Questions and Answers About Fermented Cod Liver Oil (FCLO)

The following questions and answers were prepared by Sally Fallon Morell, President of the Weston A. Price Foundation (WAPF), in response to inquiries from Foundation members and others following the recent circulation of a report by Kaayla Daniel, PhD, CNN, which raises issues about the safety and quality of FCLO [].  Dr. Daniel is a board member of WAPF, but her report was not authorized by the Foundation’s board, nor did the board see it before it was circulated. Dr.Daniel raised the concerns about FCLO contained in her report to the WAPF board last year, at which time the board investigated and concluded her concerns, with only Dr. Daniel dissenting, were unfounded [].

What is your own use of Green Pasture products?
I was introduced to the Green Pasture butter oil when it first came out in about 2003.  At that time, I was concerned that I was developing arthritis—this runs in my family, and when I woke up in the morning, my hands would be very achy and stiff.  One week on the butter oil and this condition completely disappeared.  Naturally I was thrilled and happy to recommend this product to our membership.  Green Pasture soon began selling a cod liver oil from Norway, which I began to take also.  I felt good on it but it did not clear up the night vision problems I was having—I was afraid I would no longer be able to drive at night.  When Green Pasture came out with the fermented cod liver oil, I switched to that and my night vision problems also cleared up completely.  Also, I found I could adjust to bright light much easier.  These two conditions are important indicators of vitamin A status, so for me, the vitamin A in the fermented cod liver oil has worked better than the vitamin A in other cod liver oils.

I take both products every day, without fail (mixed in warm water).  My husband takes the fermented skate liver oil, my daughter and daughter-in-law took fermented cod liver oil during pregnancy, and my grandsons get it every day.  The proof is in the pudding, in the wonderful health of these three boys.

We also use the cod liver oil lick tubs for the cows on our farm and they love it! They are very healthy and have good reproductive health.

Do you personally or the WAPF receive any compensation from Green Pastures for an endorsement or sale of product?
WAPF received $20,000 from Green Pasture in 2014 in sponsorship fees for exhibiting at our conferences, plus $360 for an ad and $250 for a membership, for a total of $20,610, about 1.1 percent of our yearly budget.

This income from Green Pasture has nothing to do with our endorsement of its products, and WAPF clearly does not need the company’s money.  We endorsed these products before Green Pasture became a sponsoring exhibitor.  Our rule is that we do not allow anyone to exhibit unless they have a product we approve of.  (By the same token, we do not allow any of our exhibitors to criticize another approved product.  If they have concerns, they need to bring them to us to look into.  They should sell their products by emphasizing their good features. Exhibitors who market their products by criticizing competing products will be asked to leave and will not be invited back.)

I do not receive any compensation from Green Pasture. My husband and I do sell its FCLO and other products in our farm store (, along with other healthy products that we believe in. Gross profit from sales of Green Pasture products probably does not exceed $1,000 per year. All the Green Pasture products for my personal use and farm store sales are purchased directly from Green Pastures; my only discount is for buying by the case.

Why do you recommend what the report calls a“stinky” product?
Of all the accusations against fermented cod liver oil, this one is the most difficult to comprehend.  Anyone who takes a whiff of fermented cod liver oil knows that it is not stinky.  I keep my fermented cod liver oil at room temperature, and even when I get to the end of the bottle, after it has been opened several weeks, it still smells just slightly fishy.  This smell comes from residual fish proteins in the oil, not the oil itself. All cod liver oil smells like this. If it had gone rancid, it would have a varnish-like smell.

Why did you send the fermented cod liver oil to the UK to be tested last year?
When Dr. Daniel first emailed me about her concerns, I immediately contacted Nina Teicholtz, author of The Big Fat Surprise.  This book has a chapter on rancidity in vegetable oils (which we reprinted in Wise Traditions, the link is here:  Since Ms. Teicholz had written on this subject so recently, I figured she would be the best person to know who is the leader in this field.  She recommended Dr. Martin Grootveld, BSc, PhD, FIBMS, CBiol, FSB, FRSC, Leicester School of Pharmacy, Faculty of Health and Life Sciences, De Montfort University, Leicester, UK. His credentials are very impressive and include Fellow of the Royal Statistical Society,Professor of Bioanalytical Chemistry and Chemical Pathology, Chair of the Faculty of Health and Life Sciences Research Ethics Committee, Head of Medicinal Chemistry Group, Director of Bioanalysis, Pharmaceuticals and Health Doctoral Training Programme (DTP), and Member of the Editorial Boards of Bio Analytical Techniques and International Journal of Medical and Clinical Research.

Because of the urgency of this issue, I over-nighted an unopened bottle of fermented cod liver oil that had been in my cupboard; the results are posted here:  Dr. Grootveld found no rancidity in the fermented cod liver oil.

One thing I discovered during the conversations I had at that time was that there is disagreement in the scientific field on how to test for rancidity in oils.  The industry tests for peroxides such as PV, PA and TBARS.  But Dr. Grootveld and others held that these were not good tests for rancidity; instead they test for aldehydes.  For one thing, the peroxide markers rise over time and then fall, so you have to test many days in a row to get any kind of idea what’s going on.  Obviously, we have a lot more to learn about all this.  Dr. Daniel wanted the Foundation to spend a lot of money sending cod liver oil samples to labs that tested for these things, but the Board felt that the funds were better spent on vitamin testing, and anyway, Green Pasture had already provided certified lab reports showing that the peroxide markers were low.  Obviously we are now going to do more testing, but we want to make sure that we are testing for the right things.  We are currently looking for a U.S. lab to do this.

This is Dr. Grootveld’s opinion on the TBARS test, which he described as “analytical garbage.”

”It should be noted that the TBARS test commonly employed for determinations of lipid oxidation product (LOP) aldehydes in foods, and culinary or health-promoting oil products (and accordingly not just MDA), are completely unreliable and serve little or no value for the estimation of these species. Indeed, we are, of course, already aware of the induction of the lipid peroxidation process at standard frying temperatures, and since this test requires the heating of biofluids or tissue sample extracts with TBA for periods of ca. 15 min., this is more than sufficient to induce the peroxidation of PUFAs therein, and hence all results derivable from this heat-dependent test system represent nothing more than artifactual data. Indeed, our H1 NMR experiments have clearly proven the thermally-induced oxidation of PUFAs in commercial oil formulations to CHPDs and aldehydic LOPs at Pasteurisation temperature (72oC), in addition to 95oC, the latter for only a 15 minute period.  If, however, this method involves a prolonged equilibration at ambient temperature (or 25oC), and the TBA-MDA (and other) chromophores are then allowed to develop slowly (perhaps for 72 hr. or more), then this test system does have the potential to monitor aldehydic LOPs, but not exclusively MDA since a wide range of aldehydes (including á,â-unsaturated ones) react with TBA to generate the same chromophores, or similar interfering adducts. Moreover, further caution should always be employed since it is known that a series of further biomolecules, especially reducing sugars (if present in food matrices for analysis), also react with TBA to form chromophores which also absorb at 532 nm.”.

But why do some people say that fermented cod liver oil is rancid?
As Chris Masterjohn, PhD, an assistant professor of Health and Nutrition Sciences at Brooklyn College, City University of New York, and a frequent contributor to Wise Traditions has pointed out, a lot of the discussion on rancidity is a question of semantics. “Chemical changes of several types contribute to what is known by the generic term rancidity. In its broadest meaning, rancidity denotes a deterioration of flavour and odour of fat or the fatty portions of foods. Such deterioration can be due to hydrolysis, oxidation, or to microbial action. The term rancidity is used in the dairy field to indicate hydrolytic deterioration; in other fields it denotes microbial deterioration, and to the fat chemist it means autoxidation.” — Ralph Holman, Autoxidation of Fats and Related Substances, 1954

According to Dr. Masterjohn, “An entire section of Dr. Daniel’s report deals with the practically meaningless semantic precision around the word ‘fermentation,’ yet she does not even allude to the very practically important and very different meanings of the word ‘rancidity.’

