Proposition 65 and Lead in Crock Pots

Part III in a continuing series on lead in crock pots.

Proposition 65 defines the known universe …

The limits of what can be known about lead in crock pots in the U.S. are defined by California’s Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986. As you can tell from the omnibus name, this law is about far more than crock pots. But let’s follow their case, because it’s ultimately very instructive.

Prop 65 is among the crown jewels of California’s leadership in environmental health standards and testimony to the fact that the ballot initiative process hasn’t been all bad. It requires that warning labels be placed on products exceeding specified limits of a list of chemicals known to be harmful, limits typically 10 to 1,000 times lower than federal standards.

It doesn’t ban such products; it is merely a requirement that they be labeled. But by shedding light on key areas, this law has cleaned up many products and practices not only in California but in the rest of the nation.

Thanks to Prop 65, you can more or less reliably find out (within the limits of compliance and enforcement reliability) if your crock pot leaches more than 0.1 parts per million of lead, 10 times less than the FDA limit of 1.0 ppm, when subjected to standard testing.

But thanks also to that law, you can’t find out – other than by having it tested at a private lab – how much less than it leaches, because no company is going to make that information publicly available. And that goes for products you might want to compare with crock pots, such as the cast-iron enameled cookware you might be researching as a possible alternative.

So Prop 65 is a good thing. But below its required warning levels companies don’t have to quantify what’s there. So as long as products meet the standard, there’s no public information about which ones do a better job of doing so – that is, no information about no lead vs. small amounts of lead.

And you can’t tell by currently available over-the-counter tests, either; these are only sensitive enough to find levels exceeding FDA standards, 10 times the Prop 65 amount.

Most crock pots pass the test, but …

The good news is most major brands of crock pots pass the test, at least according to my informal survey. So do most major brands of cast iron cookware, enameled and bare. Don’t take my word for it, though. Before buying any cookware, check the company website or contact customer service to verify that it is not required to carry a Prop 65 label in the state of California.

You can also check for Prop 65 labels on Amazon. Look under “Product Details” for any given product. If that product carries a Prop 65 label, there should be a line there that says “California residents: click here for Proposition 65 warning.” I’d still confirm with the company either way. The labeling can be vague, and this is your chance to ask the company for details.

The bad news is that, as I explained in the previous post, medical research is increasingly suggesting that amounts of lead below the Prop 65 limit can be measurably harmful, particularly for children and developing fetuses.

So how much lead are we talking about here?

If your crock pot actually leaches the maximum allowable Prop 65 warning-free level of 0.1 ppm, that amounts to 100 micrograms per liter, or roughly 25 micrograms per cup.

That’s determined by a standard test known as ASTM-738, which involves subjecting the pot to 24 hours of a 4 percent acetic acid solution at 80 degrees Fahrenheit and analyzing the solution with high-tech lab instruments. Don’t try this at home unless your atomic spectroscopy absorption equipment is fully up-to-date. A reputable lab I checked with quoted me a price of $350 to have it done.

This leaching level may possibly be acceptable for adults, who absorb a far smaller proportion than children (8-15 percent vs. 50 percent) and excrete a far greater proportion (up to 99 percent vs. only 32 percent), but by the FDA’s own standards, even those developed prior to recent findings, it is unsafe for children consuming more than small amounts.

Using EPA estimates of the effects of exposure to given quantities of lead, the FDA has developed the PTTIL – Provisional Tolerable Total Intake Levels (FDA, 1993):

  • Children, ages 0-6 years: 6 micrograms a day
  • Children, over 7 years: 15 micrograms a day
  • Pregnant women: 25 micrograms a day
  • Adults: 75 micrograms a day

There are so many variables affecting the leaching, absorption and excretion of lead that it would be unwise to take these figures too literally. But they do provide enough of an idea to suggest extreme caution for children, though there may be a reasonable margin of safety for non-pregnant adults.

Why bother counting micrograms when you already know that no amount is acceptable? Well, because lead is so ubiquitous in the environment that most people are going to have to tolerate some.

