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Note Re: Low Thresholds Of Detection for This Report

• This report  – similar to some of the other reports that we are publishing this month – references different “low thresholds of detection”  for some of the metals we are testing for – different than many of reports we have shared previously.
• If you look back through the history of laboratory testing we have been coordinating (of foods and supplements) since Lead Safe Mama, LLC began this initiative in March of 2024, the low thresholds of detection have varied throughout this time period.
• Given we are using a network of labs for the laboratory testing we are coordinating, this may happen periodically (where the lab used to test a specific product found the confidence level for their low threshold of detection to be higher than some other labs have determined for other products we have tested).
• While we would ideally prefer low thresholds of detection for each metal to fall below the 2021 proposed action levels – for reports (like this one) where one-or-more toxicants have been found to be present at levels at-or-above the 2021 proposed levels of concern for children (discussed in detail below), we feel this information is still relevant to report, as these findings mean the product falls into a range that is possibly / likely unsafe for consumption by children (when taking into account those 2021 proposed standards).
• Said another way – for this particular product – while we don’t know the exact levels of Cadmium, Mercury and Lead down to a single digit part per billion range (except that the level falls somewhere below10 ppb), the fact that the Arsenic level is at-or-above 10 ppb is enough information to indicate there is at least some degree of concern with the toxicant profile for this product.
• Separately  – our lab reports do not (yet) distinguish between inorganic and organic Arsenic.  The food industry often asserts that one type of Arsenic is considered relatively safe, while the other has been determined to not be safe (and – they argue – this distinction between organic and inorganic Arsenic matters), with some preliminary inquiries we have found enough independent scientific opinions indicating that both forms of Arsenic may be unsafe for consumption (depending on the levels and frequency of consumption). Consequently the total Arsenic content is relevant when determining toxicant concerns (regardless of the breakdown of which types of Arsenic make up the total reading). Some relevant links here:
  • Organic Arsenic may be “less harmful” (not harmless – quotes added for emphasis) – World Health Organization
  • Inorganic Arsenic is generally considered to be “more toxic” than the organic form (indicating both can be toxic – quotes added for emphasis) – National Institutes of Health
  • Exposure to high levels of some organic Arsenic compounds may cause effects similar to those of inorganic Arsenic. – Iowa Department of Health

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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 July of 2022, the work of Lead Safe Mama, LLC has been responsible for six 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!

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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 (and newly published articles, too — 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!

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Important Background: What is an Action Level?

Please note the following key points:

The original lab report for this product is below (at the bottom of this page).

The graphic above shows the levels of metals detected in this product (in red) along with the low threshold of detection (in orange – above the action levels discussed below/ green – below the action levels discussed below) for each metal not detected with the laboratory testing Lead Safe Mama, LLC had completed for this product. The numbers are juxtaposed (in blue) to the “Action Level” proposed by the medical and scientific community in 2021 as part of the Baby Food Safety Act. For this round of testing, SimpleLab (our laboratory testing provider) had a change of labs and their low threshold of detection is slightly higher than in previous testing rounds.

• These 2021 levels were proposed as “Action Levels” because they are (in fact) protective of human health.
• An “Action Level” is NOT the same as a “Maximum Allowable Level.”
  • Many food manufacturers misinterpret guidance on heavy metals to mean “allowable levels” and consider it reasonable for their products to test positive below these levels.
  • This is a (perhaps intentional?) misunderstanding/ misinterpretation the food industry makes — a misunderstanding which food manufacturers use to justify the presence of heavy metals in their products.
• Heavy metals accumulate in the body.
  • It is the cumulative / aggregate impact of heavy metal exposure (over a lifetime) that makes even small/ incidental/ seemingly trivial exposures particularly damaging and dangerous. You can read more about that here.
• Once a food product has the amount of heavy metal (Lead, Cadmium, Mercury, or Arsenic) noted (above) as the “Action Level,” that product is officially considered (by the scientific and medical community) unsafe for consumption by children as toxicants (found at-or-above these levels) are in the range of heavy metal levels that have been demonstrated to cause lasting harm.
• Action Levels are not related to serving size.
  • Action Levels are relevant for any amount of a food product that may be consumed (any quantity of the food in question).
  • PPB (parts per billion/ ppb) measurements are a percentage (albeit a very small percentage) and apply to any quantity of the food product tested.
  • For more discussion about serving size considerations (and why relying on “serving size” to limit toxicant exposure is not a relevant metric/ not a metric protective of human health), read this article.
• These “Action Levels” proposed in 2021 are the levels at which the scientific and medical community believe the manufacturer (or government) needs to take ACTION to fix the problem.
  • One “Action” would be for the manufacturer to take steps to reduce the levels of toxicants in the food product.
  • Another “Action” would be for the manufacturer to cease sales of the product until the product could be made safe.
  • Another “Action” would be for the manufacturer to inform the public that a specific food product has an unsafe level of the metal detected at-or-above the “Action Level” — making a highly-visible public announcement regarding which relevant batches of the product should be recalled/ no longer consumed.
• The Action Levels proposed with the Baby Food Safety Act of 2021 were not arbitrary toxicant levels, they were proposed because they are the levels most protective of human health. However, the Baby Food Safety Act of 2021 was not passed into law.
• Regardless of the fact the Baby Food Safety Act of 2021 never passed into law — and it is therefore legal to have foods and supplements marketed for consumption by children test positive for Lead, Cadmium, Mercury, and Arsenic at-or-above these levels — these Action Levels still reflect the current (modern/ relevant) advice of the medical and scientific communities as levels both achievable by the industry and safeguards of infant and toddler health.
• Food industry lobbyists fought against formalizing these proposed “Action Levels” as a government standard, alleging the levels were unachievable.
  • The image below (with the number ELEVEN) links to a landing page with 11 food products we have already tested this year (2024), all of which have been “non-detect” for toxicants with low thresholds of detection (for Lead, Mercury, Cadmium, and Arsenic) far below the 2021 proposed Action Levels.
  • These 11 food products (about 10% of the foods Lead Safe Mama, LLC has tested and reported on so far since March 2024 when we began laboratory testing foods) clearly demonstrate these Action Levels as achievable across a range of food types (salt, flour, coffee, oatmeal, chia seeds, hemp seeds, soy milk, packaged fruit-based snacks, beverages, and more).
• The legitimacy of these levels as “Action Levels”/ “Levels of Concern” (even though they were not adopted as law) is mirrored by the legitimacy of the American Academy of Pediatrics’ level of concern for Lead in water, which is 1 ppb, despite the FDA’s official “level of concern” for Lead in water being 15 ppb (you can read more about that here).

