keep our more widely-read articles ad-free), click here. Thank you!

---

Affiliate link to the test kit Lead Safe Mama, LLC
uses for the laboratory food test results we publish:
https://amzn.to/3UIPcHP

---

---

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 July of 2022, the work of Lead Safe Mama, LLC has been responsible for five product recalls (FDA and CPSC).
• All test results reported on this website are science-based, accurate, and replicable.
• Please check out our press page to see some of the amazing coverage of our work so far this year!

---

 

---

Here’s one reference summary we found online while writing this up:

---

Here’s another set of guidelines we found online for creating a COA:

---

May 17, 2024 — Friday
Note: Title of this article may be changed at a later date!

Today on Facebook, a Lead Safe Mama community member shared the details of her April 2024 exchange with Terrasoul Superfoods in which she requested the COA for their Cassava Flour. She also shared the “COA” that she received from Terrasoul Superfoods in this exchange. That “COA” is below.

As I reviewed the “COA,” I was quite surprised to notice her product batch number was the same as the product batch number for the bag of Terrasoul Superfoods Cassava flour that was purchased and tested by Lead Safe Mama, LLC. After our initial inquiry with Terrasoul, we were just waiting for them to send us this document but they had not yet, so it was amazing that one of our community members was able to provide it to us instead (while we were still waiting to hear back from Terrasoul).

After further careful examination of this “COA,” I saw quite a few more surprises. I then wrote a response to Terrasoul Superfoods summarizing these “suprises” and concerns — you can read that below.

After sending the below response to Terrasoul this afternoon, I was finally able to connect with the FDA representative that I have been playing phone tag with (we spoke this Friday evening, just at the end of the work day) and I explained all the details as we discussed the issue. The FDA representative gave me guidance on filing formal complaints (against Terrasoul and others) and I will be drafting those complaints this weekend. Once each complaint is filed, we will publish them here for the Lead Safe Mama community to read as well. Check out the email and “COA” below.

In the meantime, please let me know if you have any questions after reading it (and if you find it as amusing as my husband did)!

Note: While the email I sent to Terrasoul lists some of the concerns that led me to question the legitimacy of the “COA” below, that list is not comprehensive; it is just a list of what I noticed at the moment when I wrote the email. Other considerations I have (after giving this some more thought), which indicate that this “COA” is not legitimate, include (referencing the linked images above):

1. There is no address or other contact information for the business on the COA.
2. There is no address or business named (or other contact info) for the product supplier (in India?) on the COA. A single-ingredient product typically has the supplier contact info on the COA.
3. There is no name, date, or signature of an authenticating officer (a qualified and authorized inspector) at the bottom of the COA — my understanding (based on the research I have done to date) is that this is a firm FDA requirement for most COAs.
4. There is nothing indicating the testing methodology (the type of testing/ protocols/ lab parameters, etc.) This sort of information is typically present for this type of COA (food, supplements, etc.)
5. If the COA was provided by a lab (or if some of the information on the COA was provided by a lab — for example, the metals analysis) and that lab was a legitimate, independent, third-party testing facility, then detailed testing specifications from the lab would also be included alongside the lab’s name and contact information.

Hello Esther,

 

Earlier today, a reader of our website (LeadSafeMama.com) shared with me the “Certificate of Analysis” you shared with them via email. I have attached that here.

 

The batch number happens to be the same batch number for the product we purchased and tested, which I found interesting: 2411101.

 

Your “COA” also states the Manufacture date for that batch is May of 2022 and that the “Shelf Life” is 24 months — which I also find interesting. 24 months from May of 2022 would be May of 2024 — however our bag has a “Best By” date of March of 2025, which does not seem consistent with what one might expect based on the information you provided in this “COA”.

 

This test report / “COA” (from your company) has the following issues / raises the following questions:

1. It has a reading of 40 ppb Lead, which is not consistent with our third party / independent laboratory testing for product from this same batch – which found 146 ppb Lead in this product (365% of the level of Lead noted in your “COA”)
2. The “COA” is (in fact) not a COA 
   • It was prepared by your company
   • It is not from a lab
   • It is not on lab stationery/letterhead
   • The certificate is not dated 
   • The collection date is not noted
   • The testing date is not noted
   • The reporting date is not noted
   • With all of these things missing from your “report” — the authenticity of your alleged test results (of 40 ppb) is highly suspect (from the perspective of any consumer knowledgable about these sorts of things).
3. Separately — this report raises the questions: 
   • How many lots do you produce annually? 
   • Or are lots produced every couple of years? 
   • How is it that product that we purchased on Amazon in April of 2024 is from a lot of finished product apparently manufactured in May of 2022?
   • How many units are in a typical lot? 
   • What level of confidence do you have that testing from the beginning of a lot to the end of the lot will result in similar Lead test results if the lot is so large it takes you two years to sell all of it? 
     • If this is an assumption you are making, this seems like an unreasonable assumption – especially if it is an indicator that you are only testing your product every two years (or less frequently).
4. Finally, are you aware of the scientific / medical recommended limit of 5 ppb Lead in items that may be consumed by young children? [This was the level recommended in the proposed baby food legislation in 2021]
5. Can you give us more information about this testing you did? 
6. Do you have the actual laboratory report? 
7. Was the testing done by an independent lab? 
8. Or do you have some sort of facility in-house for testing? 
   • [If so — please note, this is not an ethical business practice].

Thank you for your time. 

We (the Lead Safe Mama online community) look forward to hearing back from you in response to this very serious and concerning matter.

 

Tamara Rubin