Important Update on Cod Liver Oil
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Important Update on Cod Liver Oil


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An independent analysis of Green Pastures Fermented Cod Liver Oil suggests that it may not live up to its claims. But is the analysis sound? Get the nitty gritty details and my recommendations.

best cod liver oil
One of the best ways to get a daily dosage of cod liver oil is in capsule form. obewon/iStock/Thinkstock

As many of you know, I’ve long been an advocate of cod liver oil. In addition to being a good source of long-chain omega-3 fats like EPA and DHA, it’s rich in vitamins A and D, which are difficult to obtain elsewhere in the diet.

For several years I’ve recommended Fermented Cod Liver Oil (FCLO) from Green Pasture. I took this product myself, and my wife took it throughout her pregnancy and while she nursed our daughter, Sylvie. I recommended it to my patients, readers, podcast listeners, and friends and family.

About a year ago, I received an email from a new company called Rosita Real Foods regarding a new cod liver oil product (called Extra Virgin Cod Liver Oil, or EVCLO) that they were bringing to market. Leading up to the launch of their product, they sent out a series of emails explaining how it is manufactured, processed, tested, and produced.

I was impressed by their transparency: they provided test results for fatty acids, vitamins, dioxins & PCBs, rancidity, and oxidation by-products on their website, along with a list of institutions that performed the testing as well as the dates of the tests.

As soon as the EVCLO product became available, I ordered some. I noticed right away that it smelled, looked, and tasted fresh. This, together with Rosita’s transparency and third-party testing, was enough to convince me to switch over to EVCLO and begin recommending it to my tribe.

Independent Analysis of Green Pasture Fermented Cod Liver Oil

Last weekend I received an email from Kaayla Daniel, a nutritionist who has been involved with the Weston A. Price Foundation (WAPF) for many years. She had grown increasingly suspicious of the Green Pasture product recently, and she requested that the WAPF conduct independent analysis of it to determine whether it lived up to its claims. The WAPF voted not to conduct this testing, so Kaayla took matters into her own hands.

My take on the recent report on Green Pastures Fermented Cod Liver Oil.

The result is a 110-page report with test data from multiple independent laboratories both in the United States and abroad with expertise in testing marine oils and nutrient levels. You can read the full report for free here. But in short, these were the conclusions from her report:

  • One of the three batches of FCLO that were tested was found to be rancid, based on free fatty acid values.
  • Levels of vitamins D, A, and K are lower than Green Pasture claims on its website.
  • DNA testing of the livers purportedly used to make FCLO suggests that it is not made from cod, but from Alaskan pollock. Oils from Alaskan pollock liver have a different nutritional and fatty acid profile than those from cod livers (which explains the next finding).
  • While all other cod liver oil products contain more DHA than EPA, FCLO contains more EPA than DHA. This EPA-to-DHA ratio is consistent with what you would find in Alaskan pollock liver oil.

Kaayla’s report certainly raises a number of issues that deserve attention. However, I do have some concerns about the data she presents. They arose out of research I did over the weekend, as well as discussions with colleagues in the fields of biochemistry, nutritional science, and lipid science.

Are the Fat-Soluble Vitamin Tests Results Reliable?

Testing for fat-soluble vitamin levels is incredibly complex and not yet standardized. I am concerned that the approach to quantifying them in Kaayla’s report was oversimplified. This is based on communications I’ve had with Dr. Chris Masterjohn, a nutritional scientist and an expert in fat-soluble vitamins.

Chris has noted that there are likely at least half a dozen (if not more) vitamin D compounds in cod liver oil, and it may be that the preponderance of biological activity comes from compounds other than vitamin D3 or D2. (This is the case with cow’s milk, where most of the vitamin D activity comes from 25(OH)D and very little comes from vitamin D.)

In fact, one vitamin D expert has remarked that a scientist could spend an entire career simply characterizing the factors responsible for the vitamin D activity in cod liver oil. Clearly there’s a lot more to this than comes across in Kaayla’s report.

This may explain why Dave Wetzel, the owner of Green Pasture, has been attempting to quantify the fat-soluble vitamin content of FCLO for many years but has never been entirely successful. It seems that there are many different vitamin-D-like or vitamin-K-like compounds in FCLO (and other cod liver oils) that cannot be easily measured with current analytical methods. Measuring the biological activity of vitamin D compounds by feeding the substance in question to rats may be a better method of determining vitamin D content than quantifying the levels of D2 and D3. (Green Pasture did this kind of testing in 2009, and the results indicated that FCLO contained roughly 400 IU of vitamin D per tsp, which is in line with what you would expect for cod liver oil.)

Is FCLO Really Rancid?

If FCLO were truly rancid, we would expect to see very low levels of EPA and DHA in the oil. Once fatty acids (like EPA and DHA) undergo peroxidation, they cannot be regenerated from their peroxides. However, on page 102 of Kaayla’s report, the lab results show that FCLO has approximately 315 mg/tsp of DHA and 685 mg/tsp of EPA, for a total EPA/DHA content of 1,000 mg. According to Rosita’s website, EVCLO has approximately 1,200 mg of EPA/DHA combined. So, while the batch of FCLO tested in Kaayla’s report contained less EPA/DHA than EVCLO, it still contained a substantial amount—which would not be expected if the oil were rancid as claimed.

