Response to Just Ingredients Instagram Graphics — February 2025

February 22, 2025
Text Shared on Social Media Today with the 3 Graphics Below:

Another key point not mentioned in this graphic is that the “Prop 65 limits” are often/ usually misunderstood (sometimes intentionally?) by most food manufacturers — and also by most medical providers…
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Prop 65 is fundamentally merely a labeling law; the law dictates levels that are “allowable” (allowable without a warning notice to consumers) in a serving of manufactured foods and other products. This is a level above which a manufactured/ packaged product is only “illegal” if it does not carry the Prop 65 labeling on the package (based on the “serving size” the manufacturer of the product defines).
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People misunderstand these levels to somehow be a “maximum safe level for consumption”/ “permissible/ allowable levels for consumption,” when they were never intended to be used in that context.
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Prop 65 levels were set to provide guidance that helps INCREASE awareness of toxicants (by requiring labeling) and through this awareness, LIMIT toxicants exposure via manufactured foods and products (based on “serving sizes”). Prop 65 limits were not established to provide excuses to PERMIT persistent low level/ chronic exposure to Lead or other chemicals in manufactured foods and other products.
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Fundamentally, the concern is also this: Using any “serving size” for toxicity concerns is an outdated and non-health-protective metric.
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Important relevant point:
Do most consumers typically use the exact serving size of ANY product (strictly measured as noted on the package by the manufacturer)?
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Let’s take protein powder as an example: How likely are you to use a heaping scoop when a manufacturer says to use “a measured scoop?” How often might you even use two scoops when the manufacturer says to use one?
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There are examples abound of typical consumer-consumption patterns exceeding — often by a significant amount —a manufacturer’s claimed “single serving” size, but again this consideration is fundamentally irrelevant given the fact that Prop 65 was NOT designed to limit consumption patterns, it was only intended to mandate labeling limits.
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A product can be in full compliance with Prop 65 requirements yet still be unsafe for use by women and children.

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 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 news coverage of our work, linked here.