6 replies to this topic

[kconf]

Hi all,

Anyone familiar with CA 65 heavy metal limits? FDA has limits in mg/kg or ppm, but CA 65 has in mcg/day. I am having hard time doing conversions. Is it strange that CA limits it to 1/3 of what FDA allows? 

I appreciate any comments. 

[nwilson]

Prop 65 is a fun one.  Was just doing PPB to PPM conversions this week as we received test results back for Pb & Cd.  CA does have stricter level requirements than federal limits.  One thing to consider is to also look at the RACC (Reference Amount Customarily Consumed) as this can scale up with amounts consumed (over general serving size) over the daily limit allowance.  Been through 2 ambulance chaser litigations with 2 different products with a prior company and these things cost a lot and take a large amount of time to work through, plus all the additional testing and bench marking.  Look at the link below and also look for any past settled lawsuits as some can change the daily amount allowed.  

 

https://oehha.ca.gov...s-nsrls-maximum

 

In your conversion take the PPM (mg/kg) and just convert to PPB (µg/kg).  Our lab results came back already in µg/kg so I was doing a reverse conversion as the settled lawsuit for cacao % correlation for Pb & Cd was in PPM.  

 

Happy to share any additional information if needed.  

[kconf]

Thanks Wilson for the info. I am fine converting ppm to ppb and mg/kg to mcg/kg. 

Could you please share the CA limits for Pb and Cd (in ppm/ppb or mg/kg/mcg/kg)? We are a chocolate manufacturer. This would solve my problem. 

[nwilson]

Here is some light reading for you.  Second link has a table of allowable Pb & Cd per cacao %.  

 

July 2024 – GWU Study:  

https://www.frontier...24.1366231/full

 

https://cocoasupply....ments-in-cacao/

 

Happy confectioning!  

[kconf]

Just a quick question - 2nd link - 

What is the Connection Between California Prop 65 and Cadmium?

What are the two columns in ppm? I don't get it. 

[nwilson]

Just a quick question - 2nd link - 

What is the Connection Between California Prop 65 and Cadmium?

What are the two columns in ppm? I don't get it. 

CA Prop 65 designates the following for Cadmium.  

https://oehha.ca.gov...20madlfinal.pdf

This is their establish daily limit either orally or inhalation.  

 

The left hand column and levels when a warning label is required.  The right hand is if levels are below this no labeling is required.  It is a bit confusing with 2 different levels, however I am going off the right hand column as a general standard.  

[kconf]

This was very helpful. Thanks again!