The claim that FCLO is rancid was based on high levels of free fatty acids found in the oil. Kaayla suggests that this is an accurate way to determine rancidity in marine oils. However, according to most lipid scientists, hydrolysis of triglycerides and other esterified lipids into free fatty acids is completely unrelated to oxidation and is therefore not an accurate measure of rancidity.

Instead, TOTOX, anisidine, MDA, and TBA/TBARS are better indicators of whether an oil is rancid. In Kaayla’s report, FCLO received good scores from all of the labs on TOTOX, and all but one lab (which was not able to obtain a result at all) on anisidine. Two of the labs reported normal TBA values. One lab reported a TBARS value that was high, and another reported an MDA value that was 10 times higher in FCLO than in other cod liver oils.

These results are somewhat mixed. The majority suggest that FCLO is not rancid, while two of the test results suggest that it is. I think more investigation is needed on this before any firm conclusions are drawn.

Variability in Test Results from Lab to Lab

There was significant variability in test results from lab to lab and test to test. The samples Kaayla sent in for testing had manufacture dates ranging from 2012 to 2014. It’s conceivable that Green Pasture changed its production methods during that period of time, which could explain the variation in the results.

Another possibility—and one that is likely—is that the variability is at least in part explained by different methodologies and techniques used by different labs. Unfortunately, this is difficult to verify and investigate further because Kaayla was not able to name the labs in her report (due to legal agreements).

Though this seems to be common practice in this field, I feel that the omission of the names of the labs that performed the analysis weakens the reliability of the findings. Given the known complexities involved in this kind of testing, as well as the variability between labs, it’s unfortunate that we can’t ascertain which lab did which tests. This isn’t a criticism of Kaayla, because I imagine it was beyond her control, but I do see it as a downside.

Summary and Recommendations

Kaayla’s report does raise some concerns, but clearly there is a lot more to it than initially meets the eye. Rather than viewing her report as the final word, I hope that it’s the spark for an informed and forthright investigation into the issues that she has raised.

Green Pasture has issued a preliminary response here. Interestingly, it makes some of the same points I have made in this article (that biological activity may be a better measure of vitamin D content than quantifying D2 or D3 levels, and that free fatty acids are not an accurate measure of rancidity in marine oils). They are also working on a more detailed response, which I look forward to reading.

One of the lingering issues that Kaayla raised in her report is the finding that the livers used to make FCLO were not from cod, but from Alaskan pollock. I certainly hope Green Pasture addresses this in their upcoming response.

Frankly, I feel that I don’t have the information I need to make a clear decision about whether to continue recommending FCLO. I am in touch with several people with expertise in marine oils, lipid science, and nutritional biochemistry in an attempt to better understand the implications of Kaayla’s report. I will report back to you as I learn more.

In the meantime, I do feel confident in recommending EVCLO from Rosita Real Foods. As mentioned above, they are transparent about their manufacturing process, they post independent lab results (including the names of the labs that performed the tests) on their website, and their product smells, tastes, and looks fresh. They also have an extensive FAQ with answers to many questions about their product and process.

How Concerned Should You Be If You’ve Been Taking Green Pasture FCLO?

Kaayla’s report identifies some issues that deserve further attention, including lower-than-reported levels of vitamins A, D, and K, possible rancidity, and a different ratio of EPA to DHA than would typically be found in cod liver oil.

However, it’s worth pointing out that I have numerous patients whose health noticeably improved after taking FCLO. I’ve heard similar reports from hundreds of readers and podcast listeners, as well as from women who went through my Healthy Baby Code program. In fact, my wife would count herself among this group, and if you search around on the internet, you’ll find testimonials from many people with similar stories.

So, while I do think this report warrants more investigation, I don’t think it is cause for panic. I will continue to investigate this issue and update you when new information becomes available.

Dr. Chris Masterjohn, a nutritional scientist with expertise in fat-soluble vitamins, published his preliminary thoughts on Kaayla’s report. It’s worth reading.


Join the conversation

  1. I tried the Green Pastures FCLO on more than one occasion, after you and others had enthusiastically recommended it, and just could not stomach it. My body just hated it. So on a gut level, I am not surprised that there may be issues with it.

  2. I’ve tried both FCLO and EVCLO. I stopped the EVCLO recently because the taste absolutely made me gag, and my 1.5 year old daughter refused to take it. It definitely did not have the “mild, fresh” taste that they claim on their website. I went back to the cinnamon FCLO and I can take it down fine as can my kiddo. I don’t know…I’m still not convinced any of these things are superior, and I have had a lot of concerns about the legitimacy of the Weston A. Price Foundation. I haven’t read anything that gives me reason to believe they are experts about anything in nutrition. I guess the lesson is that we should all be skeptical, do our independent research, and ultimately go with what our body tells us.

  3. I was already a GP customer when I approached David Wetzel over email with some questions regarding seafood sustainability (I’m a marine ecologist, so I am particularly interested in sustainability questions). The short of it is that I wanted to know, given how common seafood mislabeling is, how GP ensures that their product is what it claims to be. How do they know it’s cod? How do they know it was sustainably harvested? Do they know their suppliers or do they just communicate through a middleman? Not only did David Wetzel refuse to answer my questions, he basically told me to f-off and never contact him again. I was dumbfounded. Based on their lack of transparency on this matter and on how rudely I was treated (even after stating I was a faithful customer) I would never again recommend their product to anyone. Oh and the last batch of FCLO I did consume did taste awfully rancid to me.