Just because your crock pot can leach that amount doesn’t mean it does. But it does mean you can’t know whether it does or not without testing. And it means the best standard we have is not good enough for infants, children and pregnant women.

REFERENCES

California Office of Environmental Health Hazard Assessment, http://oehha.ca.gov/prop65.html

Cheng, John, FDA. “Elemental Analysis Manual: Section 4.6: Inductively Coupled Plasma-Atomic Emission Spectrometric Determination of Cadmium and Lead Extracted from Ceramic Foodware,” August 2010, http://www.fda.gov/Food/ScienceResearch/LaboratoryMethods/ElementalAnalysisManualEAM/ucm221685.htm

“Draft Lead Report,” California Department of Toxic Substances Control,  Hazardous Waste Management Program Regulatory and Program Development Division, August 2004, (note; contains misprint of 35 micrograms for pregnant women), http://www.dtsc.ca.gov/HazardousWaste/upload/HWMP_REP_dLead-Rep.pdf

In Praise of the Crock Pot, But for One Little Fly in the Ointment, Part II

So what’s the deal with lead and slow cookers? Here’s what I found:

Most slow cookers sold in the U.S. probably do not contain or leach detectable amounts of lead (1). Keep that in mind while reading the rest of this, so you don’t panic.

Because some – possibly a significant number – probably do contain detectable lead, and this lead has been found to leach into food (1).

The amounts leached are very small, so small that they’re in compliance with federally allowable (FDA) safety standards (1, 3). Phew! No problem then, right?

Wrong: The current medical consensus is that there is no safe level of lead, especially for children, who absorb a much higher proportion of it than adults and are more vulnerable to its effects, serious neurological damage being chief on a dreadful laundry list affecting every organ. Lead accumulates in the body, so small exposures can add up gradually over the years (2).

 In the last decade researchers have found that much of the harm done to children occurs at extremely low levels of exposure. Nor is it great to expose adults to low levels of lead, especially pregnant women (2). It appears that FDA standards are out of date.

Yep, crock pots that leach potentially harmful — cumulatively if not immediately –  amounts of lead can still be legally sold. They can even declare themselves “lead-free.”

The way slow cookers are actually used means they could well leach more than standard testing might suggest. Time, temperature, and acidity greatly increase leaching, especially the latter two (4). Crock pots are used for 8 to 12 hours, at far above the standard leach-test temperature of 80 degrees F, and often with acidic ingredients like tomatoes, vinegar, wine, and citrus. (And I was telling people to make bone broth in them!)

Currently available over-the-counter test kits are NOT sensitive enough to detect levels we’re talking about here. You’d have to go to a private lab where they have X-ray fluorescent guns and spectrometers and can do an ASTM C738-94 extraction test and whatnot (1). And even if your pot is not leaching now, what about down the road, with use and wear?

So it’s a no-brainer, right? Drop the crock pot! Who needs more lead than we’re already getting? End of story.

Oh, but you don’t know me, do you. If you did, you’d know that I’m going to give you the counterargument. Because, yes, there is one to be made. Or at least a qualification. And if you do know me, then you know that if there’s an argument or a qualification to be made I’m gonna make it, whether anyone wants to hear it or not.

This mental rigidity could well be because I’m one of those people born between 1945 and 1971, who, thanks to leaded gasoline, have astronomically higher body levels of lead than people born after that period, levels 300 to 1000 times higher pre-Columbian indigenous people (5).

It may also be because, dammit, I love my crock pot. That’s right. I couldn’t let go. And because I couldn’t let go, I waded in deeper.

So next up, more about lead & heavy metals in crock pots and the world:

  • Why and how you might still use a slow cooker, and the safest way to buy and use one. Everything thought you didn’t need to know about California Proposition 65 and porcelain enamel coatings.
  • Crock pot alternatives. Because you still gotta slow cook. (Hint: cast iron, enameled if you can afford it, non-enameled if you can’t; people slow cooked before crockpot, and once again a tradition has it right).
  • Perspective on lead & heavy metals that will once again lead you to the inexorable conclusion that good nutrition is the best defense against the toxic soup of continuous multiple low-level exposures in which we are today condemned to swim, whether we get rid of our crock pots [whimper!] or not.

