Why Nuzest Chose to Add the Prop 65 Label to Our Products
WARNING: Consuming this product can expose you to chemicals including lead, which is known to the State of California to cause birth defects of other reproductive harm. For more information go to www.P65Warnings.ca.gov/food.
Why Nuzest Chose to Add the Prop 65 Label to Our Products
Proposition 65 is a California state law (the Safe Drinking Water and Toxic Enforcement Act of 1986) that requires businesses to warn Californians about exposures to chemicals known to the state of California to cause cancer or birth defects or other reproductive harm. Prop 65 was intended to enable Californians to protect themselves from these chemicals by enabling them to make informed decisions about the consumer products they purchase. The standards for Prop 65 are stricter than levels deemed safe by the World Health Organization (WHO), Canada, the United States Pharmacopeia (USP), European Union (EU), and the Food and Drug Administration (FDA).
Consumer products sold in California must have a Prop 65 warning if they contain one or more chemicals on the Prop 65 list unless: (1) there is an applicable safe harbor level for the chemical(s) and the product causes an exposure at or below the safe harbor level; (2) it is an exposure to a Prop 65 chemical that is naturally occurring in a food and its presence was unavoidable despite good agricultural manufacturing practices, and quality controls were used to keep it to the lowest level currently feasible; or (3) the business has 9 or fewer employees.
Chemicals on the Prop 65 list include synthetic chemicals and naturally occurring chemicals, such as lead and cadmium. Lead and cadmium are heavy metals present in soil, and can be absorbed by plants grown in that soil.
Is Lead Found in Natural Products?
Heavy metals, including lead, are found in many natural products. In fact, they are found in fruits and vegetables, grains, nuts, and seeds, too. They are also found in lesser amounts in meat, seafood and dairy products.
Because heavy metals are naturally occurring in the soil, they inevitably can be absorbed into fruits and vegetables and other plant-based foods we eat every day.
How Much Lead is Safe to Consume?
According to the FDA, the safe/tolerable exposure level for lead (known as the “provisional total tolerable intake level” or “PTTI” for short) for adults is 75 mcg/day. For pregnant/lactating women, children 7 years or older, and children 0-6 years, the safe levels are estimated to be 25 mcg, 15 mcg, and 6 mcg per day respectively.
To ensure that the amount of lead in a food is not high enough to raise someone’s blood level to a point of concern (5 ug/dL), the FDA calculated a maximum daily intake level for lead sourced from food. It is known as the Interim Reference Level (IRL). The IRL is 12.5 mcg/day for adults, and the IRL for children is 3 mcg/day. The FDA intentionally set those IRLs low. The IRLs are nearly ten-times less than the amount of lead from food that would be required to reach the 5 ug/dL blood reference level.
To compare, Prop 65’s limits for lead are far lower. Under Prop 65, products that expose consumers to more than 0.5 mcg of lead per day must provide a warning about birth defects or other reproductive harm. To determine the 0.5 mcg/day level, referred to as the “maximum allowable dose level” (MADL), California determined the maximum level of lead exposure that will have no observable effect (500 mcg/day) and then divided that number by 1,000.
Tiny amounts of lead are even found throughout the earth, in the air, water and soil. Lead typically bonds to other elements, like zinc, copper, and silver, which prevents lead from accumulating in our bodies. In fact according to the Environmental Protection Agency (EPA), lead occurs naturally in uncontaminated soils at a level of between 50-400 parts per million (ppm).
Why Did Nuzest Add the Prop 65 Warning Label to Our Products?
Nuzest regularly tests our products for safety including heavy metal levels, allergens, and contaminants. We sometimes test at or below the stringent Prop 65 levels. However because our products are sourced from peas, which are grown in soil, each batch may contain varying levels of heavy metals.
Some batches expose consumers to more than 0.5 mcg of lead per day, which is higher than Prop 65’s safe harbor level for reproductive toxicity. Although we believe that the lead in our products is naturally occurring and therefore exempt from Prop 65’s warning requirements, to prevent expensive lawsuits by third parties who might test a batch and find a level even slightly above the Prop 65 limit of 0.5 mcg/day, we have chosen to put the Prop 65 warning for birth defects and other reproductive harm on our products. The Prop 65 warning does not indicate that a product is unsafe or will cause any harm. Although this Prop 65 warning is on our products, all of our tests have all come back at safe consumption levels.
Nuzest Products are Safe to Consume as Part of a Healthy, Balanced Diet
But you don’t need to worry. Every part of the supply chain and production process is important to determine how clean the final protein supplement product will be. Clean Lean Protein represents the very highest quality of pea protein we can get anywhere in the world. At present, we cannot guarantee supply of organically certified plant-based protein of this quality. Our pea protein is also incredibly clean. It’s a very high purity isolate containing almost 90% pure protein produced from sustainably farmed peas from northern France.
We demand the highest quality and standards at every stage of the production process, from the source of our peas, to the extraction process of the isolate, to the levels of lectin in our isolate and the testing we use to reassure ourselves it’s a clean vegan protein source.
Our pea protein isolate comes from sustainably-cultivated European golden peas grown in Northern France. They are grown in soils that do not have high natural contents of heavy metals. Nor is the environment (air, water, soil) contaminated in any other way.
The French farmers who grow the peas do this exclusively for our vegan protein. They are committed to sustainable production methods that minimize any use of pesticides or artificial fertilizers. What’s more, from an environmental and water usage perspective, peas are among the most sustainable crops that can be grown.
Put simply, we are a brand centered around quality. We put a lot of time, effort, expertise and investment into delivering the highest quality vegan products that make the most difference in people’s lives, at the best price – and as sustainably as possible. That’s what Clean Lean Protein and our entire product line are all about – it’s a notion that’s embedded deep in the DNA of our company’s founders and formulators – and we wouldn’t be using it ourselves if we didn’t feel the same way!
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