    • Viola, that is shocking indeed. Especially coming from a producer who’s reputation is based on ethical production and high quality products. I hope that was simply an aberration, but I want to thank you for sharing this. Do you still take GP or something else now?

      • I don’t take any fish oil for the time being. Instead I rely on fresh fish: I subscribe to a CSF (Certified Sustainable Fishery), which works a lot like a vegetable CSA and delivers seasonal, local seafood on a weekly basis. I still think supplemental cod liver oil is a good idea, especially in winter, and plan to try the Rosita EVCLO combined with butter oil once flu season starts, especially for my kids.

  4. While I don’t know what is going on with the blue ice fermented CLO, we did take the old formulation of high vitamin cod liver oil until it was no longer manufactured and it worked very well at keeping my children’s teeth strong. But since they no longer make this, we had tried the fermented CLO but the odor and taste was objectionable and my children would not take it. My cat would not go near it either and normally he will lick fish oil off your fingers if it’s fresh. In any case, I hope this leads to a better product overall and better transparency. We no longer buy fermented clo. We gave up on it. I’m glad to see a new product available that is not fermented.

  5. Hello Chris,
    I have no problems using the cod liver oil, I find it has benefited me on my search for health. I don’t even have a problem the livers come from polluk, in a world of overfishing our traditional cod species are over fished, I don’t mind the change to help bring their numbers back up.
    As far as whether or not the livers are processed by fermented or rotting. ….many Indigenus cultures on our North Pacific Coast made Eulachon(ooligon) oil/grease, it was a staple in their diet for preservation of different food, stomach ailments, skin disorders etc. My grandfather’s tribe the Tlingits used this amazing grease and our ancestors thrived until modernization. The eulachon fish is first rotted before the oil is extracted.

  6. Sandrine Love, a member of the BOD at WAPF posted a comment on David Gumpert’s blog stating:

    “Sandrine Love
    Today 10:59 am

    ‘My assessment is that there was no intentional deceit made by Green Pasture Products in regard to disclosing the exact species of cod used. Had Kaayla expressed her concern about the fact that the exact species of cod was not revealed before she published her report, David Wetzel has shared that would have immediately added that to his product descriptions and labels without hesitation. He will add it to his labels now. He uses Pacific Cod and about 10% Alaskan Polluck to make their fermented cod liver oil, varying on availability at any given time. As has been established by many, both species are considered to be cod in the scientific community and it never occurred to David to add a list of the specific species to his label since it isn’t industry standard to do so.’ “

    • I take Green Pastures FCLO. I’m very worried to discover that the cod used is from the Pacific Ocean, also 10% Alaska.

      I always bought canned Wild Alaskan salmon but stopped buying it because of the radiation in the Pacific Ocean from Fukushima.

      Of course, I don’t want FCLO that is sourced from the Pacific Ocean. I also see that Rosita FCLO is a lot more expensive than Green Pastures.

      Can Chris recommend a FCLO or CLO that is a safe source at a reasonable price? Thanks.

      • Fukushima radiation is inescapable, I’m afraid. You can not simply avoid it by not eating seafood out of the Pacific Ocean. The radiation from that disaster has already been detected as having reached the shores of North America some time ago, but the media has largely ignored this in an attempt to downplay the situation.

    • I take FCLO from Green Pasture. When I read this article just now, I wondered if the Alaskan Pollock and the Pacific Cod might be contaminated with radiation from Fukushima. Does anyone know?

      • I’ve avoided fish from the west coast since Fukushima, I’ve also avoided shrimp from the gulf coast since the spill and reading a report that my son found regarding the eggs of shrimp, are found by their heads. The eggs are suppose to be by their tails. Mutated shrimp isn’t on my plate. Worth mentioning, Whole Foods, in the northeast sells west coast fish ( dover sole ) and gulf coast shrimp rather inexpensively. When I wrote them about it they didn’t respond.

    • It’s irrelevant. What Dr. Daniel did is probably illegal. It’s called SLANDER. Spreading fear and scare-mongering, naming the specific company, causing harm to GP reputation, withholding info, going around the Board, abusing her position, possible collusion with a competing product, and more. LAWSUIT.

      Green Pasture has caused nobody any harm from any pathogen or Pollock. Even her “tests” found no pathogens. The rest is fear-mongering.

      • Jesus, calm down, Dave. It seems to me you are the one doing the slandering. Do you really know what that word means? She has done nothing illegal.

        • Oh, no big deal, Causing possible major financial damage to a company that has harmed nobody, publishing a scientific report as “shocking truth about fermented cod liver oil”, while on the Board of WAPF and FTCLDF, scaring people into distrusting a reputable company? It’s called LIBEL.

          Just sayin’. She’ll probably get sued for this “report”. It’s not an objective approach to this situation. GP has been in business for years. This has ulterior motives written all over it. IMHO

      • Dave, no one can say GP hasn’t done anyone harm. That might be true or false. However, the producers have the burden of proof that their product is safe, that burden shouldn’t be placed on the consumer. I have no intention of starting a fight, but I just want to point out that you have done exactly what you’ve accused Dr. Daniel of doing. And please, don’t bring up the idea of law suit, that will make a loser out of you and me and everyone except the attorneys. I work in the legal field and see it first hand.

        • Fill us in.

          I’m a vendor of Green Pasture products and feel personally damaged by this e-book. There are many of us out there. She is causing damage to GP reputation with her e-book, when nobody has been harmed by this product. She has crossed many lines here, in my opinion.

          The accusations are equivalent to yelling fire in a crowded theater, rather than taking a scientific approach to this issue. The testing should have included several different brands of CLO and compared the results, not singling one company and individual. There seems to be a different motive here. Just sayin’.

          • Dave, thanks for for disclosing that you are a vendor for GP. Is it possible that Dr. Daniel wasn’t singling out GP but fermented CLO? I don’t know b/c I’m not familiar with which company carries what products. Sounds like there are lots of vendors out there feeling the pain, but equally there have been a number of posting of consumers feeling uneasy about this product before the report came out. I’m actually neither a vendor nor a user of any CLO. I’ve just started checking it out a few months ago and haven’t made a decision on any company. So I guess you can say I’m as neutral as they come. In any case, protecting the public should be the most important issue. waiting till someone reports they been hurt before we conduct independent test, well we know that’s a terrible idea. Besides, if indeed Dr. Daniels report is wrong, your biz will recover and will likely even improve as that will boost consumer confidence. I for one will start buying this. But I’m not going to start taking something on faith alone. In the end, the best we can hope for is that the consumer come out as the winner, and if that’s the case you being the vendor will win too b/c you’ll carry the best product be it GP or some other brand.

            • Thanks Helen.

              I look forward to GP and WAPF response.

              For the record, WAPF does conduct independent tests of GP FCLO:

              Here we can see that fermented CLO is similar in process to other fermented foods like blue cheese and fish sauces, with similar amines present. It is not any less safe than these other foods in that respect.

              GP products have consistently been found safe and healthful. GP has been in business since 2000 and routinely tests their products for safety, along with others tests such as vitamin levels and absorbancy. Much of this can be found at GP’s website.

              I just don’t want fear to be overwhelming people. I have many anecdotes of the benefits of their CLO. But there are other good sources of CLO as well. Some people might not tolerate the fermented due to certain amines, like histimine.

              I don’t speak on behalf of GP, just have done my own reading and know how it personally has benefited me (tooth decay issues) and other people.

              • Hi Dave,
                Thank you for your last comment. I can sense you are genuine, and that makes me want to be more open minded about this.

            • Bravo, Helen. Excellent, reasonable response. I look forward to the coming months. I truly hope truth will prevail here that doesn’t require legal action (no offense!).

    • People isn’t it obvious WAPF has given GP special treatment in the past and continues to do so. Sally Fallon refuses to test GP products despite Dr. kaayla’s suspicion, to me Fallon has lost her credibility for good and I won’t be renewing my WAPF membership this year b/c of this. I’ve had my suspicion about Fallon and Sarah Pope for awhile. besides, Pollack isn’t cod, it’s related but not the same. That alone makes me not believe anything GP claims. Chris I hope you won’t delete my comment just b/c I named important people. Regular folks need to always question those with authority even if they are in natural health field. In the previous post someone mentioned why does everything has to be so hard in the health field, it’s hard b/c there’s a lot of money at stake, and sadly I think it’ll always be like this. So far I’ve been very impressed with everything from our Chris, and Chris Masterjohn and his friend Denise Minger.

      • Helen,
        I have heard the same thing. There is something going on between GP and WAPF. WAPF is not going to drop GP. When I heard that right away WAPF has lost its credibility for me as well. I take everything they say with a grain of salt now and it saddens me.
        I have always been suspicious of GP though and I did not understand why GP was so revered.

        • I have to admit that the pricing has always seemed over the top to me, and I have also noticed the extremely close relationship between GP and WAPF (see “Dave’s” histrionics in the above comments).

          I’m also concerned about the use of pollack.

          Having said that though, I do fine that FCLO from GP has made a difference in my health.

      • The WAPF board declined to test GP’s FCLO *again* after already having done so, I believe it was last year but that’s from memory. Jeez, people are really jumping to conclusions and assuming all kinds of bad motivations — on both sides.

        One thing to consider in the contradictory reactions is simply biochemical individuality. Some people thrive on FCLO and others can’t tolerate it. No one is “right” or “wrong” for their response, and it’s just possible both FCLO and EVCLO are both fine, healthful products — just not for everybody. I don’t have a dog in this fight; I’m just trying to follow the evidence.

      • Helen –

        I like your voice of reason here. I would love to hear your comments about Sally Fallon’s recent post responding to Dr. Daniel’s expose:

        In it, she claims that in 2014, GP gave WAPF (in the form of membership, ads and sponsorship) a little more than $20,000, or a total of about 1.1% of the annual WAPF budget. Assuming this is true (I have never had reason to think Ms. Fallon would lie about such numbers), I find it hard to believe WAPF has much to gain financially whether or not GP stays in business or not. She said she personally gains about $1000 a year through selling FCLO through her farm store. Not enough to even pay for your car insurance for a year!

        So, have you seen other happenings, something else that leads you to believe that GP and WAPF are somehow “in bed” together?

        My sense is (and Sally says so) that WAPF has promoted the GP products long before GP was a sponsor, because they believed in the products as good.

        I read all these comments on these blogs about these issues that “GP is WAPF’s biggest financial contributor” but give nothing to back it up. All I have to go on is Sally’s word that GP gave about 1.1% of their budget in 2014. I suppose someone could ask her to back up that statement with financial documents or a tax return? But where are people getting the idea the GP is giving tons of money to WAPF? $20,000 isn’t much money, in the big picture of things.

