What do Prop 65 Warnings Really Mean for Supplements?

The Prop 65 warning is triggered by any chemical listed as hazardous to the state of California, such as lead, mercury and many other chemicals, even in miniscule levels. In fact, any ingredient that tests over 1/1000th of what the World Health Organization considers to be the “Safe Harbor Level” triggers a Prop 65 warning. Even naturally occurring minerals that food and herbs cannot be produced without, require this label.

For example, lead is present in our environment, including the air, soil, water, and agricultural products. However, the threshold for this warning is set much lower than the level associated with actual reproductive harm. The California Office of Environmental Health and Hazard Assessment (OEHHA) establishes the warning levels, first by identifying a level of exposure that has been proven not to pose any harm to humans or lab animals, and then adding a significant margin of safety. This "no observable effect level" (NOEL) is divided by 1,000 to determine the margin of safety. Consequently, companies must issue a warning if exposure exceeds 1/1000th of the NOEL. Since elements like lead are widespread in nature and soil, leading to its presence in many foods and botanical products, virtually no supplement can be produced without this Prop 65 warning.

How does the Prop 65 lead level of 0.5 mcg compare to other sources of lead?

Prop 65 mandates warnings for products sold in California that contain over 0.5 microgram (mcg) of lead per maximum daily usage. This level can be compared with other average daily environmental exposures to lead:

• Air: 4.0 mcg/day
• Water: 5.0 mcg/day
• Food: 20 – 90 mcg/day

According to World Health Organization estimates, the following food items contain levels higher than those requiring a Prop 65 warning: 

The Dr. Clark Store / Self Health Resource Center Guarantee

Dr. Clark Store conducts the most strenuous tests for identity, purity and potency, guaranteeing that our products are the safest on the market. While the FDA has changed the rules, allowing up to 3% of ingredients to not even be labeled (some of which pose far more serious risks to human health than the substances on the Prop 65 list, such as carageenan, magnesium stearate, and calcium carbonate), we guarantee total transparency, list every ingredient, additive, or flow agent on our products, even if not required.

Our products are tested for heavy metals, and other dangeorous chemicals more routinely than is required, and we maintain vigilent oversight of product quality. Dr. Clark was adamant that her supplements be pure, and had issues with the FDA-approved capsule ingredients, like carrageenan, and many others.