“To a food scientist whose aim is a palatable product, the FCLO is ‘rancid.’ To a lipid chemist, it is not. Which matters? To someone who doesn’t mind the taste and wants to be healthy, only the lipid chemist’s meaning is important; just because something doesn’t taste good doesn’t mean it’s going to harm you.  It is the autoxidation that produces toxic substances,and just because something is fermented does not mean it contains autoxidation products.”

Another point by Dr. Masterjohn: “If the polyunsaturated fatty acids had peroxidized and fragmented, they wouldn’t still be in the oil. Yet the total EPA and DHA in the oil seems normal for cod liver oil at about 1 g/tsp. That these are present and not destroyed is evidence against a history of lipid peroxidation within the oil.”

What about free fatty acids? Dr. Daniel claims that high levels of free fatty acids mean that fermented cod liver oil is rancid.
Dr. Daniel is expressing a view put forth by a number of companies in the cod liver oil industry. The process used by most companies in the industry removes all the free fatty acids from an oil in the refining process and then claims that the absence of free fatty acids is a sign that the oil is not rancid. But two lipid scientists (Dr. Fred Kummerow and Dr. Martin Grootveld) assured me that free fatty acids are not a sign of rancidity.

Most or even all unprocessed oils contain free fatty acids, which are just fat molecules not attached to a triglyceride.  When we digest our food, we break down the triglycerides into free fatty acids, so they can’t be bad for us! Because fermentation is a kind of pre-digestion, one would expect a lot of free fatty acids in fermented cod liver oil.  Green Pasture has been very open about the high levels of free fatty acids in fermented cod liver oil. If an oil has no or low levels of free fatty acids, it is a sign that it has been processed.

What about the accusation that fermented cod liver oil isn’t even made from cod, but pollock?
Alaskan Pollock IS a species of cod, considered very close to the Atlantic cod.  Lots of cod liver oil processors use Alaskan pollock. Green Pasture uses mostly Pacific cod but also some Alaskan pollock, taken from Alaskan waters, depending on availability. It is standard practice for cod liver oil manufacturers to use many different varieties of cod and even other fish. They are not required to list the individual varieties on the label.

“One member of the genus Gadus [cod family] is also commonly referred to as pollock. This is the Alaska pollock or walleye pollock (Theragrachalcogramma) including the form known as the Norwegian pollock. . . .  The Alaska pollock is a significant part of the commercial fishery in the Gulf of Alaska” (C.Michael Hogan. 2011.Gulf of Alaska. Topic ed. P.Saundry. Ed.-in-chief C.J.Cleveland. Encyclopedia of Earth. National council for Science and the Environment).  Alaskan Pollock has recently been renamed gaduschalcogrammus.

What about claims that there can be no such thing as a fermented oil, or that you cannot ferment livers?
The oil is not fermented but it is a product of fermenting the livers. You can indeed ferment livers—fermentation experts will tell you this.  The glycogen stores in the liver are what ferments—and there is plenty of glycogen in liver.  The oil from this is called fermented cod liver oil because it comes from fermented cod livers.  Regular cod liver oil is oil from unfermented cod livers.

Why does Green Pasture claim that there is vitamin D2 in fermented cod liver oil? Everybody knows that there is only D3 in cod liver oil.
This is the industry view.  Most industrial (refined) cod liver oil today has vitamin D3 added because refining takes most of the natural vitamin D out.

When David Wetzel, the owner of Green Pasture, first began making the fermented cod liver oil, he sent it to NDI laboratories in Canada ( (associated with Guelph University) for vitamin D testing.  He was surprised when these tests came back showing vitamin D2, with very little or no D3. Mr. Wetzel immediately communicated this to us.  He then sent the oil to the University of Wisconsin for a rat assay test to see whether the oil had vitamin D activity—and the answer came back yes.  Mr. Wetzel has shared all this on his website []. The rat assay is considered the gold standard of vitamin D testing. The University of Wisconsin then recommended UBE Laboratories in Fullerton, California for further testing, and these labs found mostly vitamin D2 as well.

The prevailing view at that time—one that we repeated at WAPF—was that vitamin D2 is ineffective and possibly toxic.  Of course, these discoveries led us to reconsider this view—after all, cod liver oil cures rickets.  This is something we are looking into further and will be sharing with our members in Wise Traditions. There are hundreds of vitamin D metabolites, so the probable explanation is that the natural D2 metabolites in cod liver oil have different effects from the synthetic D2 added to vegetarian foods, used in vitamin drops, etc.  We encourage product manufacturers like Mr. Wetzel to share information like this to help advance knowledge about nutrition.

By the way, Dr. Masterjohn is of the opinion that the forms of D in cod liver oil are not D2, but other metabolites. We hope to solve this mystery with further research.

Why doesn’t fermented cod liver oil raise the vitamin D levels in the blood?
Some people have reported this, but the physician Roseann Volmart, DO, reports that small doses of fermented cod liver oil have very effectively raised vitamin D levels in many of her patients.  Obviously the product does not have the same effect on all people.  Again, this is an interesting question and one that we hope to look into.  Remember that all vitamins need co-factors to be effective, and one explanation is that the people for whom fermented cod liver oil is not raising serum D levels may be missing certain co-factors.  Also, the current thinking is that serum levels should be in the range of 30-40; higher levels may not be healthy.

Dr. Daniel reports that all vitamin levels in cod liver oil are low.
The first thing people have to understand about vitamin testing is that it is not an exact science, especially when the vitamins are naturally occurring. Using the same tests, different labs can get different results, and even two different technicians in the same lab can get different results. And testing for fat-soluble vitamins is even more complicated because these vitamins are mostly attached to proteins or other compounds.  If the lab does not go through processes to release the vitamins, then the results will be low.  UBE Labs says that they do a very thorough job of releasing or extracting the vitamin D, and that is why they get high results.  Unfortunately, they will not share their methodology with us, so we (WAPF) have not published any of their results in our journal. What we are planning to do is provide funding so that Chris Masterjohn can do this testing in his laboratory at Brooklyn College, so we can study this question thoroughly.

The question of how much vitamin D is in our food is an important one.  The conventional dogma is that “you can’t get vitamin D from food.” I believe that USDA is using tests that give deliberately low results, so people will not realize the health value of foods like butter, egg yolks and lard.

For example, USDA claims there is 100 IU vitamin D in 100 grams of lard.  But Mary Enig, PhD was in contact with someone from USDA years ago who found 2800 IU vitamin D in lard.

At my own expense (not funded by WAPF) I sent some samples to UBE labs and received these startling results:

 Vitamin D
IU per  100 Grams
 Current USDA Values  Old USDA Values  UBE Lab Confinement Raised  UBE Lab Pasture Raised
Egg Yolks  129  148  9240  70000
Lard  100  2800  6040  75,000
Butter  64  56 1880  6,560


The Foundation has not published these results because we don’t know the methods UBE is using. We expect to have publishable results from Dr. Masterjohn’s studies.

For other fat-soluble vitamins like A and K, the situation is similar.  We are not going to send products to labs that don’t do a thorough extraction process before testing.

What about all those lab reports in Dr. Daniel’s report?
To be a valid legal document, or to constitute substantiation for a nutrition claim on a food or supplement label, or to be sufficiently credible for WAPF to publish it, a lab report must show the name and address of the lab, the name and contact information of the person requesting the analysis, the date, the name of the product, the type of test used and the name of the person responsible for the test. None of this information is disclosed in the reports that Dr. Daniel has relied on in her report.  Therefore, we have no way of evaluating the reliability or relevance of those reports.

Should everyone take Green Pasture fermented cod liver oil?
Of course not! There is no one product for everybody. If someone doesn’t like the fermented cod liver oil, there are other recommended brands. They can choose cod liver oil products endorsed by WAPF (

Should every one take cod liver oil?
Again the answer is no.  Some people are very sensitive to the polyunsaturated fatty acids in cod liver oil; others are allergic to all fish products, or sensitive to iodine or to fermented foods.  These individuals will need to get their fat-soluble vitamins from other foods.

Is it OK to take cod liver oil while eating a standard American Diet?
Certainly not in large amounts.  The unsaturated omega-3 fatty acids in cod liver oil need to be balanced by saturated fats and especially omega-6 arachidonic acid in animal fats.  The diet needs sources of easily absorbed calcium and plentiful magnesium.  Above all, the A and D in cod liver oil need to be balanced by vitamin K2, found in aged cheeses, duck and goose fat, butter, butter oil and other animal fats.

According to Dr. Masterjohn: “If someone’s weakness is a propensity to oxidative stress, cod liver oil might be an oxidative liability and harmful. If someone’s weakness is a deficiency of one of the cooperative nutrients, it could cause an imbalance. But for many, their weakness may be that they need more A and D, and they might benefit. That might explain why it was usually associated with positive outcomes in clinical trials even though the background diets were likely subpar.”

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.

Doesn’t WAPF recommend high doses of cod liver oil?
The WAPF recommendation is 1 teaspoon per day high vitamin cod liver oil for a maintenance dose; 2 teaspoons per day for pregnant and lactating women; and higher doses for a short time during periods of stress ( We have also reported on a South African study in which women with endometriosis had a 92 percent cure rate when given high doses (up to 90,000 IU) of vitamin A daily (D M Lithgow and W M Politzer, “Vitamin A in the Treatment of Menorrhagia,” South African Medical Journal, February 12, 1997, Pages 191-193).. WAPF board member Kim Schuette, CN, reports great success with 1 tablespoon 2-3 times daily for 30-60 days in cases of endometriosis. (But after 60 days, they go back to one-half to a full teaspoon.)

Personally I take 1 teaspoon per day and a second teaspoon in the afternoon when I have a lot of stress or during the pollen season (for me FCLO works like nothing else to alleviate pollen allergies.)  I have never taken cod liver oil in tablespoons.  I do often tell people that increasing the cod liver oil temporarily can help with stress.

What about Dr. Daniel’s claim that the X Factor is not vitamin K2?
Here is Dr. Masterjohn’s article on this subject; readers will have to decide for themselves:

Green Pasture has a monopoly and this is not good.
Green Pasture has been successful because they produce a good product.  But there are plenty of customers for other brands.  The role of WAPF is to explain why people should take cod liver oil and point people to products that are natural and clean.

We will need many more companies producing a natural and/or fermented cod liver oil to meet the coming demand.  Presumably Green Pasture is not going to share its proprietary processing techniques, but it would be easy to figure out how to do this.  One good possibility is natural processing of the fresh water cod livers from the Great Lakes.

Dr. Daniel accuses Green Pasture of getting its fish livers from Alaska and its butter oil from Argentina without disclosing this fact.
Green Pasture has not advertised the source of its products but has not hidden it either.  It is a business and may not want to jeopardize its sources of supply.  The company says it has obtained its livers from Alaskan waters since the beginning.  When the company could not get enough butter for butter oil domestically, it set up a supply from a dedicated grass-fed herd in Argentina, where there is plenty of good pasture.

Who paid for all the lab tests relied on in Dr. Daniel’s report?
In her report she acknowledges “Dr. Ron Schmid. . .  and several other loyal members of the Weston A. Price Foundation [who] helped fund my laboratory testing.” I do note that the language in her report often expresses the view of the conventional (refined) cod liver oil industry.

Why would companies that make refined cod liver oil attack fermented cod liver oil?
David Wetzel has reported that when he went to Norway years ago he made a shocking discovery—that essentially all the modern processed cod liver oil today has had most of the vitamins removed by the molecular distillation process and synthetic vitamins are added back.  He made this information public, which cannot have helped the industry, and went on to develop a traditional fermented cod liver oil. It is not heat processed and contains natural vitamins, which is why WAPF has endorsed it.

Comparing processed cod liver oil to fermented or unrefined cod liver oil is like comparing pasteurized milk to raw milk—they are completely different products.  The dairy industry has spread some terrible misinformation about raw milk, and it may be that this is what the cod liver oil processing industry is doing to fermented cod liver oil.  To be fair, based on their training, these companies may honestly believe that because an oil is brown, it has to be putrid and rancid. People trained 20-30 years ago may know nothing about fermentation.

Why are you claiming that Weston Price used fermented cod liver oil?
We did not make that claim.  Dr. Price probably used cod liver oil processed by steam extraction, which was the method in use at the time.  He described the cod liver oil he used as “high vitamin,” and he probably determined vitamin levels in his own laboratory using methods available at the time.  All the tests we have seen indicate that fermented cod liver oil is higher in vitamins than other brands so it seems to us appropriate to recommend it.

What is your testing process for a product to garner endorsement?
We have never tested products for endorsement, only looked at the ingredient list to see whether they fit into our guidelines.  However, for the important product of cod liver oil, because of this controversy, I will now be recommending to the board that we develop a protocol for testing all brands for vitamin levels and markers of rancidity before we approve them.

Do you stand by Dr. Daniel’s other writings for the WAPF? What about The Whole Soy Story and Nourishing Broth?
Dr. Daniel did great work on these books and her articles—more thorough than the cod liver oil report.

What is your greatest concern about Dr. Daniel’s report?
My biggest concern is that the report is clearly aimed at putting Green Pasture out of business and taking this wonderful product away from the thousands of people who have benefited from it, including myself and members of my own family.  This would be a terrible thing to happen.

Further good information from Chris Masterjohn, PhD is here
Wise Traditions 2015, the nation’s foremost nutrition conference
November 13-16, Anaheim, California

Sally Fallon Morell is the founding president of the Weston A. Price Foundation and founder of A Campaign for Real Milk. She is the author of the best-selling cookbook, Nourishing Traditions (with Mary G. Enig, PhD) and the Nourishing Traditions Book of Baby & Child Care (with Thomas S. Cowan, MD). She is also the author of Nourishing Broth (with Kaayla T. Daniel, PhD, CCN).

81 Responses to Questions and Answers About Fermented Cod Liver Oil (FCLO)

  1. Victor says:

    Great job. So glad to that you guys got this published so quickly. I will include a link to this in all my future activism on the issue. No doubt that it will take a while for many to find this. Not that my opinion matters, but I have been posting very similar comments on my blogs, and others, to try to clarify the confusion caused by Dr. Daniel’s report. I think this Q&A style is a nice way to approach the issue, as it is easier for most people to digest.

    I hope that more people will come to appreciate Dave Wetzel and his products at Green Pasture.

  2. Now that dr. Daniel has begun this discussion, I think we should change the focus of the conversation while the arguments about whether her data/claims are valid.

    Whether, or not, the oil is truly fermented and/or rancid is certainly an important question. However, a more immediate question would be why are we convinced that fermenting the oil has made it a superior product? How has this claim been substantiated? Is it simply the notion that all things fermented are better for us?

    It now seems that Green Pastures invented the product called fermented cod liver oil. Fermenting cod livers prior to extracting the oil for human consumption has not been a staple of any nutritional paradigm before.
    Therefore, other than anecdotal data from persons who produce/sell the product, how is it that we know anything about the following:
    1. The safety of taking fermented clo long-term
    2. Are there contradinications to taking fermented clo
    3. Is there TRULY any benefit to taking fermented clo over conventional, high quality Clo?
    Before I continue to recommend fermented clo to my patients, I need these questions answered. Otherwise I am just a sheep following the herb without ever picking up my head to ask where are we going and why?

    • Victor says:

      Fermented Cod Liver Oil is an ancient process, being found in various cultures, such as the vikings. You can find this history if you search hard enough.

      For me, my own searches on modern day people using the Green Pasture FCLO were enough to convince me, and my own experiences have been spectacular. Everyone is different of course, but you can find countless detailed accounts, photographic evidence, etc., of the positive health effects of this product.

      One of the greatest benefits of the Green Pasture FCLO is that it maintains the complex natural nutritional profile of the CLO. If fermentation is nothing more than the method used to extract the CLO, it is superior, as the entire CLO market has moved to industrialized processes that degrade the CLO during extraction and processing. The CLO products are then infused with synthetic vitamins to try to mimic the original profile. FCLO has no synthetic vitamins. Green Pasture is protecting us from the large CLO manufacturers by processing the livers himself, through fermentation.

      In addition to the fermentation being a process that extracts the oil without degrading the nutritional profile of the oil, it does also seem to enhance it by imbuing it with a biodynamic nature. This product is (arguably) gaining potency over time. I am not an expert, and even the experts are not sure, but the proof is in the pudding: this product is has amazing health benefits for some people.

      For me, the gold standard in testing is healing a cavity, and the Green Pasture FCLO and Butter Oil combo works like magic for me.

      It is certainly not for everyone, but it is a powerful tool to have in your toolkit.

      • Fermented CLO is NOT a traditional practice. Putrification extraction IS a traditional practice. If you look at the “historical” examples given, they are ALL of putrifaction, where the livers were simply packed in a barrel to rot, or otherwise packaged to rot.

        Indeed, one process of putrifaction Wetzel describes on his website was used for Machine Oil, and Lighting, not for human consumption, yet he uses this as an example of “traditional fermentation of fish liver oil”.

        • You are greatly overestimating our ability to know the entirety of history. You cannot speak in absolutes, as there is far more historical knowledge that has been lost than known. We will forever be rediscovering such lost history, and Green Pasture has already posted some new sources that prove this point. Keep your eye on their website if you want to know more.

          There are certainly traditional fermented CLO practices, and more than we will ever know. Do not be fooled into thinking that ‘google’ can provide you with the answers, as it will never even scratch the surface of what was known, and what is yet to be known.

          As Dr. Weston A. Price showed us, the wisdom of our ancestors is vast. His efforts did not represent the summation of such – but rather were meant to open your eyes to the vastness of such.

          • Shira Nahari says:

            Unbeknownst to many, “Google” censures search results, and we are not allowed to see politically commercially, socially, etc. “incorrect” information.
            If you will use “www.ixquick” for searches you may have better luck. It is also the most private browsing site I know. Check it out to see why and how.

    • Desiree says:

      I am just responding to your mention of “Fermenting cod livers prior to extracting the oil for human consumption has not been a staple of any nutritional paradigm before.”
      North pacific Indegenous tribes fermented/rotted eulachon fish before they extracted the oils, how is this any different than doing the same with the fish livers? The ancients of these civilizations experienced no tooth decay and amazing health, their children however eating modern foods of commerce did not experience the same great health…this is noted in Dr. Prices book Nutrition and Physical Degeneration. Health is achieved on many levels, you cannot be healthy if you only take a supplement, all food choices in combination with the oil can make or break your health.
      Eulachon oil was a staple for these people, it was their butter, and was also used to preserve food, used for digestive ailments, skin conditions…it was liquid gold to them and history has documented the grease trails of its trade. It was a very desired item and increased ones status. My grandfather’s tribe the Tlinglet made this much coveted oil.

    • Carolyn Graff says:

      This article talks about the history of fermenting fish livers

    • Jill says:

      David, I think some of your questions and concerns might be answered in this more detailed post by Dr. Chris Masterjohn:

    • Diana says:

      Well, I guess it depends which herb you are following?

      Personally, I like parsley, but some people can’t chew it. I dislike basil, but I guess if I loved pesto, I would feel differently.

      I’m not sure about oregano, though?


      Serious reply:

      I do not produce or sell FCLO, but I have been taking it — when I can afford it — for several years. One thing I noticed — when I’m taking it, I never get sick.

      When I’m not taking it, because I can’t afford it —– I am lucky if I can get through a few months of Wisconsin winter feeling like myself. I.e.., I am sick a lot.

      I finally decided I can’t afford to be without it.

      I am on a fixed income.

  3. Robby Huang says:

    Is 1 teaspoon the recommended amount per day for fermented cod liver oil? The serving size on the Green Pastures bottle is 2 ml, which is less than a 1/2 teaspoon. Just wanted to make sure that that is correct. Thanks!

    • Carolyn Graff says:

      That is the recommended amount according to this article

      The article also says this:
      Please note that the fermented cod liver oil contains many co-factors that may enhance the body’s uptake and usage of vitamins A and D; in fact, many have reported results equivalent to those obtained from high-vitamin cod liver oil with half the recommended dose, that is ¼ teaspoon or 1.25 mL for children age 3 months to 12 years; ½ teaspoon or 5 capsules for children over 12 years and adults; and 1 teaspoon or 10 capsules for pregnant and nursing women.

  4. Justin Roy Olson says:


  5. Amanda says:

    Awesome response, Sally!

    Kaayla Daniel is a disgrace to WAPF and I sincerely hope that she is removed from the Board of Directors after this embarrassing stunt.

    • Lee says:

      So you think that Dr Daniel had ulterior motives? Do you have proof or are you jumping to conclusions too?

      BTW, I have bought 8 bottles since this because I am convinced of the health benefits but I do think a lot of good will be forthcoming as a result of Dr Daniels ‘ report (perhaps studies that ought to have already been conducted). Perhaps there is room for improving the process?


  6. J Smith says:

    One thing I’ve not heard mentioned is where the samples were purchased? GP sells to other vendors for resale. No one has brought up the possibility of a vendor mixing/diluting the product. I’ve bought from more than one vendor and found the product to be different in consistency and taste. . . more than I was comfortable with. I asked a few questions and got no response, but lacked the resources to find a lab to test on my own. If you’re going to be doing some more tests, you might consider buying from some of the vendors anonymously to include in your tests. I know the concept might be offensive to many parties, but the subject needs to be raised. It’s possible for more than one side to be right.
    Ps. Thank you for the followup and all of your hard work. Please know that it is MUCH appreciated.

    • Victor says:

      That is a valid question J, but it seems unlikely, as Dave Wetzel at Green Pasture explains that his products do in fact have quite a bit of variability in content, and this is due to the fact that he avoids any attempt to alter the product with additional processing just to even out the taste. Think of it as buying apples instead of buying apple juice. The juice will always be consistent from the large manufacturers, while individual apples vary significantly in taste.

      It is explained that this is due to the bioactive nature of the product, and the natural processing. He warns that indeed, some batches may give a bad taste, burning sensation in the throat, etc., while others will do nothing. Again this also depends on the individual. I and my family notice this variability all the time, and we order direct from Green Pasture. I’m no expert, but that is my experience and that is what I have read on the Green Pasture website and elsewhere.

      • James says:

        Thank you. I understand what your saying about GP’s handling of the product, but it does not address why you think it’s unlikely for a vendor to do so. My response and reasoning had little to do with Dave, except for the difference in texture that I found ordering from multiple vendors. It still leaves the question open as to how many samples were used by Daniel and where were they obtained, does it not? Any further investigation(ie. testing) should at least ‘consider’ using multiple samples from multiple vendors anonymously.

        • julielu says:

          If the product was a standardised product with an accurate nutritional panel on its label you would not be having this concern or any conjecture [as unlikely as it may be] over such variation.

          The texture etc is due to its ‘natural’ variability due to its very nature as a ‘food’. It therefore does not need to take into account that such variability may result in nutritional variability also.

          In fact you cannot be sure at all what you are getting at any time in any batch or bottle, except that which IS stated on the label. No nutritional info, means you cannot impute that it contains what you are hoping for .

          I hope you were not seriously suggesting that the product container is not tamper proof also.

  7. Michele says:

    do you still recommend the product for babies / young children?

    • Carolyn Graff says:


      The high-vitamin fermented cod liver oil is sold as a food so does not contain vitamin levels on the label. However, after numerous tests, the approximate values of A and D have been ascertained at 1900 IU vitamin A per mL and 390 IU vitamin D per mL. Thus 1 teaspoon of high-vitamin fermented cod liver oil contains 9500 IU vitamin A and 1950 IU vitamin D, a ratio of about 5:1.

      Based on these values, the dosage for the high-vitamin fermented cod liver oil is provided as follows:

      Children age 3 months to 12 years: 1/2 teaspoon or 2.5 mL, providing 4650 IU vitamin A and 975 IU vitamin D.
      Children over 12 years and adults: 1 teaspoon or 10 capsules, providing 9500 IU vitamin A and 1950 IU vitamin D.
      Pregnant and nursing women: 2 teaspoons or 20 capsules, providing 19,000 IU vitamin A and 3900 IU vitamin D.

      • julielu says:

        As a “food”, its active ingredients are not “standardised” and it “does not contain vitamin levels on the label.”. I do not understand how WAPF and its reps suggest or publish such estimations as posted above [C Graff] based upon unofficial tests of the nutritional values that the product MAY contain in any given random [?] product.

        It is questionable that the reason that a nutrient panel is not provided on the label is because it is “sold as a food”. Many manufactured food products have nutritional labelling. The difference is in making that information official: providing a legally binding statement that has, at its basis, obligations to the consumer. In not undertaking such proof of content that the consumer can readily access, how can a consumer be confident of such nutritional /medical dosage advice as stated above?

        I would not wish to rely on this information, [that i may be getting an approx. vitamin value in the dosage suggested] and especially since it is issued without warning as to possible toxicity should values be exceeded.

        In my view the statement issued has not thoroughly addressed the questions surrounding the legitimacy of this product. The reason it seems that a renegade board member has stood up to force a long overdue response.

        • Shira Nahari says:

          For me personally the Gold Standard is my own personal experience: whatever works. If i find that a product or supplement helps, strengthens, cures and/or has benefits I don’t care a rat’s ass what anyone says or writes about it.
          I took Green Pastures HV CLO regularly until a recent extended trip. I was very ill most of the 3 months. Needless to say I hurried to get back with the program when I returned home!

  8. Heather W. says:

    Thank you for this. I love FCLO, and ever since I started taking it, I have not caught the cold or the flu, before FCLO, I was sick at least twice a month, sometimes for weeks at a time. I love the work that you guys do and I hope for the best for Green Pastures and Mr. Wetzel, and I hope that they never go out of business because I am a customer for life.

  9. Community members have followed up and expressed concern that the issue of trans fat was not mentioned, nor the reason why Dr. Ron will no longer be an exhibitor at the conferences?

    Sally said I could publish her response to me in full:

    I just forgot about the trans fats but Chris Masterjohn addresses this subject very well at We all know that Dave is not adding vegetable oil to the fclo. (he doesn’t use canned livers either, as someone has implied.)

    I cannot comment on whether she will remain on the board; this will be a board decision

    Ron was removed because he did not take down his statement saying that fermented cod liver oil caused his heart attack. I explained to him that we don’t allow exhibitors to attack other approved products, only to talk about the good things in their products, and that if someone were criticizing one of his products, we would not let them exhibit. He then emailed me saying he was not going to take it down, so I told him we would send him his deposit back.

    Our conferences would be very acrimonous if the exhibitors were making all these wild claims about competitors–truly would create a negative atmosphere. Corganics tried this a couple of years ago with a pamphlet saying that fermented cod liver oil was putrid and rancid–when clearly it is not. I told them that if they wanted to exhibit at Wise Traditions (and advertise in the journal), they could not do this. Since then they have complied.

    By the way, no one has asked me what it was that convinced me to put Rosita in the Best category. I asked Corganics to send a sample to UBE laboratories and the results that came back convinced me that the vitamins were natural. I cannot share this report because it belongs to them, but someone should ask them to reveal what was found. It was quite surprising and could be used as a selling point for their oil.

    There are enough customers for cod liver oil to support many different types and brands. All these accusations are inappropriate and so negative. Apparently there has been a whispering campaign for several years. This is not good for anyone, and certainly undermines the credibility of the Foundation.

  10. Michelle says:

    Thank you for addressing many concerns. This controversy has certainly made me more aware of how little is known about our foods and that nutrition testing is not as simple as just sending a sample to a lab. However, I was hoping you would also address the accusation of trans fats in the sample.

    • Carolyn Graff says:

      from a previous comment: Chris Masterjohn addresses this subject very well at

    • I see some people with additional concerns about trans fats, and some fear mongering on other blogs, so let me add some additional clarification here. I have also posted this comment on Chris Masterjohn’s blog, so either WAPF or Chris can correct me if they see something incorrect…

      In short, there is absolutely nothing to worry about with regard to trans fats in the FCLO.

      Any concern about trans fats consumption from FCLO is made irrelevant by one simple fact: the amount of trans fats in the FCLO is insignificant when compared to the amount consumed in a standard American diet. The FCLO is in fact ‘trans fats free,’ according to FDA definitions. To understand further…

      If we take Dr. Daniel’s WORST test result, we have a worst case scenario of 3.2% trans fats in FCLO. The FDA says that any food containing less than 0.5 grams per serving can declare itself trans fat free. The recommended FCLO daily serving is 5 grams (one teaspoon). The calculations:

      3.2% x 5 grams = 0.16 grams, or 160mg. This is far below the 0.5 gram FDA rating.

      Even if you triple the dosage/serving, you are still ‘trans fats free’ according to the FDA. Green Pasture could legally label the FCLO as Trans Fat Free.

      One order of French Fries has more trans fats than one month of FCLO servings.

      As general guidance, it is recommended that you should consume less than 2 grams, or 2,000mg of trans fats per day. Most Americans consume far more than that – easily double or triple that amount. Consuming FCLO would contribute LESS than 1% of the recommend target for trans fat consumption. Again, it is insignificant. Even if I took ten times the recommended amount, the trans fats would not have much impact.

      One additional note – about 80% of trans fats are artificial – they are man made products. The other 20%, and FCLO, are naturally occurring.

      Sadly, many people are making accusations that FCLO is a risk because of trans fats, and as you can see, that is simply not the case at all.

  11. Bruce says:

    I am interested in the 3% trans-fats that were found in Daniel’s report. This writing does not seem to address the issue.

    • Sally Fallon Morell addressed that in my comments above. She wrote: “I just forgot about the trans fats but Chris Masterjohn addresses this subject very well at We all know that Dave is not adding vegetable oil to the fclo. (he doesn’t use canned livers either, as someone has implied.)”