    • Actually, FDA requires that you list the common name of any fish species used. Dave has no clue what he’s doing.

      Their failure to list vitamin contents in the supplement facts panel is a violation of labeling laws. So, there’s another law they’re breaking. Not surprising, really.

      • I have wondered about that, too (the lack of labeling of nutritional value per dose), esp. since I take a multivitamin and had to start taking a D3 supplement last winter due to low D levels. (I’ve been taking less than the recommended dose of the FCLO + butter oil capsules, just one per day on most days, because they are so dang expensive).

        Wondering now if the FCLO has played a role in my worsening reflux despite the improvements in my diet over the last few years…

  7. Thanks so much for posting this Chris. I haven’t thrown out my bottles of GP FCLO yet. But want to learn more about the possible presence of “vegetable oil”.

    • This was the most concerning part to me, too–about the possible dillution with vegetable oil–and I am surprised to hear so little about it in the conversation.

  8. Cod Fish are loaded with parasites and worms. Yes, even in the liver. Fermented and extra virgin cod liver oil is not heated to kill these buggers. The bigger critters can be filtered out not the little ones. What’s the exposure here? I would like to hear from the experts. It’s not uncommon to find worms in canned cod livers from Europe.

    • Hmmm….this is a good inquiry. It’s a raw fish product after all. I wonder if it’s possible to filter the oil with such a small “screen” that parasite eggs are removed. I’d also like to hear more from experts about this aspect of raw fish liver oil.

      • It’s been 40 years since I took a biology class that went into detail about the parasites in fish, but ever since I have steered clear of sushi. (I did hear that the lemon juice used in ceviche “cooks” the fish– it turns from translucent to solid white, as if it was cooked).

        So no raw fish for me, even if fermenting it makes it safer, that might not be enough.

        It’s likely that Kaayla Daniel’s edge of anger arose when her reasonable questions were ignored. I’m still grateful for her book The Whole Soy Story and other work. A good editor would have helped her voice be more dispassionate, and raise questions instead of make judgments where data was skimpy.

        Nevertheless, the more transparency the better, and Kaayla Daniel has helped us all see that. Ditto for WAPF, an organization that we will someday recognize as a major player in rebuilding health around the world. It’s like when two dear friends have a spat, I wonder why they can’t sort it out since they’re both sincere and wise.

    • I always understood that we didn’t need to cook canned salmon and canned sardines. Do we need to cook canned salmon, canned sardines and other canned fish to kill worms?

      • No.

        The heat involved in canning kills worms and other pathogens – the point of doing it in the first place, to preserve it. However, canning does not deal with botulism spores (don’t eat from bulgy or rusty or seam-dented cans), nor does it necessarily destroy all toxic products generated by said creepies prior to canning, assuming the product was not well handled. If it smells or looks bad, or is mouldy, or includes a dead fly (happened to me – twice), or metal or glass or plastic, etc., throw it out.

        Stick with reputable brands, and worry more about BPA/BPS can linings. And your vinyl shower curtain.

  9. Thanks Chris for weighing in on this very important issue. As always, I appreciate your knowledge, diligence and level-headed approach. More testing is needed, however, there are enough suspicions raised in Kaayla’s report that I will no longer be taking FCLO. The preponderance of evidence suggests to me it is not what it is claimed to be and may contain harmful substances. Why take the risk?

  10. My understanding is that some cheaper CLO processes the D out of the oil. They then add it back in… But that may defeat the central reason for taking CLO.. The idea is to maintain the natural balance of A and D..Too much D or not in the right ratio will wipe out the A and something similar in reverse..So if you are taking cheaply processed it may only be like taking a fish oil pill and a D pill. … I think you need to get the expensive stuff that more carefully extracts the oil and maintains the integrity of the A and D.

    I was thinking of switching to EVCLO but the WAPF recommendation to take FCLO kept me in place.. I will now switch.
    I would love to see more discussion of Paul Jaminet’s recommendation to only eat fish and not take CLO. I think he says cold water fish like salmon once per week and then eat sardines and other small fish regularly.

  11. I never got into taking FCLO or any oil form CLO due to the taste and ‘burpeeness’ it caused for me….I currently take Standard Process cod liver oil and Tuna Omega-3 oil, both in gel perles and rotating back and forth between them….but for the most part prefer to eat a lot of real foods such as pastured organ meats……regarding the issue at hand, standards seem unclear; transparency is lacking; and questions abound….however, these are ‘supplements’ none-the-less and are meant to supplement FOOD….eat more food…

    • I also take Standard Process cod liver perles; Standard Process comes recommended to me through my chiropractor. He has visited the site to see how they produce their products and says they have very high standards for their products.
      Chris, I would like to know if you have used or considered using any Standard Process products in your practice. High quality products are very important to me.

  12. Each time I’ve tried GP FCLO I’ve experimented anxiety, hot flushes/sweats, acne … I left the very expensive bottle in the fridge and there it is, now I can explain my reaction.
    I thought it was because of fermentation and ordered the rosita EVCLO … Let’s see.

    • I’ve experience more skin problems since I’ve upped my dose. I’m breast feeding and needed to make sure I was getting enough. I had a keratosis Polaris outbreak and it’s making it worse. I just ordered the EVCLO a couple days ago. We will see if it makes it better.

    • Fascinating! I just started taking Green Pastures FCLO (a week or so ago) and I’ve been experiencing something like hot flashes and sweats, which I could not understand (being 61 and well past all that nonsense). Strange, and now I’m really curious about whether they could be related. And, if so, how?

  13. Chris,

    As I commented on a recent piece written by David Gumpert, I’m very confused as to why Daniel saw fit to black out all lab identifying information for data she claims is legitimate. Which as you’ve explored may be…but also potentially may not be.

    Daniel says vaguely in her report that the participating labs required it for unspecified legal reasons. Another commenter on David’s blog added that, somehow being a third-party and not dealing directly with a supplier, an identified lab in this scenario would be subject to legal repercussions. Is this true?

    There doesn’t seem to be much logic to those explanations. As long as the lab abided by standards for a testing methodology, there shouldn’t be any risk of being sued, say, for defamation. They’re just running the tests. In the anti-doping world, athletes who have been found to use banned substances don’t have a case against the lab(s) that furnished the incriminating data, as long as the tests were carried out with honesty and integrity. And WADA-accredited labs y are by nature a third party.

    But how are we supposed to know if the labs Daniel used carried out their functions in an honest way if we don’t know who they are? If Daniel is not transparent about her sources?

    Imagine sitting in a courtroom. You’re in the jury. Daniel (plaintiff) v. Wetzel (defendant). Issue is over whether or not the oils are rancid, which Daniel charges they are. Wetzel presents lab evidence that the oils are not rancid. The names of the labs used are identified, as are their managers, who take the stand to explain their results, how they were obtained, why in their judgment results indicate that the oils aren’t rancid. Daniel the plaintiff now gets an opportunity to cross-examine these lab managers, to question their expertise and the value of their testing.

    Now it’s Daniel’s turn to present lab data supporting her allegations. She presents figures and interprets them for the court, but when asked for identifying info. re her participating labs…she can’t supply it to the jury…”for the legal reasons”? Wetzel the defense, as a result, doesn’t have an opportunity to cross-examine the lab managers acting for the plaintiff because…we don’t know who they are. They’re anonymous.

    Is this evidence admissible? As consumers in the jury, trying to determine if Daniel’s report has validity, how are we in some measure supposed to cross-examine the origins of the evidence if there is nobody to take the stand, nobody to cross-examine?

    We can’t adequately do so, and are only left to wonder why transparency is supplied from the side of the defendant but not from that of the plaintiff.

    • Perhaps Ms. Daniel was able to obtain independent lab tests at a much lower cost by agreeing to the anonymous reporting. Liability insurance would be quite expensive.

      Any expert testimony would be quite expensive. The greater the compensation, the greater the bias likely to be inferred by the jury or judge. Personally, I am less persuaded by lab test results that are paid for by a commercial manufacturer or other seller. This comes up in any discussion of pharmaceutical company research of course. Note that the best scientific medical journals now require that funding sources be disclosed.

      • A further note: in contrast to other health professionals and online businesses, the provision of medicines is limited to pharmacists, who should be independent practitioners, not financially linked to the prescribing medical doctor. For this reason, I do not buy supplements or medicines from online commentators,

    • I work in the legal field. Trust me no one wants to get sued, no one wins others than the attorneys. I totally understand why the labs didn’t want to take the risk of being sued. It will kill their business even if they did nothing wrong. To me the fact that Dr. kaayla’s didn’t reveal the lab names doesn’t make her less credible. The fact that WAPF refused to test GP products makes me wonder what kind of financial arrangements are made btw them.

        • Well I actually asked about the financial arrangement kinda rhetorically, but since you brought it up, I think it’s must be a real sweet deal for WAPF/Sally Fallon to put her reputation on the line and refused Dr. Daniel’s request for testing.

        • They probably pay in the neighborhood of $10k in order to sponsor wise traditions. In return, theirs is the only product recommended to the thousands of WAPF members the world over.

        • Kat, thanks for pointing out the GP sponsorship of WAPF conferences. Yes I overlooked this obvious one. I introduced my friends to WAPF shortly after I joined. I always told my friends that it’s the best org I’ve found so far but watch out as soon as they get big, their advise will become tainted like every other influential org. I guess that time has come sooner than I expected.

      • The Healthy Home Economist Sarah said that the board voted not to retest because they had already tested for rancidity. So the WAPF board voted not to RETEST because they had already TESTED previously.

        “Hi Joy, the WAPF has already independently tested the FCLO for rancidity and this occurred last year. It was done by a highly reputable lab in the UK and was the basis for the WAPF Board voting 7-1 against futher testing and that Dr. Daniel’s concerns about the product were unfounded.

    • I read elsewhere that the reason Daniel may have been required by the labs to black out their names is that she was not the supplier, but rather, a middleman. If the supplier had provided them with the product directly they would have been happy to publicize the results under their name. But since they couldn’t vouch for the “chain of custody” of the product, they would have been opening themselves up to a lawsuit by publicizing the negative results. (or something like that!)

    • The whole point is we are not in a court setting. We can consider all the evidence presented to regardless if it’s admissible or not. Dr. Daniel can’t reveal the lab names she used. But if this ever got to court(hope not), new tests can be done w/ labs willing to reveal their names b/c they’ve been adequately paid for the insurance they need to take out on this. We are consumers, we can make decisions without a judgement from court. I’m far more disturbed by what GP and WAPF are trying to hide than Dr. Daniel not able to reveal the lab names.