————–

REFERENCES

1. Most slow cookers sold in the U.S. probably do not contain lead … [but] some  possibly a significant number – probably do … and this lead has been found to leach into food.”

I’m basing these carefully qualified assertions on two sources. The first is investigative reporter Bill Gephardt’s remarkable series on lead in foodware, aired on KUTV in Salt Lake City in December of 2007. It’s a story that bears retelling, especially as it’s no longer available on the web.

Following the alarming results of his initial investigations into lead in dishes, Gephardt, prompted by a viewer who alerted him to high levels of lead found in her crock pot at a fairgrounds test, took a small random sample of ten or so slow cookers to a private lab  (admittedly a small sample, but then investigative reporters don’t have FDA budgets).

There he found at least two crock pots contained measurable amounts of lead, suggesting in a preliminary sort of way that something like 20 percent of the product out there might have detectable lead in it – and of course that something like 80 percent might not.

Gephardt then took the viewer’s crock pot to another private lab to undergo the standard FDA test for leaching. The result was leachable lead at 0.85 parts per million. Perfectly legal by FDA standards of 1.0 ppm for “large ceramic hollowware” (http://www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/ucm074516.htm). But unacceptable by recent medical standards (see below).

Though Gephardt’s samples weren’t big enough to be conclusive, they were big enough to be suggestive. But no one is going to undertake massive testing or modifying of a product containing levels the FDA already considers acceptable.

In the best of worlds, the FDA would have tightened its standards after 2005, by which time medical research had established the need to do so. To its credit, the agency has done so a number of times in the past, keeping up with the increasingly worrisome findings on lead since the 1930s. But this isn’t the best of worlds, not these days.

So now you know why my terms are so qualified – “probably,” “possibly,” “something like.” In a world of as-long-as-inadequate-government-standards-are-met-no-one-has-any-idea-what’s-in-there-and-no-one-has-the-money-and-resources-to-systematically-look, one lone reporter is all I’ve got.

Gephardt’s series inspired Utah Representative Jim Matheson to seek U.S. labeling legislation. In 2009 Matheson managed to get some labeling for ceramic foodware into federal law: “This product is made with lead-based glaze consistent with Food and Drug Administration (FDA) guidelines for such lead.” No doubt the mild-to-the-point-of-misleading “warning,” which sounds more like a reassurance, that emerged from the legislative sausage-making does not honor the congressman’s original intentions (http://matheson.house.gov/index.cfm?sectionid=49.12&itemid=182).

I am indebted to the blogs “Insightful Nana” (http://insightfulnana.com/home-garden/housekeeping-home-garden/lead-poisoning-and-crock-pots/html) and “Green Fertility,” (http://greenfertility.blogspot.com/2008/03/lead-in-rival-crockpots.html), and to natmommy.com of the Mothering.com community (http://www.mothering.com/community/t/852699/crock-pots-and-lead/20), for bringing Gephardt’s crock-pot segment to my attention. The latter two posted excerpts of the KUTV web text for Gephardt’s original stories, which are no longer posted on the station’s website or elsewhere and would otherwise have been lost to anyone not willing or able to pay a private service for video clips or a subscription database.

Because I had no original copy, I emailed Gephardt the excerpts of the text; he confirmed their accuracy, for which I thank him here. Gephardt is still steamed about the lack of labeling in Utah and the rest of the U.S. except California. “Let people eat chunks of lead if they want to. But they should know it’s there,” he said, adding, “You just don’t have to use lead in these products. It’s micropennies cheaper.” As for FDA standards that legalize medically unacceptable lead levels, he had a choice word not printable in a family blog.