    • Carolyn Graff says:

      from a previous comment: Chris Masterjohn addresses this subject very well at

    • Jason says:

      Bruce, I found Dr. Masterjohn’s post about the free fatty acids to clear up the issue for me (this is the article Sally Fallon referred to):

      Quoting Dr. Masterjohn:

      “Dr. Daniel states that “Free Fatty Acids are so cytotoxic to cell membranes that
      the body makes it a priority to build them back into the safe triglyceride form as
      quickly as possible.” This statement is part of a brief discussion suggesting that the FCLO is harmful because of the free fatty acids themselves. The potential toxicity of free fatty acids is true, but is pulled grossly out of context.

      When we digest food, we hydrolyze fats to free fatty acids and monoglycerides before absorbing them into the intestinal cell, where they are repacked into triglycerides. Some authors argue that long-chain omega-3 fatty acids are more bioavailable when supplemented as free fatty acids. This is controversial, but it is notable that there are scientists even conducting studies of free fatty acid supplementation, which would not be the case if it were obviously harmful to consume free fatty acids.

      Free fatty acids elevate within our bodies in both good and bad contexts.

      When we burn fat for energy, whether derived from our diet or our adipose tissue, we hydrolyze fats into free fatty acids so we can break them down during beta-oxidation. This increases in the context of fasting between meals, exercise, or consumption of a diet richer in fat or lower in carbohydrate. These processes are normal and healthy.

      In the stress response, our body senses the need to release large amounts of stored fat, so free fatty acid levels elevate. Insulin prevents the release of free fatty acids, so in insulin resistance free fatty acids also elevate. These free fatty acids can compete with glucose for energy metabolism and thereby contribute to elevated glucose. They can also inhibit the biological activity of thyroid hormone. If cells are overwhelmed with more free fatty acids than can be efficiently burned for energy, they can also have toxic effects and increase the vulnerability to oxidative damage. But this is not an intrinsic toxicity of free fatty acids; it is the harm they cause during metabolic derangement.

  12. Muriel says:

    I would like to take the fermented CLO but I am concerned about consuming any products from the Pacific Ocean since Fukushima is an ongoing problem. I wish the CLO was from Atlantic Cod.

  13. ethan says:

    This seems like a good place to post this– has a 25% off deal for all fish oils… including Blue Ice caps which is only 30 to begin with. Doing it right now! Code is GOFISH25

  14. Charlie says:

    Since Sally Fallon Morell states that her family and she have experienced good results from taking GP FCLO, is it possible that she received a different product, i.e., higher quality, than the rest of us received? WAPF may not depend on GP, but I bet GP depends on WAPF.

    I fed my child a small amount of GP FCLO and he gagged it up (thank goodness). When I asked GP about my child’s reaction, he said “it is cod liver oil.” (a short smart-a@@ response. I have the email still.) I have been using a different of brand CLO for years for my family and never once a gag.

    • Steve Tallent says:

      Since nobody from WAPF has followed up to answer your question, I’ll step in. Nobody, not even Dr. Daniel, is contending that FCLO is without benefit. The contentions are that it might be riskier or even much riskier than folks have been led to believe, and that there are labeling issues, and misrepresentation about sourcing. There is an institutional belief in GPP and WAPF that this product is extremely beneficial to all and virtually risk free, that it is a truly special product, incapable of spoiling or going bad in any way under virtually any circumstance. That being the case, there would be no need for a specially handled product to be prepared for VIPs. I would imagine the GPP folks would be outraged at such a suggestion as the implications are numerous and very unflattering to say the least. Sally said that she sells the products on her website, as I do on mine. I would imagine that like me, when she wants a new bottle, she gets one from her stock – the same stock that she’s making available for anybody.

  15. Three Pipe Problem says:

    I have spent an hour or so looking into whether pollock is “a species of cod”, as is stated above. The statement appears to be a misrepresentation. Many sources indicate that pollock is in the cod family. Well, apples are in the rose family; but apples are not roses.

    The FDA prohibits selling pollack as cod.

    Here is a thread full of UK fish and chip shop owners discussing how inferior they consider cod for their purposes.

    In describing one investigation into seafood fraud, the UK Food Standards Agency is summarized as concluding that, “In 27 cases the fish described as cod was another species, such as haddock, whiting or pollock.”

    An article in NOAA’s “Marine Fisheries Reivew” on the subject of how to distinguish these two different species, begins “The pollock, Pollachius virens, is a good source of
    protein which can often be processed and prepared in
    recipes that call for Atlantic cod.”

    A New York Times article summarizing FDA investigations into fraudulent substitutions of pollock for cod states that, “In April 1991, the agency’s Commissioner, Dr. David A. Kessler, told the board of the National Fisheries Institute that the F.D.A. intended to find and prosecute institute members who substituted less expensive, less desirable species of fish for more valuable ones.”

    Chris Masterjohn has cited one source stating that it was legal in the 30’s to sell pollock liver oil as cod liver oil. Given the amount of legislation that has been passed in recent decades on mislabeling seafood products, I would be surprised if it is still legal today.

    Organizations that conduct research have no business taking money from vendors. If the WAPF wasn’t tied up with these people, would you be motivated to twist this simple issue, for example?

    • Terry says:

      you’re mixing up Pollock with Alaskan Pollock. Alaskan Pollock is a cod family fish, Gadus genus. Pollock is not. All cod are Gadus genus, with various species represented.

      • Three Pipe Problem says:

        Terry, I guess that’s news to the At-Sea Processors Association, an organization of Atlantic Pollock fishermen, which as far as I can tell, never identifies Atlantic Pollock with cod in their website/publications, except to say that Pollock is in the Cod family.

        It would probably be also news to this guy who was sued under the Lacey Act for selling Atlantic Pollock as Cod.

        In this paper, the National Aglaw Center lists substituting Alaskan Pollock for cod under, “Examples of Common Illegally Substituted Seafood”

        Since I’ve presented evidence refuting your claim, do you have any to back it up?

      • Steve Tallent says:

        Three Pipe Problem may have mixed up Pollock with Alaskan Pollock, I don’t know. It doesn’t invalidate the point. The “Allowable Market Name(s)” for Gadus chalcogrammus according to the FDA are Pollock or Alaska Pollock. Unless there is a grandfather clause or a specific “oils” rule somewhere (which I’ve asked WAPF to cite or reference since they specifically stated that “They are not required to list the individual varieties on the label.” which would indicate that there is some kind of rule governing this that they are referencing or else have been led to believe that there exists such a rule), the product would be “mislabeled” which as Three Pipe Problem referenced, the FDA does take very seriously.

        • Shira Nahari says:

          Apples, roses, cod, haddock, guppies…all could “smell as sweet by another name.” As I wrote above I am totally pragmatic. If something works for me that’s enough and I don’t care what it is called.
          (And the FDA is not my friend–or actually yours either.)

    • Melissa says:

      Actually, apples are roses. If you looked back to roses as they were before they were purposely bred for their current appearance you would find blossoms that look very much like those of apple blossoms. Cheers.

  16. Jeanmarie Todd says:

    Excellent, clear, concise response. Thank you, Sally Fallon Morell.

  17. Steve Tallent says:

    Perhaps you could clear up a few things for me:

    1) I’m a little unclear on the timeline of the testing and conversations with Dr. Grootveld in relation to board meeting. Board member Sarah Pope said that the board voted to not pursue further testing because you already had Dr. Grootveld’s results in hand, dated December 12, 2014. You said the board voted not to do testing because you already had peroxide tests provided by Green Pasture. But you also said that “Dr. Grootveld and others held that these were not good tests for rancidity” and that you learned that in conversations around that time. I don’t know the date of the board meeting, although I wrote requesting the meeting minutes almost a week ago. So this leaves me confused.

