An Open Letter to David Wetzel of Green Pasture, Makers of FCLO

Dear David Wetzel,

As a mother and a concerned consumer, what I care about most when buying products from a health supplement company, is a quality product, truth in advertising and transparency from the manufacturer.

I used to work with you and your company when you were a sponsor of my blog and of the other blogs I represented with my former blog network.

One of the things I always felt good about was that you seemed to be a man of integrity and always said you cared about the quality of the product and the customers you were serving. That is why I always felt so confident recommending your products to my readers.

When the FCLO scandal broke last fall when Dr. Kaayla Daniel published her whistleblower report on Green Pasture’s FCLO, I was curious to see how you and your company, Green Pasture Products, would respond.

The actions you have taken in the past year in response to the crisis have been disappointing to say the least.

Many of us were hoping you would become more transparent about your manufacturing processes, clean up your issues with labeling, and ease people’s minds about how you produce this “fermented” cod liver oil, which we now know is a misnomer since you can’t actually ferment oil.

Sadly, we have not seen more transparency. We have only seen more obfuscation.

I’d like to address some of the issues I have with your actions, and your lack of action, in the following open letter.

Your Current Giveaway and Your Website’s Purity Statement

It recently came to my attention that you are currently promoting a giveaway that features a trip to tour the fishing vessel the “Northern Leader”. This is the ship that you recently wrote about as being the one that supplies Green Pasture with its cod livers to make your fermented cod liver oil (FCLO).

In that article you state:

“The Northern Leader is the largest and most innovative commercial fishing vessel built in the U.S. in over 20 years. This Alaskan freezer-longline fishing vessel is 184′ long and packed with the most innovative processing equipment that ensures the highest quality longline cod product in the world, including cod livers.”

I’m a little confused. The Purity Statement currently on your website reads:

“Many of the world’s issues regarding the sustainability of fishing communities are directly tied to the size of the fishing boats. The most pronounced issues arise from the use of large boats, such as large commercial high seas processing boats.”

The article goes on to state:

“We do not work with any large commercial processing boats.”

And finally:

“A perfect world would mandate that a fishing boat not be larger than a family size boat.”

Family Size Fishing Boat or 16,000 Ton Commercial Vessel?

According to the Port of Seattle YouTube video below of the Northern Leader Christening, the Northern Leader is “one of the largest longliners in the world, weighing in at 16,000 tons.”

Washington Governor, Jay Inslee says in the video:

“At 184 feet long, it’s the largest commercial vessel… in the last 20 years.”

Why This is Problematic for Your Customers

There is nothing wrong with using a large commercial fishing vessel like the Northern Leader. In fact, I’ve read that this commercial vessel is one of the most eco-friendly in the world.

But here is the problem people have with your communication, Dave…

You said you don’t use large commercial processing boats and then it turns out you do.
You said your fish comes from Scandinavia and then it turns out you’re getting it from Alaska.
You said you’re using cod and then according to the lab testing, it turns out at least some of it is pollock.
You said you “ferment” cod liver oil and then you admit that oil can’t be fermented.
You said your product has high vitamin A and D and then independent testing reveals the levels are much lower than you advertised.

Perhaps you haven’t gotten around to updating the Purity Statement. May I suggest that you fix this inconsistency on your website?

This should be easy for you to do, since you have experience with rewriting this page over the past year. I’d like to address some of those changes…

Updates to FCLO Website and Packaging Made After Dr. Kaayla Daniel’s Whistleblower Report

Arctic Ocean or Bering Sea?

Before Dr. Kaayla Daniel’s report was published on August 21st, 2015, your Purity Statement contained the following information:

“The fish used in our Fermented Cod Liver oil and Skate Liver oil are exclusively wild caught in and around the Arctic region.”

Here’s a photo of what it looked like prior to Dr. Daniel’s report, thanks to a screenshot from the Wayback Machine:

After Dr. Daniel’s report, you immediately updated that web page to say:

“A majority of our livers used for our oils come from deep cold water oceans in and around the Bering Sea region and in general area of the Aleutian Islands.”

This is what it looks like now:

The Aleutian Islands where Northern Leader fishes is over 800 miles south of the Arctic Region. Perhaps you were thinking the Alaska pollock and Alaska cod swim across the North Pole and into the feeding grounds of the Atlantic cod then migrated down into the Lofoten region of Norway to spawn before returning to Alaska’s Aleutian Islands?

Is this why you also stated the codfish swim up to 1,000 miles and why you call one of you FCLO flavors Oslo Orange? You do realize Oslo is in Norway on the other side of the world from the Aleutian Islands don’t you?