My second “source” is more like a suspicion: the simple inference you can make from the gap between current medical consensus (see below) and the current regulatory standards (see below), plus the fact that food is heated in crock pots for long periods of time, often under acidic conditions. And while the standard leach test is a longer period (24 hours), it is only done at 80 degrees F, while a crock pot gets three times as hot.

2. Current medical consensus is that harm to children from lead occurs at very low blood levels, well below the previously defined (1991) CDC “level of concern” of 10 micrograms per deciliter. Indeed, a great deal of the damage done by lead appears to happen at below 10 micrograms/dL, starting measurably at 1 microgram/dL, with no safe level found.

See:

Levin, Ronnie, et al. “Lead Exposures in U.S. Children, 2008: Implications for Prevention,” Environmental Health Perspectives, 2008 October; 116(10): 1285–1293. Published online 2008 May 19. doi:  10.1289/ehp.11241, http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2569084/

Bellinger, David, C., Harvard Medical School. “Very low lead exposures and children’s neurodevelopment,” Current Opinion in Pediatrics: April 2008 – Volume 20 – Issue 2 – p 172-177, http://journals.lww.com/co-pediatrics/pages/articleviewer.aspx?year=2008&issue=04000&article=00013&type=abstract ;

Brown, Mary, Centers for Disease Control. “Interpreting and Managing Blood Lead Levels <10 micrograms/dL in Children and Reducing Childhood Exposures to Lead; Recommendations of CDC’s Advisory Committee on Childhood Lead Poisoning Prevention,” CDC, Nov. 2, 2007, http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5608a1.htm ;

Brody, Jane E. “Personal Health; Even Low Lead Levels Pose Perils for Children,” New York Times, Aug. 5, 2003

Kosnett, Michael J., University of Colorado, Denver. “Health Effects of Low Dose Lead Exposure in Adults and Children, and Preventable Risk Posed by the Consumption of Game Meat Harvested With Lead Ammunition,” http://www.peregrinefund.org/subsites/conference-lead/PDF/0103%20Kosnett.pdf. This article is useful because it looks at levels and vectors comparable to the FDA maximum allowable leachable lead level for crock pots.

For a great overview of the above findings and much, much more, see the Franklin Institute’s website: http://www.fi.edu/learn/brain/metals.html

3. The FDA maximum allowable leachable lead limit for “large ceramic hollowware” is 1.0 ppm. See “CPG Sec. 545.450 Pottery (Ceramics); Import and Domestic – Lead Contamination,” issued 10/1/80; revised 4/16/92, 12/12/95 (60 FR 63721), 5/2005; updated 11/29/05: http://www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/ucm074516.htm

Detection limits of the test used to establish regulatory compliance: http://www.fda.gov/Food/ScienceResearch/LaboratoryMethods/ElementalAnalysisManualEAM/ucm221685.htm

4. Time, temperature, and acidity: Hight, S. C., et al. “Lead and Cadmium Release Under Conditions of Consumer Use: FDA Experiments With Cookware, Glass Tumblers, Lead Crystal Baby Bottles, And Ceramic Mugs,” Ceramic Transactions, Vol. 61 , pp. 11-22, 1995: http://md1.csa.com/partners/viewrecord.php?requester=gs&collection=TRD&recid=7708035CWC&q=FDA+leachable+foodware&uid=791387631&setcookie=yes

A high percentage of the lead leaches in a 24-hour contact period does so in the first few minutes, so length of cooking is a perhaps a relatively insignficant factor. However, temperature and acidity are highly significant factors, especially temperature – crock pot cooking may be low temperature for cooking, but the test uses room temperature (80 degrees F). See:

“Policy Statement Concerning Lead Leaching From Glass Tableware Into Foodstuffs,” Partial Agreement in the Social and Health Field, Council of Europe Public Health Committee: http://www.coe.int/t/e/social_cohesion/soc-sp/public_health/food_contact/PS%20E%20LEAD%20LEACHING%20VERSION%201.pdf

5. Historic blood levels: Issacs, Steven, “Where Public Good Prevailed,” The American Prospect, July 19, 2001, http://prospect.org/article/where-public-good-prevailed and The Franklin Institute website resource page, http://www.fi.edu/learn/brain/metals.html.