  14. My daughter took FCLO for maybe a year or less. We went through 2 bottles. aprox age 2-3. She would randomly throw up in mornings 1-3 times and be fine by noon. (she has only thrown up once in her life and we were both sick) I found out that every time she threw up, I had given her FCLO the evening before. I thought maybe her stomach was too empty and made sure to always give it with something or with dinner but that did not help. Once we stopped the FCLO she has not thrown up again in 9 months. It did not happen every time she took it and my best guess was that maybe it wasn’t all rancid but she was getting rancid pieces that she could not handle. We switched to Rosita’s EVCLO and have had no problems. I find this all very interesting given our history…

    • I can’t keep it down either, the smell is horrendous! The taste worse…

      I have read that the rancidity is due to the liver cells, not the oil. If fermented/rotted/rancid liver tissue is the reason for the dark color and the putrid odor, then even though the oil may be wonderfully rich in fatty acids and vitamins we are still ingesting something rancid and some people literally cannot stomach that. Use something else, I also use Rosita, but I use their ratfish oil – a few drops per day.

  15. I started taking GP CLO several years ago while I had marked joint pain & stiffness. I had a hard time walking to work & sleeping due to the pain. I started on Krill oil and the pain dropped off magically in 5 days. After 2 bottles of that I switched to GP CLO, taking just a quarter to a half teaspoon daily for about 4 years. Occasionally I would go off of it and within 2 weeks the raging pain & inflammation would return. I also had my 25-hydroxycholecalciferol tested during that time and it was 66 ng/ml, which I felt was significant considering I had lived in Seattle for over a decade at that point. I have since moved to a sunny locale and have drastically reduced my GP CLO and am only slightly more stiff & painful than without it. I am opposed to supplements preferring foods instead. I thought of CLO as more of a food than a supplement. However, now I am hesitant to keep taking it. A Salish medicine man once told me that before the white man came, his ancestors used to dig a pit in the ground and fill it with ooligan and wait for the oils to rise to the top. They would then mix the grease with blueberries and make cakes out of it that they ate all winter. I assume that the antioxidants in the blueberries kept the fat from going rancid & the fat kept the blueberries from rotting & molding. Perhaps a lesson in there somewhere for fish oil producers today.

  16. Chris,

    Thanks for a great article as always. As someone who wants to switch from Green Pastures to Rosita, what would you recommend for us to supplement in addition to get our dose of K2? Would eating grassfed butter be sufficient or is there something else to substitute the loss of Green Pastures?

    Thank you!

    • Hi, Chris,

      I would like to echo Rosita’s comment. Do you have any recommendations for alternatives to Green Pastures’ Butter Oil? Your thoughts would be EXTREMELY helpful.

      Personally, I have seen a huge improvement in my skin from taking the FCLO/BO blend and no ill effects. However, I really trust your thorough, unbiased investigative ability to wade through “scientific” claims, and if your judgment is that some degree of concern and caution may be warranted, I don’t want to ignore that.

      As Ida pointed out, if I were to stop taking Green Pastures’ FCLO/BO, I would still need something to replace the Vitamin K2 from the Butter Oil.

      Lastly, thanks for posting an article on this subject; I was starting to see concerns raised about Green Pastures and was hoping you’d be able to give us a truthful perspective on everything.

      • Sorry, I mis-typed! Names get so easily confused. I meant to say that I echo Ida’s comment, of course.

        Don’t mind my typo. XD

  17. Oxidation of EPA/DHA (derivatives or non-essential fatty acids) is and will always be a problem. With 5 and 6 double bonds are many times more susceptible to oxidation that the plant-based Essential Fatty Acids. In fact, unadulterated Linoleic Acid is much more stable and the oxygen dissociation curve is similar to haemoglobin, which is why it is necessary for for proper cell membrane structure. The biochemistry makes sense.

    • But many people are not able to convert plant-based, short-chain omega-3 fatty acids into the long-chain animal form that our (animal-type) bodies use in our cell membranes. Only about 1/3 of the global population is reliably able to make that conversion.

      • That is actually not true. It is commonly taught but not backed up by science. “Alpha-Linolenic Acid Conversion Revisited,” by Norman Salem, et al., states “A recent article in the PUFA [Polyunsaturated Fatty Acid] Newsletter indicated that in adult men and women the ‘average estimated conversion of alpha-linolenic acid to n-3 LC PUFA metabolites and docosahexaenoic acid was 17.3 ± 12.8 and 3.6 ± 3.8 percent, respectively (mean + SD).’ This is likely to be an overestimate of the actual overall conversion rates for several reasons. We see even with this excessive estimate of the omega-3 derivative conversion that theoretically no more than 37% of them are converted to derivatives.”
        The article makes the case that in reality only about 5% of the ALA (omega-3) is converted into derivatives. Pawlosky and others calculate that less than a mere 1% goes to derivatives. The article ends with “The best estimates of alpha-linolenic acid conversion to n-3 LC-PUFA are much smaller than those claimed….”
        The article, “What is the role of alpha-linolenic acid for
        mammals,” Lipids 2002 Dec;37(12):1113-23, reveals that the major metabolic route of ALA in the body is beta-oxidation [burning for energy!]. ALA accumulates in specific sites in the body of mammals, and only a small portion of the dietary ALA is converted to DHA.