Oslo Orange? Arctic Mint?

That brings us to another issue… the labeling on the bottles…

You recently had your labels redesigned… but for some reason you decided to stick with the names “Oslo Orange” and “Arctic Mint” for two of your flavors.

Considering that the Northern Leader does not catch fish in the Arctic Ocean, and Oslo, Norway is on the other side of the world from the Bering Sea, where your fish are caught, do you think it makes sense to keep these names on your packaging?

Do you think that maybe it might be misleading to customers thinking they are buying a product that comes from Norway? If the products are made from fish coming from Alaska, shouldn’t you call these products something else other than “Arctic” and “Oslo”?

Updates Made After Price-Pottenger Nutrition Foundation’s Cod Liver Oil Article

On August 6th, 2015, The Price-Pottenger Nutrition Foundation (PPNF) published the blog post, “Cod Liver Oil: A Historical Perspective”. PPNF was founded in 1952 and is the steward of all of Dr. Weston A Price’s research. Their cod liver oil blog post uncovered two new revelations:

1. Dr. Weston Price didn’t recommend fermented cod liver oil. He recommended fresh/raw cod liver oil.
2. Dr. Price also warned against using solar activation.

Here’s a quote from the article:

“Exposure for one hour to the noonday summer sun or to a mercury vapor quartz lamp produces a product which is distinctly harmful, and it would be better to use the raw cod-liver oil unactivated than to use this product.”

Prior to the PPNF blog post, your FAQ contained the following statement:

“We solar activate all our products as Dr Weston A Price did. Solar activation is simply exposing the product to the sun. Our Plant is a solar plant and we ensure that all our oils are exposed the the sun, moon and stars.”

After the PPNG blog post, you immediately changed your FAQ to say:

“Our plant is exposed the sun but this does not equate to solar activation as Dr. Price discusses. Dr. Price had a specific protocol and definition for the term solar activation and it does not occur unless uv rays are directly exposed to the products. In our plant the products are not exposed to solar uv.”

Tablespoon or Teaspoon?

There’s another piece of inaccurate information that is still on your website that you need to remove…

At the very top of your FAQ page, you still feature a video of Weston A. Price Foundation Board member and Sarah Pope of The Healthy Home Economist blog advising your customers to take 1 TABLESPOON of cod liver oil per day.

Sally Fallon Morell, President of the Weston A. Price Foundation, posted on their website a year ago that the over-consumption of cod liver oil for an extended period of time can contribute to heart failure.

Quote from the WAPF website:

What about claims that taking fermented cod liver oil caused someone to have heart failure?
An individual took 1-2 tablespoons per day of another brand of cod liver oil from 1979 to 2006 and 1-3 tablespoons daily of fermented cod liver oil from 2006 to 2012. This is 3-9 times the recommended dose over many years. If this in fact contributed to his heart failure, it is just as likely that his extended over-consumption of cod liver oil in general, rather than fermented cod liver oil in particular, was the contributing factor.

Heart failure is a very serious and fatal condition. Shouldn’t you remove that video from your FAQ, Dave?

Looking Forward to Your Response

Dave, I have emailed a link to this article to you, to ensure that sure you see it.

Given the fact that you were able to very quickly update your website in response to Kaayla Daniel’s whistleblower report last year, I am confident that you will be able to update your Purity Statement to remove the statement that you do not use large commercial fishing boats.

Also, I think it would be very wise for you to remove the video of Sarah Pope recommending that we take a tablespoon instead of a teaspoon of FCLO.

I would also like to suggest that you change your labeling to more accurately indicate where you are sourcing the fish you use in your processing of the oil.

Finally, if you really want to show that you are running a transparent and trustworthy operation and producing a quality product, why not come clean with your manufacturing process? I think I can speak for most of my readers when I say we’d all like to see how you make fermented cod liver oil. For example, how do the livers get transported from the Northern Leader fishing vessel to your Nebraska farm for processing and “fermentation”? Are they packed and shipped frozen? Where does the fermentation of the livers take place? Is it in a factory or in the greenhouse on your farm? Is the oil exposed to light and air? How does the fish oil stay protected from rancidity? Is it kept cold and in the dark and not exposed to oxygen?

I think if you really want to reassure consumers that your product is safe, you will share this information with us.

I have not gotten a response back yet to any of my written communications with you and Green Pasture Products since I started emailing you last fall. Looking forward to your response. I will update my website if I hear from you.

Sincerely,

Ann Marie Michaels
A former supporter of Green Pasture’s FCLO