In Praise of the Crock Pot, But for One Little Fly in the Ointment, Part I

I was going to use this first post of the year to sing the praises of the crock pot. It was going to be all about how the slow cooker (to use its non-trademarked name) is an easy way to make nutrient-dense meals that demand amazingly little time, effort, money, and carbon, using modern technology to get traditional results.

Slow cooking is among the healthiest ways to cook what you’re not going to eat raw. The low heat preserves nutrients and gently breaks down food for maximum digestibility and minimum generation of carcinogenic, inflammatory, oxidizing compounds and effects – that tongue-twisting litany of heterocyclic amines, polycyclic aromatic hydrocarbons, acrylamides, denatured proteins, advanced glycation end products, and free radicals spawned in the demonic hell of high-heat, rapid cooking (1).

I’ve been evangelizing about the crock pot for a number of years now as the best way to slow cook, provided you take care not to overcook. It’s the most energy efficient, the most precise, the most forgiving, the easiest to clean up; the smallest footprint in every way. It doesn’t heat up the house or set it on fire.

You throw things in, leave for the day and come back to a hot meal that’s pleasurable and comforting enough to keep you from calling for take-out. It’s a staple of my cooking routine, and an invaluable aide to keeping that resolution you all made to eat more home-prepared whole foods.

I love to tell people how you can make a whole chicken deliciously cooked in its own liquid, an effortless gourmet meal that exemplifies my recommended mantra for those who think they don’t have time for real food: “don’t cook; assemble.” (I don’t know who first came up with that, but it’s genius.) How, contrary to reputation, crock pots can create some fine aesthetic effects if used skillfully — not the tasteless mush some foodies complain about —  and without the health-defeating browning prep some think necessary.

How it’s the best way for lazy cooks like myself (I prefer to be described as “labor-sensitive”) to handle grass-fed meat and inexpensive cuts; to finesse tough prospects like duck, or scary ones whose original identity you may prefer to blur in a stew, such as organ meats, bunny rabbits, or, I’ve been thinking lately, those back yard squirrels that keep digging up my patio planters.

I go on and on about how crock pot cooking gets all the meat off the bone and makes mineral-packed bone broth while you wait. About how nicely it renders lard and fat, capping off the efficient use of the whole animal – bones, organs, fat and all, the only respectful way to use life if you’re going to take it; nothing wasted. Yet not too messy for the faint of heart.

And I’m still going to tell you all that.

But as I was pulling up my chair to get started, I checked my email in a last burst of procrastination, and there I found some disturbing information. People on the Weston Price yahoo group were wondering how to find a lead-free crock pot. Lead-free? Crock pots have lead in them?

My head whirled. Was I poisoning myself with my favorite modern convenience? Would I have to change my whole way of doing things? Worst of all, was I going to have to explain to the clients, friends, and family who had bought crock pots on my advice that they should now get rid of them?

Well, maybe. And maybe not. In Part II, I’ll tell you what I found. And get to some recipes. Stay tuned. Don’t throw anything out or run out and buy anything new just yet.

References

1. See hundreds of studies in the past 30 years; try searching PubMed (http://www.pubmed.gov/) using key words from this paragraph. U.S. research tends to single out red meats cooked at very high/dry heat, but in fact most heat-processing, i.e, cooking, of most foods involves some harm production and nutrient loss (see Jägerstad, M. “Genotoxicity of Heat-Processed Foods,” Mutation Research, July 1, 2005, 156-72, http://www.ncbi.nlm.nih.gov/pubmed/15914214 and other studies from abroad, as well as studies on acrylamides and AGEs). Does this mean you shouldn’t cook food? Raw foodists say yes, but I say no, and I’ll be telling you why in future posts.

2. Learn more about Weston Price at http://www.westonaprice.org/.