For any unaware, California has a fun citizen’s initiative commonly referred to as “Proposition 65” or “Prop 65” – it’s the reason many consumer products have a warning that “this product contains chemical known to cause cancer in California” (or similar) which is generally followed by everyone thinking “good thing I’m not in California!” I’ll not get into the validity of the “No Significant Risk Levels” and “Maximum Allowable Dose Levels” established as part of Prop 65, they are what they are, and if a company sells something to a resident of California, a California resident (usually a lawyer) has the ability to sue if there is not a warning and the product contains levels of heavy metals or other contaminants higher than the levels established. I can say that the heavy metal levels in Proposition 65 are low enough that coffee shops have had to post warnings and Disneyland has warnings in their picnic area.

Keto Chow was served a notice that “Safe Products for Californians” intends to sue Keto Chow for not having warnings that Keto Chow contains heavy metals, specifically lead. The tactic being that many of the levels defined by Proposition 65 are so absurdly low that quite literally EVERYTHING has enough lead to qualify for needing a warning. Also, since Keto Chow contains protein, and the ‘cool’ thing to do these days is use plant protein which tends to be from China and contains a lot of heavy metals, logically Keto Chow will contain heavy metals (like Soylent™ does). The thing is: we don’t use plant protein, instead we only use protein created by sustainable mobile bioreactors (ruminants); in fact, very few of the ingredients come from plants and the animals don’t absorb heavy metals.

Due to the lawsuit, we paid for an independent lab to test for heavy metals in Keto Chow, the complaint was only for “Lead and Lead Compounds” but we went ahead and had Arsenic, Cadmium, Lead, and Mercury tested. The test has a minimum measurable level of 0.01 mg/kg of material, and each meal of Keto Chow is around 44-50g of powder. Here are the measured levels of heavy metals in Keto Chow, the serving size, and what your exposure is compared to the allowed levels with one caveat: the cadmium level is only established for inhalation, if you ingest it orally there is not established level.

Lead is interesting, Proposition 65 establishes a “No Significant Risk Levels” for causing cancer set at 0.015 mg or 15 micrograms per day. Lead also has a “Maximum Allowable Dose Levels” (MADL) for causing reproductive harm of 0.0005 mg or 0.5 micrograms per day. The MADL is set by looking at the level that no observable effect occurs and dividing that by 1000. In other words, if a toxin causes an effect at 10 units, the MADL would be defined at 0.01 units; meaning that the dose where lead will cause reproductive harm is 0.5 mg or 500 micrograms per day. I guess it’s surprising that many of the flavors of Keto Chow do NOT contain enough lead to require a warning label. Notably, the ones with the highest levels are those that contain spices or other plant-derived flavorings.

FlavorArsenic mg/kgCadmium mg/kgLead mg/kgMercury mg/kgServing Size (g)
Banana0.013< 0.010.011< 0.0144.434
Chicken Soup0.013< 0.010.011< 0.0145.449
Chocolate0.0150.0310.014< 0.0148.504
Chocolate Mint0.013< 0.010.013< 0.0146.104
Chocolate Toffee0.013< 0.010.012< 0.0146.541
Cookies & Cream0.014< 0.010.011< 0.0144.504
Egg Nog0.014< 0.010.013< 0.0146.039
Mocha0.0140.0230.023< 0.0148.099
Natural Strawberry0.013< 0.010.012< 0.0144.824
Orange Cream0.013< 0.010.012< 0.0146.541
Pumpkin Spice0.013< 0.010.013< 0.0146.679
Raspberry Cheesecake0.013< 0.010.013< 0.0146.454
Root Beer Float0.013< 0.010.013< 0.0146.542
Salted Caramel0.012< 0.01< 0.01< 0.0144.804
Snickerdoodle0.014< 0.010.026< 0.0146.069
Strawberry0.013< 0.01< 0.01< 0.0144.604
Vanilla0.010< 0.010.011< 0.0144.654

If you eat a meal of keto chow your exposure (as defined for cancer risk by Proposition 65) will be:

FlavorArsenic (mg)Cadmium (mg)Lead (mg)Mercury (mg)
Banana0.00058 mg – 5.8% risk exposureToo low to be measured0.00049 mg – 3.3% risk exposureToo low to be measured
Chicken Soup0.00059 mg – 5.9% risk exposureToo low to be measured0.00050 mg – 3.3% risk exposureToo low to be measured
Chocolate0.00073 mg – 7.3% risk exposure0.0015 mg – 36.7% risk exposure (if inhaled)0.00068 mg – 4.5% risk exposureToo low to be measured
Chocolate Mint0.00060 mg – 6.0% risk exposureToo low to be measured0.00060 mg – 4.0% risk exposureToo low to be measured
Chocolate Toffee0.00061 mg – 6.1% risk exposureToo low to be measured0.00056 mg – 3.7% risk exposureToo low to be measured
Cookies & Cream0.00062 mg – 6.2% risk exposureToo low to be measured0.00049 mg – 3.3% risk exposureToo low to be measured
Egg Nog0.00064 mg – 6.4% risk exposureToo low to be measured0.00060 mg – 4.0% risk exposureToo low to be measured
Mocha0.00067 mg – 6.7% risk exposure0.0011 mg – 27% risk exposure (if inhaled)0.00111 mg – 7.4% risk exposureToo low to be measured
Natural Strawberry0.00058 mg – 5.8% risk exposureToo low to be measured0.00054 mg – 3.6% risk exposureToo low to be measured
Orange Cream0.00061 mg – 6.1% risk exposureToo low to be measured0.00056 mg – 3.7% risk exposureToo low to be measured
Pumpkin Spice0.00061 mg – 6.1% risk exposureToo low to be measured0.00061 mg – 4.0% risk exposureToo low to be measured
Raspberry Cheesecake0.00060 mg – 6.0% risk exposureToo low to be measured0.00060 mg – 4.0% risk exposureToo low to be measured
Root Beer Float0.00061 mg – 6.1% risk exposureToo low to be measured0.00061 mg – 4.0% risk exposureToo low to be measured
Salted Caramel0.00054 mg – 5.4% risk exposureToo low to be measuredToo low to be measuredToo low to be measured
Snickerdoodle0.00064 mg – 6.4% risk exposureToo low to be measured0.00120 mg – 8.0% risk exposureToo low to be measured
Strawberry0.00058 mg – 5.8% risk exposureToo low to be measuredToo low to be measuredToo low to be measured
Vanilla0.00045 mg – 4.5% risk exposureToo low to be measuredToo low to be measuredToo low to be measured

Chocolate and Mocha both contain cocoa powder, a plant product, and both have the highest levels of heavy metals on the list; though the levels are still far below the very low bar set by Proposition 65 to necessitate a warning for cancer. The threshold for needing a “reproductive harm” warning is 0.00050 mg – as a precaution against future litigation we just went ahead and put the warning up for everything.