    2) You above that for you to post lab results, “a lab report must show the name and address of the lab, the name and contact information of the person requesting the analysis, the date, the name of the product, the type of test used and the name of the person responsible for the test.” The Grootveld lab report that you posted does provide most of that but fails to show the name and contact information of the person requesting the analysis.

    3) In his initial rebuttal, David Wetzel posted a comment from Grootveld. According to Sarah Pope, Wetzel had not used that lab before. The quote is, “… I am pleased to let you know that we did not detect any toxic lipid oxidation products in your Blue Ice Fermented Cod Liver Oil sample… In addition we
    performed some heating experiments on your oil, and found that this process (which readily induces and /or perpetuates these products in many commercially available oils) generates little or none of these toxic agents in your oil ……Somewhat surprising but valuable results….”

    The ellipses indicated that these were selected sentences from a greater whole. The Grootveld lab report that you posted has the first sentence (with a couple of changes one of which is to provide context (product name)), but none of the subsequent sentences. That begs the question, are we seeing the report in its entirety? If so, then do you have any clues as to where did Mr. Wetzel got the additional sentences? Was there an addendum? Cover letter? Summary?

  18. Steve Tallent says:

    Could you please provide the specific FDA rule that allows cod liver oil manufacturers to market all different kinds of fish oils or fish liver oils as cod liver oils? That seems highly unlikely to me judging by how careful we have to be in labeling our products. That manufactures do use all sorts of fish to make CLO does not seem unlikely. But isn’t that the kind of practice that we in the real food movement frown upon? As of the FDA’s mid July update to the seafood list, cod is not an acceptable market name for Alaska Pollock (or any other kind of pollock).

    I’m trying to imagine how I would feel if I went to one of my local farmers and was led to believe that I was buying pork from a heritage breed and come to find out later it was basically the same thing I could have gotten at any grocer. I guess betrayed, tricked, and foolish.

    • truth in labeling says:

      How telling that you are consistently ignored when bringing up the facts of the law on this matter.

      And consumers agree with you, which is why so many are so angry about the bait and switch on the fish species. They were sold on a traditional, authentic cod liver oil. They were expecting Atlantic Cod and instead they got Fukushima Fish.

      What ever happened to the customer is always right? I was sorely disappointed by this response. Rather than science we get competing anecdotes, smoke and mirrors, and conspiracy theories.

  19. Thank you for this, and for getting it up so soon!

  20. Augie says:

    Through my career I have known well over 100 trade and professional associations and worked with many of them. Never, ever do they recommend a particular brand. Any suggestion to do so would never be tolerated by their board or members. They do not recommend or rate or prefer one brand over another because it is not within their charter as a tax-exempt trade or professional association and if they did there would be a huge amount of fighting. If WAPF was not doing this then this type of fight and hurt feelings would not be happening. It is not necessary and should stop

    • Judy says:

      WAPF is not a trade or professional organization. Its members – including me – WANT recommendations. I welcome WAPFs continuing research and investigation of CLO and FCLO, but it should never have been brought to the attention of the public in an “expose” intended to incite a riot. I am highly suspicious of Daniel’s motives and would welcome an “expose” on her true motives.

  21. Judy says:

    1. I accept as true the assertion made by others on the board who know their cods, that the Alaskan pollack is a cod.
    2. Did Dr. Price identify which specie of cod he was referring to when he discussed COD liver oil? If not, then a cod by any other name is a cod.
    3. Are the makers of the many other cod liver oils also using Alaskan Pollack? How about directing some outrage at them?
    4. There is apparently much resentment over paying a “premium” price for FCLO, especially now that Dr Daniel claims the oil is not from a cod. Some commenters say they’ve paid $50 a bottle. I pay $34 a bottle, but I always buy 12 bottles to get the discounted price OR I wait for a sale. The $34 bottle contains 237 mL or 48 tsps. I take 1 tsp/day, the bottle lasts 48 days, or almost 7 weeks, and costs 71 cents a day, which is a price comparable to other CLOs on the market.

    While awaiting WAPFs full report coming in the Wise Traditions Winter Q, I will continue to take Green Pasture’s FCLO.

  22. Three Pipe Problem says:

    “I accept as true the assertion made by others on the board who know their cods, that the Alaskan pollack is a cod.”

    Judy’s loyalty to people over evidence speaks volumes.

  23. Ron Blouch says:

    Thank you, Sally. That was helpful. It was a real shock to see David Defending himself against a WAPF board member. I appreciate you clearing up the issue and explaining what is going on.

  24. janieinMN says:

    The FDA has rules for labeling, branding, ingredients, allergens, etc. They are quite specific. It is ILLEGAL to substitute pollock for cod (or any other fishes). If pollock liver oil is being used, the product canNOT be branded “COD liver oil”. When multiple fishes are used, they must be specified in the ingredients, by their acceptable market name.

    Green Pastures has misbranded their cod liver oil, mislabeled the ingredients, created risk of serious reactions to their product by not declaring ‘pollock’ as an ingredient and under ‘contains’, mislead their customers, and they’ve done it willingly and purposefully. In my opinion, Weston Price organization is also guilty through association, recommendations, condoning and approving the practices of GP.

    This is FRAUD.

  25. three pipe problem says:

    jamieinMN says, “Green Pastures has misbranded their cod liver oil, mislabeled the ingredients, created risk of serious reactions to their product by not declaring ‘pollock’ as an ingredient and under ‘contains’, mislead their customers, and they’ve done it willingly and purposefully. In my opinion, Weston Price organization is also guilty through association, recommendations, condoning and approving the practices of GP. / This is FRAUD”

    This seems a bit strong, or premature. Has it been established for certain that GP used Pollack? Or that there isn’t a special exemption for the law, given what is documented about pre-1930’s law?

    I am sure that the facts will be sorted out on each question that has been raised. It seems clear that there are plausible counterarguments to some of Daniel’s point, and I am glad people like Masterjohn and Kresser have addressed this scientifically. They are clearly trying to address this as objectively as possible.

    But regardless of how each specific question shakes out, what this thread, and the one on Sarah Pope’s blog, is that insider’s are quick to leap to defense of insiders, even when it involves forms of ad hominem, questioning motives rather than facts or invokation of the “argument from authority”. This is only natural, which is why smart organizations design their relationships defensively.

    One never knows when new information will come out. It behooves organizations to order their relationships and funding such that when new information comes out, the natural tendencies to protect insiders — an instinct that could not be more clear in these conversations — is not in the way of evaluating the new information and accommodating for it. It seems to me that this situation has revealed the WAPF can and should improve in this respect. Doing so would not be a wholsale endorsement of Daniel’s criticism any more than it would be a refutation of Green Pastures product. It would be smart.

    WAPF is an extraordinary organization. To it’s credit is is allowing this debate to happen and contributing to the scientific portion of the debate. If WAPF were like most organizations I doubt we would be seeing this. We should applaud this. We should also speak out in favor of WAPF not engaging relationships that may create even the *potential* of conflict of interest or reduce agility/objectivity in cases like this. Because in such matters the potential can become the reality… or at least the public perception.

    Unfortunately $20,000 is enough money to influence people. I think we all know this. It has been maintained that WAPF doesn’t depend on this money, because it is a small portion of the budget. To me that’s good news, because it means the board can easily step away from financial relationships with vendors in areas where it funds research. Which would definitely be the best thing to do!