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 “Simply Not Achievable”

While the packaged, processed food industry would have consumers (and the government) believe the standards proposed in 2021 are not achievable, this industry position (an oft-rearticulated response to nearly every set of laboratory test results for food we have published to date) is simply not true. It is possible to make safer processed, packaged food products that fall well below the safety levels for toxicants proposed within the Baby Food Safety Act of 2021. To read more about the 11 food items Lead Safe Mama, LLC has tested and reported on so far that resulted in “non-detect” for Lead, Cadmium, Mercury, and Arsenic (with the limits of detection as reported for each product), click the image below (with the big number 11)!

Here are direct Amazon links to those 11 safer products as well (this list is growing alongside the food testing we are organizing — to see the updated list at any time, click the graphic with the number above):

1. Sea Salt (Oregon, USA)
   • Amazon link for this product: https://amzn.to/4dcbk5L
   • Article with the lab test report for this product
2. Organic Einkorn Flour (Italy)
   • Amazon link for this product: https://amzn.to/3LIqxix
   • Article with the lab test report for this product
3. Organic, Gluten-Free, Sprouted Rolled Oats (Canada)
   • Amazon link for this product: https://amzn.to/3WIQ1BN
   • Article with the lab test report for this product
4. Organic, Non-GMO, Gluten-Free Chia Seeds (Mexico)
   • Amazon link for this product: https://amzn.to/3YvE7xC
   • Article with the lab test report for this product
5. Organic Espresso Roast Ground Coffee (Multi-Country Origin, Non-USA)
   • Amazon link for this product: https://amzn.to/3yo1eiL
   • Article with the lab test report for this product
6. Sparkling Grape-Flavored Tonic
   • Amazon link for this product: https://amzn.to/4cjFYZu
   • Article with the lab test report for this product
7. Pure Organic Layered Fruit Bars in Strawberry Banana Flavor
   • Amazon link for this product: https://amzn.to/3WQEekA
   • Article with the lab test report for this product
8. Pure Organic Layered Fruit Bars in Raspberry Lemonade Flavor
   • Amazon link for this product (sold in a box assortment, we haven’t found these sold separately): https://amzn.to/3XcFsIp
   • Article with the lab test report for this product
9. GoGo Squeez Organic Fruit On The Go in AppleApple Flavor
   • Amazon link for this product: https://amzn.to/3XhWYLe
   • Article with the lab test report for this product
10. Organic Soy Milk
    • Amazon link for this product: https://amzn.to/4dwev8l
    • Article with lab report to be published shortly
11. Organic Hemp Seeds
    • Amazon link for this product: https://amzn.to/4e05RP9
    • Article with lab report to be published shortly

Amazon links are affiliate links. 

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Published: September 29, 2024
Sunday

Hello! We are working on publishing a LOT of test results very quickly this week.

We will be updating this section of each article (with more information about the specific product and other similar products for context) as time permits, but we wanted to make sure the greater Lead Safe Mama community (and the general public) had access to this scientific data (about foods and supplements in their home) as quickly as possible.

Please scroll down to see the full laboratory test report for the product pictured above.

Thank you for your patience.

Please do check out the other links on this page for additional information about the truly independent, third-party, laboratory testing we are conducting on food products.

As there are almost no reasonable safety thresholds proposed for toxicants (heavy metals) consumed by adults (in foods and supplements), our focus is (as always) on the health of children. The available proposed safety thresholds (and guidance) for foods consumed by adults are not set at levels protective of human health and therefore are not relevant to the work we do here at Lead Safe Mama, LLC.

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Some additional reading & links that may be of interest:

1. This is the Lead Safe Mama Amazon affiliate link to purchase the test kits we used for this testing.
2. Here’s our landing page with links to all the food test results for products we have tested and reported on so far.
3. Here’s our landing page listing all of the food testing we have in-progress (at the lab/ pending, etc.) — please consider making a contribution in support of any of the pending crowd-funded foods if they are a food you use! Thank you.
4. Here’s information on how to send your own food samples into a lab for testing (the cost is $195 per single food sample tested for Lead, Cadmium, Mercury, and Arsenic) and how to collaborate with Lead Safe Mama, LLC on the food testing we are hosting.

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Amazon links are affiliate links. If you purchase something after clicking on a Lead Safe Mama, LLC Amazon affiliate link, Lead Safe Mama, LLC may receive a percentage of what you spend — at no extra cost to you.

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Lab report for the Natural Whole Nutrition Vital Proteins Collagen Peptides – Unflavored Dietary Supplement pictured here: