Beeyoutiful’s Second Response to the Controversy: the Weston A. Price Foundation & Green Pasture Fermented Cod Liver Oil

Beeyoutiful's Second Response to the Controversy: the Weston A. Price Foundation & Green Pasture Fermented Cod Liver Oil

It’s been a little over a month since our previous post on the Fermented Cod Liver Oil (FCLO) upheaval. I promised then that we would wait to see how Green Pasture Products (GPP) and the Weston A. Price Foundation (WAPF) addressed the major issues that have come to light, and then we’d respond again.

In the interim, GPP has released quite a bit of information, including laboratory test results. WAPF issued a long Q&A, and some bloggers and researchers connected to WAPF also posted responses. So, it’s time now for our update.

second fclo update bars

I’m going to do this backwards and start with the summary, since some might not want to wade through the nitty-gritty details. If you’re interested in just the highlights and my takeaway, read this section and then scroll on down to the bottom for my conclusion.

As it stands now, we have stopped carrying Green Pasture Products at Beeyoutiful. There are just too many unknowns about the product. We’d still like to know:  Beeyoutiful's Second Response to the Controversy: the Weston A. Price Foundation & Green Pasture Fermented Cod Liver Oil

  • What’s the source of the trans fats in FCLO?
  • Why is there D2 in an animal product?
  • What about the many reports of health issues that are now coming to light?

In my opinion, both GPP and WAPF have acted as though they are more concerned about losing consumer confidence than they are in openly and honestly addressing these and many other issues.

We have had a personal membership with WAPF for many years, attending conferences as a participant, a vendor, and a sponsor, and have directed many people to their site for information on healthy living. Sadly, we can no longer recommend the Weston A. Price Foundation as a reliable, trustworthy resource for health advice. 

And, based on the way they have treated others who have said anything negative about GPP’s fermented cod liver oil, they probably wouldn’t have us as a vendor again anyway. We have seen enough information coming out of WAPF as this situation has unfolded that we know to be untrue, that it calls into question the accuracy of other information that they have published and endorsed.

I’m still holding out some hope that out of this turmoil some good changes will come about in GPP and WAPF, and that we might be able to renew these business relationships in the future. My hope wavers, though, when I think that rebuilding trust is going to require a much higher level of honesty and transparency than we’ve seen thus far.

I do not mean to imply that everything GPP and WAPF are saying is untrue. Sometimes what is not said is as important, and sometimes more important, than what is said. For example, you might ask someone, “How is that cool car of yours? Is it still running?” And they reply that yes, it purrs like a kitten, and they detailed it just the other day and how wonderful it is to own a car like that. It is easy to infer from this that all is well, nay, even fantastic with the hot car, and that the owner cruises around in it regularly, just feeling the wind in his hair.

But that’s not actually what was said. Some pertinent information that wasn’t revealed might be that the tires are bald, the brakes are squishy, and they hydroplaned in it on a rainy day, crashing into a median, bending the axel and tearing off the front quarter panel, and this glorious car isn’t even drivable at the moment. What was actually said is still absolutely true, but at the same time also completely misleading.

Both WAPF and GPP have been doing similar things with the information they publish, and have been for years. This is why people believed that the fish in FCLO was Atlantic Cod and that it was sourced from the Atlantic and Arctic regions like most other high quality CLOs. We were led en masse to believe these things, because of both what was and was not communicated by GPP and WAPF, even though they never said these things specifically. There is now evidence that they knew this is what people were believing and they did nothing to correct these misconceptions.

For Beeyoutiful to have a relationship with WAPF and GPP in the future, we must feel confident that it won’t require reading between the lines to figure out what’s not being said in order to have a correct understanding of where a product is sourced, how it’s made, and what ingredients it contains.

Now for detailed questions and answers for those of you who are interested. (Everyone else, skip to the important part at the bottom.)

Beeyoutiful's Second Response to the Controversy: the Weston A. Price Foundation & Green Pasture Fermented Cod Liver Oil1) Question: Does Green Pasture FCLO contain the levels of vitamins claimed in their literature?

Our previous answer: “Well, it seems like probably not. In his rebuttal blog post, Wetzel didn’t even argue that point. However, he said that the amount of vitamins is less important than the bio-activity of the vitamins. He says their bio-activity is very high.”

Update: “Probably not” still seems accurate, based on the updated information that we have. GPP did post information that one scientist said that the only way to properly measure Vitamin D is to do a rat bioassay. (Feed the rats the product in question, then kill the rats and test the tissue and blood for the component that interests you.) GPP also posted a rat bioassay from 2009 that apparently showed good levels of vitamin D.

Other information has come out, though, that indicates that taking FCLO does not raise blood serum Vitamin D levels in some people, and at least one person reported that it actually suppressed the level. This is something that WAPF said bears further investigation.

Also, GPP is reporting that most of the vitamin D in FCLO is D2, and most of the vitamin D in other premium CLOs is D3. Possible explanations are that the fermenting process converts D3 to D2, or that the test results from that lab are simply not accurate. Vitamin D2 is generally considered a lesser vitamin, being far less active and much more potentially toxic than D3. (I’ll address Vitamin D in more detail later.)

Beeyoutiful's Second Response to the Controversy: the Weston A. Price Foundation & Green Pasture Fermented Cod Liver Oil2) Question: Is Green Pasture FCLO actually fermented, or is it rancid?
Answer: One of the questions that has arisen out of this controversy is a simple one: can meat be fermented? This person, who seems to know a bit about fermenting, says no, but that it can be cured.

I consulted Sandor Katz, the author of “The Art of Fermentation” and he said that yes, meat could be fermented, in hundreds or maybe thousands of ways, but that he didn’t know enough about the GPP process to comment on it specifically. He did reference a passage from an old book that spoke about cod liver oil extraction through putrefaction (the same passage GPP references as a model for their process). In answer to my follow up question of whether putrefaction and fermentation were the same thing, he said that “putrefaction is often occurring alongside fermentation and is responsible for some of the ‘edgier’ flavors.”

So, is the cod liver oil fermented? Is it putrefied? Is it both? I don’t know. Short of having a whole panel of fermentation experts intimately review the entire process, I’m not sure we’ll ever know. I seriously doubt GPP is willing to open up their entire process to that level of scrutiny.

In the past few weeks, I have learned more about oils, lipids, and rancidity than I will probably ever find useful in any other context! I learned is that there are three types of rancidity:
  • Hydrolytic rancidity – results in Free Fatty Acids (FFAs) which are susceptible to oxidation and salts of FFAs, and has a bad odor
  • Oxidative rancidity – results in aldehydes, ketones, and other substances which can be toxic and create a bad odor
  • Microbial rancidity – results in a bad odor

I cannot find any information that specifically says that hydrolytic or microbial rancidity can result in anything other than bad odor. It is readily apparent to me that the product is rancid, almost certainly experiencing hydrolytic rancidity, and maybe microbial.

The scientists that GPP and WAPF have trotted out have been very careful to speak only about oxidation and to say that the product is low in primary and secondary indicators of oxidation. Not one of them has said that the product is not rancid, although GPP and WAPF themselves have both stated unequivocally that FCLO it is not rancid.

Beeyoutiful's Second Response to the Controversy: the Weston A. Price Foundation & Green Pasture Fermented Cod Liver Oil

3) Question: Is Green Pasture FCLO safe to use?

Answer: Most people think this hinges on the issue of rancidity. As stated before, the product does not have the markers of oxidation and does not seem to contain toxic byproducts of oxidation. I can’t find any information that says that hydrolytic or microbial rancidity are dangerous in and of themselves, but they seem to usually go hand in hand with oxidation, so there really isn’t much information on them alone.

However, there have been rumors and reports of people not doing well while using FCLO. There have been claims of heart conditions, including heart failure, that have cleared up after stopping daily FCLO supplementation. I have seen at least one person whose CRP (a blood test for inflammation in the body) numbers went down significantly after one month of no FCLO, when they had stayed at a steady elevated level for the previous 5-6 years while on the FCLO.

There are numerous reports from people that say that they couldn’t tolerate the FCLO, but they did fine on other non-fermented cod liver oils. There are reports of burning throats when taking the FCLO, with one person reporting that it was like her throat was on fire.

And then there is the issue of trans fats. Trans fats are not “generally recognized as safe” by the FDA, and manufacturers have until 2018 to get them out of foods (or get an exception). Trans fats are believed to be one of the biggest contributors to heart disease. GPP posted a number of test results recently and most of them had trans fats levels near or above 1%. One of the tests from the report from Dr. Kaayla Daniel showed levels over 3%.

This is a huge problem because in the real food movement, trans fats are a huge no-no, no matter the amount. If it has detectable levels of trans fats, it is simply not considered a good product. Trans fats are a problem about which GPP and WAPF have remained very quiet.

Now, there are things that aren’t good that we eat in our diets all the time and our bodies filter them out. I’m sure the same would be true of trans fats in small amounts. The problem now is that it is in high quantities in many foods, and the effect of trans fats is cumulative.

If you know your diet to be otherwise free of trans fats, this might not be an issue for you. Trans fats are required to be listed on the label of all foods, but dietary supplement labeling is different. Because the serving size of FCLO is so small, there could be over 20% trans fats in the product and they would not be allowed by the FDA to put that on the label. (2)

Dr. Weston A. Price warned decades ago that cod liver oil had some toxins in it, and to use it in small amounts. He also said that because of the synergistic effects of using it with high vitamin butter oil, the same effects could be achieved with much smaller doses.

Green Pasture touts their product as wholly unique and is very up front that “this product is not for everyone”. Whether this unique product is any more dangerous than other CLOs, and the issues listed above are simply from overdosing, I do not know.

WAPF basically blamed Dr. Ron’s heart failure on FCLO overdose, implying irresponsibility on his part. That would mean that too much FCLO is dangerous, but how much is too much? For years, WAPF recommended 6-12 times the dosage that GPP now has on its website and labels. Thankfully, those references have now been removed and they are only recommending a dosage a little more than 2 times the GPP recommendation.

They still recommend putting FCLO into baby formula and the dosage is very high, because it is based on their previous recommendations and hasn’t been updated. I would recommend not putting any cod liver oil in homemade baby formula, but if you think you need it, I would advocate that you use a different one until more is known about this issue and its safety.

It is certainly possible that this unique product may have unique beneficial properties as they say, and it may also be unique in its detrimental properties. Since it is unique, all of the studies that have been done on CLO toxicity, safety, and benefit do not necessarily apply to FCLO.

I think the takeaway from all of this is that Cod Liver Oil, in any form, is not a whole and complete food. It is an extracted, highly concentrated product, and it should be used with care, perhaps treated as carefully as a medicine (which seems to be how Dr. Price employed it).

Beeyoutiful's Second Response to the Controversy: the Weston A. Price Foundation & Green Pasture Fermented Cod Liver Oil

4) Question: Is Green Pastures FCLO diluted with a vegetable oil?

Answer: I have not been able to confirm yes or no. A very prominent marine oil scientist thinks that it is. Initially, I thought that the trans fats present in that one test by Dr. Daniel were compelling evidence as to the presence of a vegetable oil, but that it could have been just one batch.

Now we see that there are levels of trans fats in all recently tested batches. Chris Masterjohn in his response said that dilution with a veggie oil was certainly the easiest explanation, but that it could also be a result of microbial activity. Since GPP are “fermenting” and “adding a starter”, you would definitely think there would be microbial activity, but there is not evidence pointing to that as a source.

David Wetzel says that they don’t even have vegetable oil in their kitchen, much less in their plant. He has also said that they don’t use or add vegetable oil in their process. What he has not said is that the trans fats are NOT from vegetable oil. This could be significant, or not. It could be that the cod livers are put in vegetable oil before being frozen. It could be something else in the way that they are handled before they even get to GPP. Or there could be no vegetable oil at all, from catch to bottle, and the trans fats are from something else entirely.

Without more transparency, it’s simply impossible for us to know. If the trans fats are coming from a veggie oil, that is something that can probably be fixed in GPP’s production process. That some microbial activity could be creating a harmful substance is not a happy thought, and I don’t know how they could fix that.

Beeyoutiful's Second Response to the Controversy: the Weston A. Price Foundation & Green Pasture Fermented Cod Liver Oil

5) Question: Is Green Pasture FCLO actually from cod livers?

Answer: “Yes.” And “No.” And “Yes” again. And “No” again.

I’ll explain. First it was reported by people close to GPP that they “only” used 10% Pollock livers, and that they would have put that on the label if only they had been asked or had known that it was important to people.

Then, WAPF said in their Q&A that GPP “uses mostly Pacific Cod but also some Alaskan Pollock”. It took more than a month before we heard from GPP that in the past they have used Pollock, but this season they are using Pacific Cod. They did not mention a quantity of Pollock or whether it was seasonal, whether all batches were a certain percentage, or some a high percentage and some low or none.

We also got confirmation from them that all of their fish is sourced from the Pacific and none from the Atlantic or the Arctic, as many of us had been led to believe by statements such as, “The fish used in our Fermented Cod Liver oil and Skate Liver oil are exclusively wild caught in and around the Arctic region.”

So “Yes” FCLO is actually from Pacific Cod livers. But “No” it seems that Pollock livers were also used. But then “Yes”. Turns out that Alaska Pollock was reclassified about 18 months ago to be in the same genus as several other codfish and is scientifically considered to be the closest relative to the Atlantic Cod. But alas, “No”. The FDA does not allow Pollock to be marketed as Cod at this point in time. If you’re confused, you’re not alone. (1)

Beeyoutiful's Second Response to the Controversy: the Weston A. Price Foundation & Green Pasture Fermented Cod Liver Oil

6) Question: What about the High Vitamin Butter Oil?

Answer: There has been no update on HVBO from GPP. It has not been mentioned. No mention of rancidity or not, no testing of it, no mention of sourcing or handling. Nothing. We did get confirmation from WAPF of it being sourced from Argentina, but no other information and no response directly from GPP. The last references of “Great Plains” sourcing were also removed from the GPP website.

7) Question: Where is the WAPF in all of this?

Answer: Here, to me, is the saddest part about this whole giant mess: WAPF seems incapable of objectivity with regards to Green Pasture Products. Some have speculated that this is so because of some secret financial arrangement or a family tie. I don’t think so, but the truth is that there is a special relationship between WAPF and GPP that does not exist with any other vendor.

Whether it’s nepotism, cronyism, or some other “-ism”, there is something going on there besides just the vendor-organization relationship that WAPF has tried to present. They have said they would act the same way with any other vendor, yet,  they have actually behaved in opposite ways to other vendors of cod liver oil products in the past.

There are numerous articles written by David Wetzel and others on the WAPF website that are solely for the promotion of Green Pasture Products. No other vendor has enjoyed that benefit. WAPF is acting as though they are a marketing and PR firm for Green Pasture products, and has for years. They could not be working for them any harder if they were paid to do it.

Beeyoutiful's Second Response to the Controversy: the Weston A. Price Foundation & Green Pasture Fermented Cod Liver Oil

As WAPF members and vendors, we expected them to be the gatekeepers, to research and review and thoroughly vet products for us in an objective manner. And they appear to have no capacity to be impartial when it comes to Green Pasture Products. Instead, they have banned a vendor and featured speaker at their conferences who attributed his heart failure to FCLO. They say this is their policy, and it has been enforced before, but only ever in regards to GPP, to my knowledge.

We’ve even heard that The Weston A. Price Foundation is threatening to expel local chapter leaders for saying anything negative about Green Pasture Products. Reportedly, they are coaching chapter leaders in how to talk their concerned members through this GPP issue. They are patrolling WAPF-branded Facebook chapter sites and demanding that links to anything but pro-GPP info be removed, and threatening lawsuits if they are not removed. They have canceled the Santa Cruz chapter for linking to a blog that is reporting the other side of the story. They are removing chapter leaders from their private Yahoo group if they say anything negative about GPP, question GPP, or question the way that this situation is being handled. WAPF has completely lost its objectivity and integrity in how it is handling this situation.

Sally Fallon Morrell tells a story that is a perfect example of how completely screwy this has gotten:

“When David Wetzel, the owner of Green Pasture, first began making the fermented cod liver oil, he sent it to NDI laboratories in Canada (associated with Guelph University) for Vitamin D testing. He was surprised when these tests came back showing Vitamin D2, with very little or no D3. Mr. Wetzel immediately communicated this to us. He then sent the oil to the University of Wisconsin for a rat assay test to see whether the oil had Vitamin D activity—and the answer came back yes.  Mr. Wetzel has shared all this on his website. The rat assay is considered the gold standard of Vitamin D testing. The University of Wisconsin then recommended UBE Laboratories in Fullerton, California for further testing, and these labs found mostly Vitamin D2 as well.

The prevailing view at that time—one that we repeated at WAPF—was that Vitamin D2 is ineffective and possibly toxic.  Of course, these discoveries led us to reconsider this view—after all, cod liver oil cures rickets.  This is something we are looking into further and will be sharing with our members in Wise Traditions. There are hundreds of Vitamin D metabolites, so the probable explanation is that the natural D2 metabolites in cod liver oil have different effects from the synthetic D2 added to vegetarian foods, used in vitamin drops, etc.  We encourage product manufacturers like Mr. Wetzel to share information like this to help advance knowledge about nutrition.” (5)

So, to recap, GPP was expecting D3 in the product. They found only D2 so this was reported to WAPF immediately because it was unexpected. They sent it to another lab, just to confirm that it was really D2 in the product, and it was. Nobody has said that D2 is not effective, just that it is not as effective as D3, and that it can be toxic. Natural D2 is found in plants. Natural D3 is found in animals. Cod liver does not have significant D2, but is high in D3. And good CLO that doesn’t strip out vitamins and add them back in or add back synthetic vitamins also has D3. Tests showed that GPP has D2. There are two possibilities I can think of.

  • The fermentation process is converting D2 to D3.
  • The lab results were wrong. Twice. Sending to a marine biology/chemistry lab to triple-check seems like a no-brainer, but it wasn’t done. Why not?

Considering all of the research on D2 vs D3, and WAPF’s acceptance of all of that information (one would assume after examining the studies, their methods, and conclusions), and perpetuation of that information, we should find it interesting that they were willing to abandon it all because D2 was found in FCLO. This was at the beginning, when FCLO was first made. There was no research, no studies, no anecdotal evidence, no human trials or testimonials. There was nothing. Yet, because D2 was shown to be in this product, they completely changed their minds about D2’s value.

On the one hand, there is decades of research into vitamins with tons of studies by reputable scientists. On the other hand, a guy uses an ancient putrefaction method for cod liver oil extraction, adds some bacteria to the process, and calls it fermented. Now suddenly, oh, D2 isn’t so bad! (WHAT?!) They determined in their minds beforehand that FCLO was best and therefore anything CONTAINED in FCLO was best, and they were and are willing to abandon actual research, ignore health complaints, put the best possible spin on test results, bury information, make up new narratives, put out false information, fail to disclose negative test results, suppress free discussion of the issue in their circles, and to the extent that they can, punish anybody that counters (or even just questions!) this PR campaign.

WAPF is the organization that we were trusting to give us good information about health and food. That’s not to say that they haven’t put out good information. The problem now is that we have to sift through that information and question all​ of it, because we don’t know what’s legitimately good and what’s been compromised by some preconceived ideology.

It seems reasonable to me to expect that when WAPF drastically lowered their recommended daily dosage of FCLO, they would have announced it. I mean, why would they change it? More FCLO means more nutrients, right? So taking more is good, right? But they did change it, and changed it to a much lower dosage.

Can you think of any reason that they would do this other than health concerns, that perhaps too much might be toxic? I cannot. And if that is the case, then wouldn’t it be responsible to announce that you are lowering your recommendations so that people could lower their dosages? Unless, of course, people started asking questions and you had to explain that you were doing so over toxicity concerns, but that would certainly undermine public trust in the product.

And it’s interesting to me that the WAPF didn’t just change the dosage. They are acting like they never ever recommended any OTHER dosage, and that anybody that took “too much” was not following their recommendations. I can only think that they are trying to protect GPP and themselves from litigation, protect GPP sales, and perhaps there is an element of pride involved as well.

Beeyoutiful's Second Response to the Controversy: the Weston A. Price Foundation & Green Pasture Fermented Cod Liver OilThere is a lot more, but it makes me weary just to think about writing even more about it, so what I’ve covered here will suffice. Except for this all-important thing that I need to say. At Beeyoutiful, we’re completely committed to being a full disclosure company. If we know an ingredient is in the product, we put it on the label. Period. We have an established process that we put any companies and products through before we use or carry them, and one of the steps of this process is to verify that they too are full disclosure.

To our chagrin and shame, we realized that we had never put Green Pasture through the normal process we do with every other vendor. We trusted the Weston A. Price Foundation endorsement of both the product and company so explicitly that we didn’t put Green Pasture Products through our normal checklist. With the way WAPF went on about them, this had to be pretty much the best product EVER, right? (What’s the old adage about when something seems to good to be true…?!)

I feel like we were misled and fooled, but that’s on us. We should have done more research. We should have asked more questions. Regardless of how this situation eventually turns out, or what facts come to light, we endorsed both the company and products without adequate research.

We didn’t know sourcing. We didn’t know vitamin content. We didn’t know a lot of things. I’m so sorry. We messed up. I can imagine some reading this might feel disappointed in us. Indeed, we’re disappointed in ourselves. We have definitely learned a painful, yet valuable lesson through this.

I hope you can find it in your hearts to forgive us. 

Please post your comments or questions below, and I will try to address them to the best of my abilities.

Dig deeper: 

33 comments

  • Thank you so much for taking the time to write and research this. As a longtime member of WAPF, I am saddened by the lack of transparency and integrity from both GPP and WAPF. And thanks, too, for your transparency. It’s part of the reason why I recommend your products to friends and family and won’t allow my daughters to wear make-up from anyone else!

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  • Thank you for that very thorough response. 🙂 What are your recommendations to replace GPP FCLO and get the same benefits we thought we were getting from COP FCLO? I have only been using it a short time and am relatively new to the whole foods lifestyle. I have 7 children ages 10 mos to 12 years, and a husband who has diabetes and hypertension. My kids actually liked the orange flavored GPP FCLO.

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    • It is best if you can get the nutrients that you need from whole foods. Fish and grass-fed dairy are probably your best bets for replacing what you thought you were getting from FCLO and HVBO. If you feel like you need to use a concentrated supplement like cod liver oil, the research that we’ve done on Rosita Extra Virgin CLO seems to indicate it is excellent. Their no-heat production process is impressive. Their Ratfish oil is an even more concentrated supplement. Organic 3 makes a very good butter oil. We carry both of these products but are currently out of stock on the EVCLO. We’re doing research on more CLOs now and hope to have something else added on in the next few months. We’ve heard good things about NutraPro and Carlson’s.

      I have a friend who also had diabetes and hypertension and after 1 year on the ketogenic diet, gotten off of his diabetes medication, BP is 120/90 and he lost 70 pounds. I don’t think the ketogenic diet is a good long term solution, but it is similar to WAPF, paleo and primal, so it would be easy to transition.

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  • Great write up. Pretty much reflects what so many have been feeling but you are able to articulate it in a very clear way. Thank you.

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  • Bummer way to start my day. Not sure what I’ll do now. Thank you, Smart and Ethical Steve.

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    • Totally, Nancy. It’s disappointing and depressing. We’re going to give the Paleo-Primal-Price foundation a try. If it is at all what they are claiming, it might be a good fit for us, and we may see about opening a chapter in our area. I know that you know more than many how important fellowship and positive peer reinforcement and encouragement in this area of diet and healthy lifestyle is. Miss you guys!

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      • But do you really want to support paleo/primal and their entire lack of starchy carbs? I can’t do that. Been there done that. I need study and prayer time before deciding what to do. Would love to visit in person and learn more.

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  • Hi,
    Thanks for your honest response to this issue. I personally never have used any of GPP, but I do own the book Nourishing Traditions. In light of all that has come out with the WAPF not being completely honest ,do you believe that Nourishing Traditions is a reliable resource for nutrition and healthy living? Also where is Sally Fallon in all of this?
    I had the opportunity to hear her speak about a year ago and I really enjoyed it, but now I’m questioning what I’ve read in Nourishing Traditions.
    Thanks !

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    • Hi Mari,

      This is something that we’ve kicked around. I still feel like Nourishing Traditions has some great recipes in it for healthy eating. One are where we DEFINITELY feel like we can’t trust WAPF is the area of vitamin claims. There is more information that I can’t share because I can’t show solid evidence and reveal sources, but basically the lab that Sally and GPP have been using that show high vitamin content, is highly suspect. Apparently it is a small operation, basically one man, and he’s not using standard methods. In fact Sally said that they can’t post his test results because he won’t disclose his methods. But they still make claims based upon these test results. As we go forward, we will definitely be reading things from that source with a degree of skepticism. And if something seems incredible or too good to be true, it probably deserves some research to confirm. I think we’re all going to have to use some common sense. 🙂

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    • Mari, I neglected to answer your question about where Sally is in all of this. Sally IS WAPF. There is nothing that happens there, that she doesn’t approve. I watched a video interview with Dr. Kaayla Daniel on Cheeseslave.com yesterday in which she claimed that Sally has said to people that she IS the WAPF board. Dr. Daniel was the vice president of that board so I would think that she would know. Sally started the foundation. Sally runs the foundation. Sally appoints new board members. Sally personally reviews and approves each new vendor and advertiser. Sally even approves the menu and speakers for every single chapter meeting. You can be confident that anything that WAPF is doing is because that is what Sally wants done.

      Liked by 1 person

  • Thank you so much for this. I have recommended this product and it was recommended to me by many trusted health advocates. My doctor even recommended it. I am very disappointed in the Weston Price Foundation, they should have done better considering the role they play in the health community. I appreciate you being honest concerning your findings. If only all companies had the same integrity as you. Thank you again, Rebecca

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  • Re: trans fat.

    Dr. Sathivel states in this article: http://www.greenpasture.org/fermented-cod-liver-oil-butter-oil-vitamin-d-vitamin-a/scientific-analysis-of-oxidation-test-reports-by-dr-subramaniam-sathivel/

    “The above-mentioned commercial analytical labs report showed an average of 1.19% trans fatty acids in your oil. It is normal to have very low level of trans fatty acids. Some labs may not report trans fatty acids in fish oil because they are, if present, present only at undetectable level or at levels less than 1%.”

    http://www.greenpasture.org/fermented-cod-liver-oil-butter-oil-vitamin-d-vitamin-a/what-do-the-scientists-say/

    “You have routinely had commercial analytical labs analyze samples of your fish oil. The data obtained did not show trans fatty acids, that is, if trans fatty acids did exist, they were present at a very low level. In general, fish oils may contain very low levels of trans fatty acids. Low levels of trans fatty acid may naturally present in bovine milk fat (0.6 – 3.9%) (Månsson, 2008), beef meat (3.6%) (Woods & Fearon, 2009), and dairy creams (3.02 to 4.11g/100 g) (Jan et al., 2011). This may be the result of microbial hydrogenation of cis-unsaturated fatty acids in the stomach of ruminant animals (Bauman & Griinari, 2003).” – Subramaniam Sathivel, PhD

    Dr. Sathivel is the Professor of Food Engineer at the School Nutrition and Food Sciences and the Department of Biological and Agricultural Engineering, Louisiana State University Agricultural Center (LSUAC). Before joined LSUAC, Dr. Sathivel worked five years as an Assistant Professor of Seafood Processing and Engineering at the Fishery Industry Technology Center (FITC), University of Alaska Fairbanks, Alaska. He is responsible for the food process engineering laboratory at the LSUAC, where his projects include design and development of an adsorption technology to purify fish oils and fish protein, value added products, edible films and edible coatings. Dr. Sathivel has published 60 refereed articles, two popular articles, five book chapters, and six pro­ceedings. Dr. Sathivel has an equally respectable record of published abstracts and professional presentations, many of which were invited talks at international scientific meetings and conferences.

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    • Thank you for the comment. Yes, I read that. Maybe I didn’t mention it in the article, but I have read just about everything that is available from all sources. I have spent way more time on this than I probably should have, but I was interested in getting to the truth. Unfortunately, I think the absolute truth on this is something that nobody knows at this time, and only more studies, research, transparency and even collection of anecdotes (good and bad) along with some follow up to try to create a demographic map may be the only way to achieve significant truth.

      I have some problems with Sathivel’s explanation of trans fats. They might be significant, they may not matter at all. First he says that it is normal to have “very low levels”. He doesn’t say what very low levels means. Is that “under 10%”, “under 1%”, “under 0.1%”, “under 0.01%”? We don’t know. That’s a problem. If they are normal, than it should be very well established what those levels are. That he didn’t mention a range in the context of this discussion, makes it seems like it might be smoke screen and not actually relevant. What I mean is this: if it is normal to have trans fats in fish oils in the 1-2% range, you state that fact, show your reference, and the matter is done. You are a scientist. This is what you do. No further explanation is needed. He gave ranges on the other products, but not on the fish oils. That he didn’t seems to indicate that the trans fats are higher than the normal “very low levels”.

      He also says that GPP has routinely had testing done through the years that showed insignificant or undetectable levels of trans fats. That’s not the case now. Something has changed. Either there is something different with the sensitivity of the testing, or there is something different with the product or methodology.

      The reference to trans fats in dairy and meat products also seems like a smoke screen. For one thing, the type of trans fats in ruminant products have been demonstrated to be beneficial. Until the trans fats in FCLO are demonstrated to be of the beneficial variety, then citing that they are present in other items that we consider to be healthy is irrelevant and misleading. As he seems to be a pretty sharp guy, I can’t imagine that he is unaware of what he is doing.

      In the end, I guess that way I look at this is like I’m a juror listening to testimony. Expert testimony is usually paid for and ALWAYS supports the side that is presenting it and is never unbiased third party. It’s up to the jurors to sort through the evidence. That’s what I’m trying to do.

      Dave Wetzel has informed me that there is more information on trans fats coming out shortly from them, so I will examine that when it is available.

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  • The scientific analysis conducted by Dr. Jacob Friest, PhD Organic Chemistry, Chair of the Nebraska Section of the American Chemical Society. It is a direct rebuttal to Dr. Daniel’s report: http://www.greenpasture.org/fermented-cod-liver-oil-butter-oil-vitamin-d-vitamin-a/scientific-analysis-of-dr-jacob-friest/

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  • Scientific Analysis of Dr. Jacob Friest

    What follows is the scientific analysis conducted by Dr. Jacob Friest, PhD Organic Chemistry, Chair of the Nebraska Section of the American Chemical Society. He had access to any test results he wanted. We tested anything he wanted and provided samples from our vats for further independent evaluation. Below is just a sample of the many tests he reviewed:

    Midwest Laboratories, Inc. Report of Analysis FCLO 20946ABS September 23, 2015
    Midwest Laboratories, Inc. Report of Analysis FCLO 07252ABS September 23, 2015
    Midwest Laboratories, Inc. Report of Analysis FCLO 05751ABS September 23, 2015
    Midwest Laboratories, Inc. Report of Analysis FCLO 31641ABS September 23, 2015
    Midwest Laboratories, Inc. Report 15-265-4118 FCLO September 22, 2015

    Eurofins Nutritional Analysis Center Certificate of Analysis AR-15-QD-115048-02
    September 23, 2015

    Midwest Laboratories, Inc. Report of Analysis FCLO C14061815 September 15, 2015
    Midwest Laboratories, Inc. Report of Analysis FCLO C15061815 September 15, 2015
    Midwest Laboratories, Inc. Report of Analysis FCLO C16061815 September 15, 2015
    Midwest Laboratories, Inc. Report of Analysis Fermented Liquid Fish Brine September 28, 2015

    Fermented Cod Liver Oil (FCLO): Investigation of Green Pastures Fermentation Process and Food Safety Implications.

    Author: Jacob A. Friest, PhD Organic Chemistry, 2015 Chair of the Nebraska Section of the American Chemical Society.

    Release Date: 27 October 2015

    Introduction

    A recent article published by Dr. Kaayla T. Daniel, “Hook, Line and Stinker! The Truth About Fermented Cod Liver Oil” has recently raised concerns regarding the safety of fermented cod liver oil (FCLO) products manufactured by Green Pastures. David Wetzel, owner of Green Pastures, requested that I conduct a review of Dr. Daniel’s assertions to determine their validity and to further evaluate Green Pastures product testing to ensure that their product is safe.

    Fermentation

    The key assertion of Dr. Daniel, that fermented cod liver oil (FCLO) as manufactured by Green Pastures cannot be from the fermentation of cod liver oil (CLO) or fats, is confirmed. Fermentation experts would all agree with Dr. Daniel that oils/fats cannot be fermented. However, Green Pastures does not claim, neither do they advertise, that their product is produced by the fermentation of CLO but by that of the carbohydrates found in the whole cod livers themselves. As Dr. Daniel pointed out in her article, cod livers contain between 1 and 2 grams of carbohydrates for every 100 grams of liver. Typical fermentation processes only require 0.62 grams of carbohydrate per kilogram to lower the pH by 0.1 pH units1. Based on the 1 to 2 grams of carbohydrate/100 grams of liver, this would give rise to a total drop in pH between 1.6 to 3.2 pH units. If we assume that the process of fermenting a cod liver begins at neutral pH of approximately 7.0, the natural levels of carbohydrate found in cod livers would be sufficient to lower the pH of the final fermented product batch to between 3.8 and 5.4. This brings us to the question of what is an acceptable pH range to achieve a safe-for-human consumption product. Dr. Daniel asserts that the pH needed to prevent food spoilage for true lacto-fermented product is less than 4.6. However, as published by the Food and Agriculture Organization of the United Nations (FAO)), raw fermented sausages are only moderately acidic with a pH range of 5.0-5.5 and are safe for human consumption2.

    In her article, Dr. Daniel indicates that the pH of the bottled FLCO product is between 5.17 and 6.0. After questioning David Wetzel about Green Pastures fermentation process these numbers are as expected and in no way disprove that effective levels of fermentation were achieved to ensure product safety. To make sense of this I will first describe Green Pastures fermentation process: (1) the frozen cod livers are added to the fermentation vats along with Green Pastures starter culture and salt. The vats are then sealed and allowed to ferment. This process produces three distinct layers within the fermentation vats. At the bottom of the vat is the solid liver material and sediment. On top of this is a water layer which is formed as water is released from the cod livers during fermentation. On top of the water, an oil layer is formed. (2) After the fermentation is complete, this top layer containing the coveted oil is pulled from the fermentation vat and centrifuged to remove all sediment and liver material as well as separate out any water that was pulled from the vats with the desired oil. It is important to understand the layers formed during the fermentation process and how the oil is separated/purified by centrifugation to understand why the FCLO pH falls outside the normal pH range for fermented animal meat products. This is because the major acid by-product of a lacto fermentative process is lactic acid. Lactic acid is a highly water soluble acid and is extracted from the resulting oil during the pulling and centrifugation of the oil. To be certain of this, Green Pastures has measured the pH of the resulting water layer (brine) at the end of the fermentation process and found it to be between 4.8 and 5.04 (see attached testing from Midwest Laboratories). These pH values fall well within the normal pH levels accepted for the fermentation of raw meat products as described by the FAO.

    Determination of FCLO Rancidity

    There are two pathways by which fatty esters or triglycerides become rancid. Hydrolytic rancidity, which occurs when the fatty esters are hydrolyzed to free fatty acids, and oxidative rancidity leading to the formation of hydroperoxides and aldehyde by-products. According to Dr. Daniel’s article, fatty acid levels based on acid value are the most reliable markers to determine the hydrolytic rancidity in FCLO. However, acid value is determined by an acid/base titration with potassium hydroxide or sodium hydroxide and is not selective for fatty acids. Acid value is a measure of total acids in a sample. Since acids are a desired by-product of lacto fermentation it is not surprising that the acid values for FCLO are high since it would undoubtedly be expected to contain other free acids, not related to fatty acids, but rather by-products of carbohydrate fermentation. Therefore, acid value determination is not a good measure of hydrolytic rancidity for fermented cod liver oil since it is not selective for measuring only free fatty acids.

    Dr. Daniel also states that fatty acids, the product of hydrolytic rancidity, are toxic to cell membranes. Unfortunately, this is a tactic to add scare value to her argument, and in the case of potential fatty acids being present in FCLO, is completely untrue. What Dr. Daniel has failed to state is how fatty esters or triglycerides are metabolized by the body3. When fatty esters and triglycerides enter the intestinal tract they cannot be absorbed by the duodenum. Instead, pancreatic lipase and bile hydrolyze the ester bond and release the fatty acids which are then absorbed by the duodenum. In this regard, if there were any free fatty acids present in FCLO, they would truly be in a “pre-digested form” and more readily taken up by the absorptive enterocyte cells lining the intestines where they are reassembled into triglycerides and packaged together with cholesterol and proteins to form chlyomicrons. The resulting chlyomicrons are excreted from the cells and collected by the lymph system and mixed into the blood. Various tissues can then recapture the chlyomicrons and release the re-built triglycerides to be used as a source of energy. In short, our bodies would take the ester or triglyceride form of cod liver oil and hydrolyze it to the free fatty acid form so our bodies can adsorb it. Free fatty acids in FCLO would not require this digestive step and would be readily adsorbed by the intestinal enterocytes directly and reassembled into triglycerides for transport.

    Oxidative rancidity in fatty oils occurs as oxygen reacts with the oils to form hydroperoxides. Secondary to this is the decomposition of the hydroperoxides over time, to aldehydes and other carbonyl compounds. The key indicators for oxidative oil rancidity are to measure the oils peroxide value, p-anisidine value, or a TBA/TBARS levels. As Dr. Daniel explains in her article, peroxide value and the TBARS test are poor indicators of rancidity for FCLO due to the breakdown of the peroxides to aldehydes, and in the case of the TBARS test, interfering compounds in the product matrix. However, since a primary concern of rancidity is the formation of hydroperoxides and other reactive oxygen species, I would contend that peroxide value is indeed a valuable snapshot of the product in its current state, showing that reactive oxygen species are at safe levels for human consumption. In this regard, the peroxide values for several FCLO lots tested at levels between 2.9-6.7 meq/Kg, well below the levels established by the FAO, indicating that FLCO is not rancid.

    The TBA or TBARS tests are also measures of aldehydes present in oils and are very commonly used to determine oxidative rancidity of older oils. Specifically, these methods are concerned with the detection of malondialdehyde formed during oxidative degradation of oils, which is reactive and potentially mutagenic and has been found in edible oils that have been heated. It is interesting that 2 out of the 3 labs that tested FCLO for Dr. Daniel reported safe levels for the TBA and TBARS values yet she is quick to disregard this testing as not being a valuable indicator of whether FCLO is safe since the formed aldehydes must have reacted with the proteins/DNA in the cod liver itself. Since the key question is whether FCLO is safe, it is a very important test! The process by which Green Pastures separates FCLO from the fermentation mixture likely removes all protein from the oil. First, the proteins/DNA would be more water soluble and therefore remain in the water layer from the fermentation process and secondly, if any solid liver material was removed with FCLO during the “pulling” of the oil it would be completely removed during centrifugation. Therefore, if any oxidative rancidity of the pure FCLO were to occur, the aldehydes, especially malondialdehyde, would not be able to react with any proteins/DNA since it has been removed from the oil. Therefore, these tests are in fact demonstrating again that FCLO is not rancid.

    The third testing method discussed by Dr. Daniel for determining oxidative rancidity is p-Anisidine Value (AV). This is a test which measures aldehyde levels that arise as secondary oxidation products formed during the decomposition of hydroperoxides. The determination of aldehyde levels is a valuable indicator in determining oxidative rancidity in older oils. Not surprisingly, all testing results by Dr. Daniel are well below FAO guidelines, yet she concludes that the testing is not valid since many of these aldehyde by-products are volatile and escape to the environment before testing can be carried out. However, whether Dr. Daniel’s testing was performed on freshly pulled FCLO right out of fermentation or on the finished product, the testing PV should provide an accurate picture of late-stage oxidative rancidity. Why is this? Because the fermentation process occurs in a sealed vat, meaning that any aldehydes formed during fermentation cannot be lost, and since the finished product is purified by centrifugation and not distillation it would not be expected that these aldehydes would be lost at this point in the process as well. In fact, unless the labs who performed the testing of FCLO left the FCLO sample bottles uncapped and exposed to the air for extended periods of time, it is unlikely that this is a logical argument as to why FCLO tested within safe limits for all three testing methods (PV, TBA, and AV). What seems more likely is that Dr. Daniel is coming to these conclusions based on the acid value testing, even when all other results are to the contrary, and rather than consider why the acid value testing might be flawed, she simply discredits all other testing to support a hypothesis. Dr. Daniel’s conclusion about her own testing suggests that she began her investigation into FCLO already convinced that FCLO was rancid and this left her blinded to results that have clearly demonstrated otherwise.

    Finally, let’s consider whether either of these forms of rancidity would even be expected to occur. As far as hydrolytic rancidity is concerned the conditions that would favor this process would be either very acidic or highly basic conditions. The fatty esters would be expected to be very stable in the pH range for which FCLO is produced. Additionally, since water is required for the hydrolysis of the fatty esters during hydrolytic rancidity, once the FCLO is pulled and centrifuged in the Green Pasture process, most of the water is removed thereby reducing the likelihood of hydrolytic rancidity. Lastly, oxidative rancidity is also greatly minimized in the Green Pastures fermentation process since it is carried out in the absence of oxygen which is required for hydroperoxide formation to cause oxidative rancidity.

    Levels of Biogenic Amines Found in FCLO

    Biogenic amines (BA) are organic, basic, nitrogenous compounds of low molecular weight that are formed by the decarboxylation of amino acids and occur due to biological activity. BAs occur naturally in animals and humans and are important as neurotransmitters, blood pressure regulation, and cellular growth regulators. However, BAs can become hazardous if their levels reach a critical threshold. The most important BAs found in food products are histamine, tyramine, putrescine, cadaverine, and phenylethylamine. Biogenic amines, especially histamine, are associated with the pathogenesis of food poisoning and Scombroid fish poisoning (SFP)4. SFP occurs in healthy individuals when a dose of 50 mg of Histamine is consumed from a single serving of a fish product (250g serving size).4 This correlates to fish with histamine levels exceeding 200 mg/Kg. For fish to contain such levels of histamine, which would cause SFP, the following conditions must be met4:
    the fish are of a species that contain sufficient free histidine to be converted to histamine,
    the presence of histamine producing bacteria,
    conditions that support the growth of histamine producing bacteria and their production of the enzyme histidine decarboxylase enzymes.
    In the case of FCLO, cod is not a species of fish that is associated with having high or sufficient levels of histidine to lead to histamine levels of 200 mg/Kg4. The conditions for fermentation do support the growth of histamine-producing bacteria, however, this is easily controlled by the use of starter cultures that do not contain amino acid decarboxylase enzymes. Moreover, the risk of SFP is greatly mitigated even before Green Pastures receives the frozen livers by the implementation of a HACCP plan. An HACCP (hazard analysis critical control point) is a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product. Controls for histamine, as well as other biogenic amines, in susceptible fish have been identified5. The risk mitigation strategies, which have been adopted by the FAO/WHO, detailed in the above reference include the following:
    post-harvest chilling of fish,
    gutting and gilling of susceptible fish,
    freezing and refrigerated storage,
    use of decarboxylase free starter cultures for fermented fish products.
    Green Pastures has assured me that an HACCP plan is in place for the harvest and handling of their cod livers from the harvesting of the fish all the way through the fermentation process.

    In addition to utilizing a HACCP plan by Green Pastures, the most important question to ask is whether FCLO is expected to be at risk for containing high levels of biogenic amines. The answer is no. This is due to the way in which Green Pastures produces FCLO. Since biogenic amines are highly water soluble and not fat soluble, any biogenic amines formed during fermentation, would be extracted to the aqueous layer of the fermentation vat. After removal of the water and sediment layers from the FCLO by centrifugation, biogenic amine formation is completely eliminated in the finished product since none of the required precursor amino acids would be present.

    Analysis of FCLO Samples by Midwest Laboratories and Eurofins Nutritional Analysis Center

    In response to the article published by Dr. Daniel, Green Pastures sent FCLO samples to Midwest Laboratories and Eurofins Nutritional Analysis Center to determine the rancidity profile of FCLO based on FAO guidelines and testing recommendations. I would like to make special note of the quality and authenticity of the reports provided for this investigation by Green Pastures. The reports were provided as prepared by the testing labs and include sample lots, testing dates, and by whom the testing was performed. It is unethical to publish redacted test results or to omit these key identifiers. By reporting her findings in this way, Dr. Daniel has made it impossible for any other labs to corroborate or discredit her testing and by doing so invited the authenticity of the data to be called into question. All lab tests results from Midwest Laboratories and Eurofins Nutritional Analysis Center clearly demonstrate that FCLO is not rancid with the exception of acid value which is higher than recommended by the FAO. This can easily be explained by the nonselective nature of this test and the fact that all fermented products are expected to contain elevated levels of acids, not necessarily free fatty acids, but likely acid by-products of carbohydrate fermentation (see attached reports).

    Conclusions

    Testing of FCLO produced by Green Pastures clearly demonstrates that FCLO is safe for human consumption and displays no signs of product rancidity or significant levels of biogenic amines. Moreover, after reviewing Dr. Daniel’s arguments regarding the safety of Green Pasture FCLO, it is clear that her analysis of the issue is flawed and her conclusions are incorrect and have misled the public. Whether this was intentional or unintentional is yet to be seen. Furthermore, the authenticity of her data is questionable since the key identifiers that would allow independent testing by other labs have been withheld. It is recommended the Dr. Daniel provide full transparency in her testing and data, and review the nature of FCLO and the Green Pastures fermentation process. On the other hand, Green Pastures has provided more than adequate testing to prove that FCLO is in fact not rancid, as well as to support their claims regarding the levels of fat soluble vitamins in FCLO.

    References

    1. Fermented Meat Products: Production and Consumption. Herbert W. Ockerman and Lopa Basu, Ohio State University, Columbus, OH

    2. Meat Processing Technology, Food and Agriculture Organization of the United Nations, 2007.

    3. Fats and Oils in Human Consumption: Report of a Joint Expert Consultation. FAO 1994.

    4. Public Health Risks of Histamine and other Biogenic Amines from Fish and Fishery Products: Meeting report, 23-27 July 2012, Rome, Italy

    5. Scientific opinion on risk based control of biogenic amine formation in fermented foods. EFSA J., 2011, 9(10): 2393.

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    • Jacob Friest has a PhD in organic chemistry, and works for a pharmaceutical company named Novartis doing drug degradation testing. He’s been out of school for about 3 years. Not bad credentials but not a lipid scientist or marine oil specialist either.

      I can summarize the entire “fermentation” section with this – lactic acid fermentation resulting in a low pH does nothing to ensure the product safety of an oil. Low pH level inhibits microbial activity. That is not a problem with an oil. Oils are subject to oxidation – especially PUFAs which are high in CLOs. Low pH resulting from fermentation protects products like sour kraut from molds and bacterium which would render the product unsafe. I don’t understand why a chemist that new anything about oils and/or fermentation would be going on such. One would assume that he should know both to be qualified to render a meaningful judgment on the safety of FCLO. If you came away from those two paragraphs thinking that fermentation somehow protected the product from going bad, well, I can’t help but think that was the intention. The resultant low pH probably protects the liver from the microbial ravishers, but the oil is just as subject to oxidation as ever.

      The next section talks about FFAs. Here he says that the FFAs are actually low and that what we are actually seeing are the acid by-products of fermentation that we would expect to see. Of course, in a previous paragraph he said that those were removed in centrifuging. So . . . what to think.

      The next paragraph covers the Dr. Daniel’s assertion that FFAs are toxic to cell membranes. Strange that he would even bring this up as he just argued that there were not high levels of FFAs in the product so it wouldn’t matter whether they were toxic or not. I guess this is maybe a “just in case” scenario. He references natural metabolism in the body, and says that FFAs are merely “pre-digested”, which sounds eerily familiar to what Masterjohn said, but doesn’t actually reference any scientific works showing that elevated FFAs in foods are safe. However, if you google FFA safety, there are a LOT of links talking about FFAs effecting glucose metabolism. From what I can understand FFAs aren’t necessarily bad unless the blood serum level of FFAs gets too high and then this can lead to insulin resistance. This would be a much higher concern for overweight people apparently. A lot has been said about testing, so let’s skip over it. Everybody agrees that the tests show low primary and secondary oxidative markers for freshly opened bottles of product. I would like to go to the end of those two paragraphs and show you this: ” Dr. Daniel’s conclusion about her own testing suggests that she began her investigation into FCLO already convinced that FCLO was rancid and this left her blinded to results that have clearly demonstrated otherwise.” That seems strangely out of place in a scientific analysis, but what do I know?

      The next paragraph is very intriguing as he discusses whether hydrolytic rancidity or oxidative rancidity would even be expected to occur. “As far as hydrolytic rancidity is concerned the conditions that would favor this process would be either very acidic or highly basic conditions. The fatty esters would be expected to be very stable in the pH range for which FCLO is produced. Additionally, since water is required for the hydrolysis of the fatty esters during hydrolytic rancidity, once the FCLO is pulled and centrifuged in the Green Pasture process, most of the water is removed thereby reducing the likelihood of hydrolytic rancidity.” So, once it is bottled, we wouldn’t expect to see hydrolytic rancidity. Got it. But wait sir, what about during the fermentation process in salt water resulting in a very acidic environment??? That sounds like PERFECT conditions for hydrolytic rancidity, yes? “Lastly, oxidative rancidity is also greatly minimized in the Green Pastures fermentation process since it is carried out in the absence of oxygen which is required for hydroperoxide formation to cause oxidative rancidity.” So, there is minimal oxidative rancidity while the livers are in the vats, because after a short time, there just isn’t any more oxygen. I’ll buy that. But, but, what about after they are bottled? Oh right, there isn’t much oxygen there either. Well what about while they are being used, sitting at room temperature, opened up daily to allow fresh oxygen in. What about that?

      The next section is on Biogenic Amines. I just have a couple of thoughts on this long section. He mentioned a number of BAs. Then his entire argument centers around the only one that FCLO tests low for – histamine. He ignores all of the others. Then he concludes, “In addition to utilizing a HACCP plan by Green Pastures, the most important question to ask is whether FCLO is expected to be at risk for containing high levels of biogenic amines. The answer is no. This is due to the way in which Green Pastures produces FCLO. Since biogenic amines are highly water soluble and not fat soluble, any biogenic amines formed during fermentation, would be extracted to the aqueous layer of the fermentation vat.” Except that they still test high for BAs. So, you know, uh, weird, I guess. These BAs which Friest says would all sink down out of the oil during fermentation are the same amines that Masterjohn said, “I suspect that some negative reactions some people experience with FCLO are due to the amine content.” You know, the amine content that he found on the test results. He elaborated on Facebook, “In case this wasn’t clear from my comment above, I stated in my blog post and meant to reiterate this above that I think many people could negatively react to the biogenic amines in the FCLO.” Except Friest says that there aren’t really any. So, guess it is a further case of “pick your scientist”. Only this time it is two Pro-FCLO scientists which disagree.

      And the next section on testing, Friest once again takes a shot at Dr. Daniel, basically calling her unethical. What he says about the lack of ability to verify because the lab names are blacked out is completely disingenuous. Listen, I figured out one of the labs that she used. I don’t use these labs, I don’t use any labs, but I figured out it out. They know which lab it was, because they used the exact same one – but got different testing done for some reason. If they wanted to know the names of the labs to verify whether they were any good, I think they could have just asked. This seems like a roundabout way of further character assassination which again seems completely misplaced in a scientific analysis. When GPP has been using a lab whose results are so suspect that WAPF will not post test results from them on their website because they won’t reveal their methodology, accusing others of using crappy labs seems a little hypocritical. Listen, the lab found D2 (a vitamin found in plants) in an animal product, and found no D3 (the predominant D form found in animals and fish). Listen, WAPF and GPP are not even contesting the vitamin tests Dr. Daniel got done. That’s how suspect their lab is.

      My conclusion is that Dr. Friest began his investigation into FCLO already convinced that FLCO was good, and this left him blinded to results that should have at least led to some deeper questioning. Since Dr. Friest seems to live near GPP, I am curious as to the relation between the two. I mean, this isn’t his specialty, why have him review it? Is this a friend from church, an old family friend, or what?

      My concern with this product is that people are still having adverse reactions. I read today about two women who were experiencing hair loss. One of them has been off of the product for a couple of weeks now and that has stopped. Whether related or not, I don’t know. It’s just two more stories. It took decades for the vaccine court to finally rule that a vaccine caused a case of autism. Situations were similar. Some were/are convinced that vaccines (FCLO) cannot harm people. Some are convinced that the good outweighs the bad. The only evidence is circumstantial. Only by committing to accumulating adverse event reports can it be determined that there is a discernible pattern versus happenstance.

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  • If secondary oxidation has occurred then my understanding is the p-Anisidine values would coincide with that hypothesis. They don’t, (in any of the lab tests). I think this is significant:

    “Other information has come out, though, that indicates that taking FCLO does not raise blood serum Vitamin D levels in some people, and at least one person reported that it actually suppressed the level. ”

    I don’t think the problem is rancidity. I think people may be absorbing vitamin D differently, and other cofactors are involved. (Such as magnesium or sulphur).

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    • Thank you for your comment. It is my understanding that p-Asinidine, like peroxides, degrade into other components. Multiple people have said this. Nobody has said what those other components are – not Daniel, not Masterjohn, not any of the scientists that GPP has posted. I haven’t been able to find out in any of my research. Maybe you can’t test for them. Masterjohn stated in his report: “Dr. Daniel cites a video in which Dave Wetzel discusses the time-dependent peroxide value history of his oil, wherein he says that it rises to a high level and then returns to normal before he bottles the oil. In response to the Daniel report, Wetzel released data in pdf form on the same topic. He had told me about this phenomenon years ago, and, as noted above, it had crossed my mind that this was harmful. In reviewing it now, the phenomenon does sound eerily similar to the natural course of peroxide formation where it increases until the peroxides degrade into secondary products that are toxic. Yet Wetzel’s data show that the anisidine value, an indicator of secondary peroxidation products, never rises to unacceptable levels over the same time course.”

      I would love to see those test results showing the rise and the fall of the peroxide markers vs the anisidine value. But they haven’t been published. On another note here, Masterjohn tries to insinuate that the peroxide test could be picking up K2 instead of peroxides. The problem is that CLO and FCLO have very low levels of K2, which is why you need butter oil.

      I don’t think that I presented the vitamin D information in the context of rancidity, but if I did, that was in error. It was supposed to be in the context of the question of vitamin levels. I too don’t think that any vitamin D issue would have to do with rancidity. I think it might have to do with vitamin levels in the oil, or perhaps due to an absorption issue as you mention, which could be related to inflammation that some experience, possibly due to biogenic amines. If you notice a lot of conditional words in there, that’s intentional. It’s pure speculation. The facts are that people are reporting low vitamin D levels that clear up when they cease their daily FCLO dosage. It is hearsay and possibly not true at all, but there is a mounting number of reports that are very similar in nature. If it is true that FCLO is causing low vitamin D levels in some individuals, I don’t know the cause.

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      • It seems that I have not been clear in my communications, so I will try one more time, hoping that what I say makes sense.

        It is my understanding that the p-Anisidine values measure the levels of aldehydes. In the interview Ann Marie did with Dr. Rudi, I “think” he said the P-Anisidine values, (the measurement of aldehydes), should not go above 10. The data I have seen on FCLO shows the p-Anisidine values do not go above 10, but other CLO products do go above 10.

        Dr. Rudi also said “spectrometric analysis” is a good way to test for rancidity. (paraphrasing). The NMR analysis by Grootveld showed there were no aldehydes. (nd – none detected). Now I don’t see why the aldehydes, which are a product of secondary oxidation, would no longer be in the oils. My understanding is the NMR data should have been significant and shown that rancidity is not a problem with FCLO.

        I can’t figure out why the spectrometric analysis would have missed the by products of oxidation. It is an accurate test.

        I am contacting a few chemists to answer my questions. So my question to you is if it is proved, beyond a reasonable doubt, that the FCLO is not “hyper-oxidized”, then what is your alternative theory? I have a few, and at this point I am not sure Rosita’s EVCLO is a good choice.

        Thanks

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      • My understanding is that the aldehydes go to carboxylic acids as a third stage of oxidation (hyper-oxidation). They then wouldn’t be present and detectable. But you would be able to test for carboxylic acids, which might be in the form of free fatty acid. I haven’t seen a specific line item testing for carboxylic acid on any of the tests that GPP is getting and I haven’t taken the time to go check out the tests that Dr. Daniel did.

        Contact me when you hear from your scientists. I’ve got a couple of hypotheses.

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      • I see what you are saying about the aldehydes becoming tertiary products. However, I don’t see any reason why ALL the secondary products would be converted, and the spectrometer test should have picked them up. (Also, the levels of PUFA remaining is significant).

        I contacted Dr. Rudi directly, but I have not heard back from him yet. In my opinion, a fair and balanced interview with him would have involved showing him the data and asking him if the FCLO was rancid. That was the only reason I watched the video, because Ann Marie told me it would answer my questions.