        We only need 10mg of EPA/DHA daily and this is easily accomplished on an as needed basis by our bodies. It is the unadulterated Omega-6 that is all important for proper cellular functioning. 95% of LA stays in its native form and is vital for cell membrane function and integrity, don’t get lost in the pathways.

          • If you supplement with Omega’s, it should be plant-based combination of organic, cold-pressed Linoleic Acid (Omega-6) and Alpha Linoleic Acid (Omega-3) in a 2.5 to 1 ratio, at least 3 grams a day. The difference you feel will be remarkable.

        • That’s a different issue. There is a difference between how MUCH gets converted (which is what your quotations address, I believe) and WHETHER people can do any conversion at all, which is what I was addressing. IF you can successfully get through all the conversion steps, then yes, your stats might apply. But that’s a big “if” — too big an “if,” in my mind, to make it a good idea to recommend plant-based n-3s as the best way to meet our need for omega-3 fats.

          Also, most Americans are already getting WAY too much omega-6. Recommending taking omega fats in the correct ratio is never going to overcome the huge imbalance from the rest of the diet.

          My 2-cents.

          • I would think all can do the conversion or they wouldn’t be long for this world. The Omega-6 the Americans are getting is highly processed so it is basically non-functional. They need to supplement with large amounts of non-processed, functional Linoleic Acid (Omega-6, at least 3 grams a day) to compensate for this problem. Fish oil will not address this problem.

            • Actually from memory delta 6 desaturase requires zinc, magnesium and B6 as cofactors and delta 5 desaturase requires zinc, vitamin C and niacin. Then there are the various desaturase SNPs. I’m not sure what the elongases require, but there don’t appear to be the same issues elongating the omegas as there are creating the double bonds. Delta 6 desaturase appears to be the rate limiting step. People in poor health and vegans would not be wise to rely upon short chain omegas to supply their essential fatty acid needs. Deficiencies in long chain omega 6 and 3 fatty acids have been described frequently among people suffering from eczema and schizophrenia, often due to problems with delta 6 desaturase enzymes. Supplementation with GLA for the omega 6 or of fish oils for the omega 3 has been shown to be beneficial in these targeted groups. Certainly evening primrose and borage oil or fish oils seem to help a lot of women with mebstrual issues and acne or eczema.

              • You’re getting your terms mixed up. There are only 2 essential fatty acids, the 18 carbon fatty acid Linoleic Acid (one of the Omega-6 fatty acids) and the 18 carbon Alpha-Linoleic Acid (one of the Omega-3 fatty acids). When you say supplement with fish oil for Omega-3, your are talking about the derivatives of EPA and DHA which are 20 and 22 carbon fatty acids with 5 and 6 double bonds. Vegans can do well but they have to be very careful about which foods they cook and what they eat raw. Cooking destroys the fatty acids (oxidizes them) which makes them non-functional.
                Delta-6 desaturase works fine in almost all people (if it didn’t, one could not mount an inflammatory response, not good for long term survival) and only needs to convert 1% of LA or ALA in the fatty acid cascade to keep up the the body’s needs. 95% of LA stays in its native form and used as a structural component of cell membranes, while 40% of ALA undergoes beta-oxidation for energy and the rest again is mostly unaltered.
                The problem we keep running into is people are using nomenclature improperly. We shouldn’t be using the term “Omega” at all because it refers to families of fatty acids, not specific ones.
                You are right that Evening Primrose Oil has been used for centuries (high in Linoleic acid and GLA) and it does work, I use it daily, but borage oil has different stereochemistry and has more limited bioavailability.

            • Dr. Jeff, regarding your comment

              “If you supplement with Omega’s, it should be plant-based combination of organic, cold-pressed Linoleic Acid (Omega-6) and Alpha Linoleic Acid (Omega-3) in a 2.5 to 1 ratio, at least 3 grams a day. The difference you feel will be remarkable.”

              Would you mind identifying any products that fit that recommendation?
              Also, if the common diet is already consuming too much Omega-6, does that recommendation still provide enough balance for Omega-3 intake?

              Also in regards to feeling remarkable, do you mind expounding on what benefits consumers might feel?

              Thank you!

        • OK here is the real data about conversion rates from Hussein, Nahed, et al., Journal of Lipid Research, Volume 46, 2005, pages 269-280

          “Overall conversion rates of LA and ALA, calculated from peak [13C] LCP concentrations adjusted for dietary influences on pool sizes of LA and ALA, were low and of similar magnitude overall for AA and EPA (0.18% and 0.26%; Table 2). LA→DGLA and AA formation was significantly lower on the FXO diet in each case, with ALA→EPA and DPA formation on average higher on the FXO diet, although the differences were not significant. Conversion of tracers to DHA was much less. [Note: We see EFA conversion rates of less than a mere 1%. The same less than 1% conversion rates held for DGLA, DHA, and DPA.]

          Few studies have attempted more than relatively crude estimates of isotope transfer from tracer into the various trace pools, and it is recognized that AUC values will overestimate true conversion rates and provide only approximate relative rates of transfer.” [Note: This is why so many health professionals have been misled into thinking the EFA-to-derivative conversion rates are much higher than they actually are.]

          • “Comparison of bolus versus fractionated
            oral applications of [13C]-linoleic acid in humans,” European Journal of Clinical
            Investigation, Volume 29 Issue 7, Pages 603 – 609

            “Conclusions: Using areas under the curve [the simple, standard method of analysis] overestimates the conversion, because different residence times are not considered.”

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