        I hope Dr. Rudi responds.

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      • Steve:

        Steve;

        Dr Rudi has not responded to my questions yet. I find that odd. My friend, who is a brilliant organic chemist, has responded. This what she said in response to the H NMR analysis I sent to her.

        “In the NMR spectra they would detect any molecules in the sample, so if they did not see any peaks that correlate to aldehydes or hydroperoxydiene precursors, they aren’t in the sample at detected levels. NMR is really sensitive so these byproducts are likely not there. When you run an NMR its not like you query for secondary products and not tertiary; the analysis gives you a measurement of every hydrogen bond that exists in the entire sample. You can tell what molecules are near what hydrogens and determine the molecular structure from this information. The hydrogen on an aldehyde group or a hydroperoxydiene group have unique spectral results compared to a standard carbon-hydrogen chain in a fatty acid, and would easy to visualize.

        If they didn’t see any peaks in the spectrum the molecules don’t exist at a detectable level. NMR is incredibly sensitive, so if an oil is rancid it would likely have detectable peaks. Thus, the oil sample they analyzed is not rancid.”

        I understand the distrust in some of the experts in this situation. My friend has no knowledge of this controversy. I just sent her the H NMR analysis.

        I am not sure if her reply has answered your questions, but it most certainly has answered mine. The FCLO is not rancid.

        I hope you figure out why some people have a problem with it. I truly do. My family has been very happy with this product.

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      • Thank you for looking into this. I’m glad that you got your questions answered. Regarding that test, I’m not sure we’re actually seeing the original. I have evidence that WAPF did not post the entire test result and summary, and I’m not sure why they would not post it in its entirety, yet represent that they did, if the tests and the analysis were truly so complimentary of FCLO. Secondly, when I pointed out a problem with the report from Grootveld, it was edited within an hour to make it seem like that had never been a problem and there was no acknowledgement of the fact. These make me leery. I’m not thinking that Grootveld is a bad scientist or that he is colluding with Sally and Dave or anything like that. I’m just not sure that we’re getting the full story and that makes me nervous. I’m also wondering, if that is such THE definitive test, why GPP has done more than a dozen tests since then, but hasn’t had that one repeated by another lab, instead doing the exact same tests over and over again that Grootveld himself held to be “not good” for an oil of this type. Again, is there something to hide there?I wish you and your family all the best. Please refrigerate and quickly use any CLO that you choose to use. They all have fragile PUFAs.

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      • Steve – I don’t know anything about the full Grootveld Report. I don’t like to speculate, but it is possible they did some other testing that was not related to the oxidation and they were not ready to release the results.

        Sarah Pope at the Healthy Home Economist said that testing has been done on many brands of Cod Liver Oils and the results will be made public too. It will be interesting to see.

        I do think the vitamin D levels are significant, and not because of rancidity. But without more data it is just a hunch.

        Anyhow, I had 2 unopened bottles of FCLO and I am not going to let them go to waste unless new information is released that shows this product is harmful.

        Thank you for your concern.

        Best
        Keri Hessel

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  • Pingback: Fermented Cod Liver Oil Scandal: Steve Tallent on Green Pastures’ Lack of Transparency

  • I have been a long time customer, possibly from the very beginning of your company, if not, than close to it. I have always highly recommended your company, because of the excellent products, wonderful information you share, your high standards of quality and disclosure, and that you are a small family business. This is an excellent article. Thank you for your time and effort researching this issue as well as all the research you do in general. I appreciate your humbleness admitting you carried the FCLO without vetting it like you do the other products in your store. Thank you for your honesty and apology and desire to do better from here on out. I definitely forgive you and will continue to be a happy customer.

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  • Thanks Steve for all your research !

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  • Great information in this article, and I appreciate all your research. I think there might be one typo in your bullet point after Sally Fallon’s comment about the lab tests: “The fermentation process is converting D2 to D3.” – don’t you mean converting D3 to D2? (as stated earlier in the article, so I think it’s just a typo)

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  • I am recently facing some significant health problems, and to top it off I have 5 cavities plus one that they are recommending a root canal for. I am reading Cure Tooth Decay. Do you think that the findings of this book are suspect? Is Weston A. Price himself still a good source?? I didn’t get a chance to read the entire blog posts, but I did read a good portion.

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    • I’ve heard Ramiel speak, and the information seems to be good. I haven’t read through the book all the way yet. I think Dr. Price’s information is still good. Some of his speculation may be dated, but in general, he seemed to be a very careful man who was very conservative in his analysis. He also had a lot of hands on experience in treating people, so he figured out things that worked.

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  • A year later … All the FCLO hype seems to have died down, and the Primal Paleo Price Foundation (that’s not the right name any more, I don’t know what the current name is) has had their kick-off meeting …. I’m not hearing a word about it any more. Is Beeyoutiful still a member of WAPF, or are they now members of PPPF, or …. ? I am most interested to understand where things are these days. It was an awfully big ruckus that got fairly nasty and was extremely discouraging to those of us who are just trying to source and consume real, healthy food for ourselves and our families. WAPF appears to be in need of financial support (per the mailing I recently received). PPPF appeared to be having leadership issues (per a blog article I saw), and I’ve heard nothing from them for a long time. I was very thankful for Beeyoutiful’s handling of the FCLO situation and response to it. Do you have any updates? Thank you for your time.

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    • Hi Amy,

      Yes, the FCLO hype has died down. I attribute it to a number of reasons, but they pretty much all boil down to WAPF and GPP circled the wagons and the people that cared finally got tired of riding around firing arrows to little or no effect. Some people that were firing the arrows had axes to grind, some wanted to find the truth and/or expose the truth, and some were seeking personal gain.

      I really don’t know what is going on with the (now named) Hunt Grow Gather foundation. I helped to write some of their bylaws for approval by the board, but haven’t heard anything recently other than the name change. I would love to see the blog post you reference about leadership issues. I would have expected them to have plans for a conference this year, but have seen nothing and wouldn’t be surprised if leadership was part of the issue. Sometimes a dynamic leader with a vision is what you really need. Beeyoutiful is still a member of WAPF – at least, we’re still getting the quarterly journal (just got one yesterday), but I don’t think we’ve paid any dues for this last year, so I don’t know. In the past we got invited by WAPFs conference coordinator to various WAPF events. This year we’ve been invited to other events, but not to WAPF. I don’t know if we would be welcome if we tried to go, but at this point we have no intentions of trying to show at their conferences or even pay membership dues. I was very vocal about the FCLO issue in places where they could see it, and they actually made up some new rules to keep me from getting information as I was trying to dig in this further. Repercussions from Sally are a very real thing that I have had first hand accounts of over these last 18 months. I have no doubts that WAPF and GPP both took a financial hit over the FCLO debacle, not just because of the revelations, but especially because of their handling of the matter. Both organizations had been kind of playing it fast and loose with information about FCLO for years, and finally all of their insinuations, poor (or non-existent) research, unsubstantiated claims and questionable testing all came to a head at one time. I heard from one person who was there that they did an “energy reading” on the product at a board meeting. From that point on it was “we know it is good (based on the energy reading), we just have to find the data that proves it”. All information and testimony to the contrary was discounted, denied, or discarded.

      I continue to believe that there are problems with FCLO. First, the testimony from David Wetzel that he doesn’t believe the product can go bad should be disturbing to anybody that knows anything about healthy natural or fermented products. Have you heard the saying that you shouldn’t eat any food that doesn’t go bad? Real food goes bad. Fermented and cultured foods are protected by bacteria and have a longer shelf life, but still go bad. Oil goes bad – even the most stable of oils. His product is not protected by bacteria, and is a very fragile oil that tends to go bad quickly. If he is seeing no change in it after years and years, I can’t come up with any other explanation than that it already went bad – especially with the high amine count, putrescine and cadaverine being among them. Secondly, I read first hand testimonials of people whose health improved and whose very low vitamin D levels came back to normal after stopping the FCLO. Remember FCLO was touted as having extremely high vitamin D levels.

      We’re very happy with the Rosita Cod Liver Oil and Ratfish Liver Oil that we’re carrying, and our customers seem to be very happy with it as well. We also had a high vitamin butter oil, but that has now been replaced by emu oil from Walkabout Health Products. Emu oil is stable and has 10x the vitamin k levels of butter oil, and is very mild. My kids ask for it. It doesn’t hurt that the capsule is mildly sweet when chewed! 🙂

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