    Regardless of how each of Daniel’s

    • David says:

      Interesting and objective post, three pipe problem.

      It seems like you want to use “science” in its intended form and definition. I like that, it is the best method we have.

  26. Morg says:

    We’ve done an analysis of Dr Kaayla’s report and found it inconclusive at best. Please take the time to give it a read:

  27. Victor says:

    At the end of this post I propose a solution that can perhaps bring both ‘sides’ together for a common purpose. But please bear with me for a moment as I lead up to that…

    Anyone relying solely on science for the answers has missed the point of this FCLO issue entirely. You have committed two sins that defy the very logic for you being here (in the traditional food space):

    1. Sin #1: You are insisting that science trumps experience. Yet we are here exactly because we are tapping into the personal experience of our ancestors. Our science will never be able to completely understand water, let alone FCLO. The march of science is relentless because it is forever incomplete.

    2. Sin #2: You are dismissing personal responsibility. Each individual is supposedly taking responsibility for their own health by joining this subculture, as they attempt to wrest control away from big business, big government, and whomever else is trying to deceive them or make them dependent. Trying to make WAPF or GP responsible for individual ‘FCLO abuse’ violates this essential idea of personal responsibility. The people must become aware of, and responsible for their own experience.

    Dr. Weston A. Price did not use science to ‘find’ the answers. He used it to confirm what was already proven by the traditional people. The entire idea of pursuing ancient traditions is founded on the fact that they were much healthier than us. Their experiences proved the efficacy of their diets. Science just helped communicate that to us. Dr. Price looked for healthy people and tried to figure out why they were that way. He succeeded.

    Dave Wetzel has actually done a similar thing, which most of you are disregarding. He is trying to provide a completely natural FCLO that eschews modern intervention to the greatest extent possible, and relies only on traditional processes, in order that it might provide benefits that we cannot yet quantify or understand. He succeeded.

    Now we have people like Dr. Kaayla Daniel and David Gumpert making (IMO) libelous statements in an attempt to throw out the wisdom of experience. In my opinion they are certainly guilty of libel; however, their more serious crimes are committing the sins I mentioned above.

    They are attempting to return people to the leash of scientific ‘authority’ – give up your personal responsibility, ignore the wisdom of experience, and be guided only by the rhetoric of supposed leaders; which of course would be them, and not WAPF. Ironically, they do not have science to support their guidance, so they are using fear, uncertainty, and doubt (which is why it is libel in my opinion).

    They are asking us to ignore the countless people around the world reporting the spectacular effectiveness of FCLO for nearly ten years. They are also asking you to disregard the science. Yea, OK, it was rancid fish oil from China that was mixed with vegetable oil, devoid of nutrition and filled with toxins. Yea, ok, that is the product that cures rats of rickets in rat assays, helps heal cavities and eczema, etc., etc., etc.
    Yea, sure.

    Let’s put all that aside.

    If there is a common issue that we can rally both sides around, perhaps it is this: There is a problem in the consumer base with FCLO ‘abuse.’ While the term and idea has not been discussed to my knowledge, I believe that both sides would agree that it matches the single concern about FCLO: There are people out there that are not compatible with FCLO, and they need help in understanding that.

    This is not at all new or unique. All food products are potentially dangerous to someone, and we must stop promoting the idea that personal responsibility is not required. A glass of wine is good for you. For most people this is true. But not for all. And obviously alcohol abuse is not good for you. This advice is given by countless doctors and experts. And it is the same as the FCLO advice, and any number of other foods. Dave Wetzel has a daughter that is not compatible with FCLO, and he promotes that fact.

    We need to encourage more personal responsibility, and educate consumers about weighing their own experiences with that of others, and with science too. This would be a legitimate and helpful pursuit that would be in line with everyone’s concerns.

    There is definitely FCLO abuse occurring in the consumer base, and that doesn’t have to mean that we are blaming the consumer. Some people are just too eager, and the product is somewhat new to them, and to all of us. FCLO is like a magic pill for some people, and those stories of success are what drive the product sales – and possibly product abuse. In some ways, the product is a victim of its own success.

    Blaming WAPF and GP is not correct, appropriate or constructive by any stretch. Certainly, we can all improve. Empower the people to use their own experience and make their own judgments – not only about FCLO, but about all their foods.

    • Bill Leach says:

      Victor, beautiful post!

    • David says:


      Um YES Dr. Price DID use science. He documented, was objective, etc. He used OBSERVATION as one of the crucial variables he used in his process, BUT it was just ONE variable and is widely accepted in science. It is not allowed as the ONE and ONLY variable and foundation for the experiment, BUT it IS VALID in science!

      I cannot believe people are trying to resolve this discussion when they cannot get the basic definition of words to be the same from person to person OR from comment to comment between the same person!

  28. Selina says:

    Hi I’m a regular green pastures fermented butter oil user & have recently found out that I am pregnant and I am worried with all these new claims that I may be harming my unborn baby with this product was wanting your thoughts on using this product while pregnant??
    Thank you

    • Bill Leach says:

      Selina, If you are not having any problems with FLCO then I suggest not worrying about the ‘controversy.’ It seems that science is rather strongly in support of Green Pasture Products FLCO. I suggest following the current WAPF guidelines.


  29. Kippy says:


    You last post was so point on and amazing. It brings us back full circle, and I hope everyone reads it and understands it. We are all responsible for our health, and we here to find what our ancestors did and science does NOT trump that! Thanks so much for taking the time to write it in such a way!

  30. Turquoise says:

    I take GP’s new Blue Ice X-Factor Infused Organic Virgin Coconut Oil with the fermented cod liver oil, X-Factor High Vitamin Butter Oil,& Blue Ice Fermented Skate Liver Oil. This does not seem to be involved. No one has mentioned this product at all. Am I the only one to take It??

    • Turquoise, I and some of my family members take the Infused oil, in a couple of different flavors. I can count five different households in my family that have used the Infused Coconut Oil at one time or another.

      A few family members even like the taste (caramel or banana carob); though that would not include me 😉 However, I find the Infused products to be the most convenient, and they definitely impact my health. (The capsules are actually the most convenient, and some of my family switched to them, while others use the straight FCLO and BO, as those are most cost effective.)

      I am too lazy to take anything consistently, and inevitably I will get a cavity or sensitive teeth, which I can remedy rather quickly with the infused oils. I take maybe half a teaspoon morning and night when I feel the need. I keep mine in the fridge and use a demitasse spoon so scrape some out and swallow it down.

      By the way, my current jar was actually packaged over two years ago, and it still demonstrates the same effectiveness. I overstocked a couple of years ago before I learned the amount that was effective for me. Everyone is different, and like every other food, these products may not be for everyone. However, I have not found any merit in Dr. Daniel’s concerns, and all the followup I have seen the past month is supporting what Sally has said here.

  31. Ashley says:

    I had black stools today after taking two capsules of the Green pastures Blue ice fermented cod liver oil last night. Is this normal? I just started on the supplement about three days ago and I’m seven months pregnant, 31 years old. No other factors contributed as nothing else in my diet or other supplements have changed. The bottle did travel overseas and I have since started refrigerating it as opposed to leaving it out in a dark cabinet.

  32. Tiffany says:

    I just purchased the butter and the FCLO and I am praying it will help my sons tooth decay. Since his teeth have come in they have been weird and two dentists told me that was normal. He is three and now has several cavities that are very obvious (one being a hole) and a weird film on all of his teeth. Please be in agreement in prayer that he will be healed with the nutrients! Please dont respond if your going to be negative! I believe this is going to work and I am going to take pictures of before and after for proof. 🙂

  33. Cherie says:

    Tiffany, Hi, my 5 year old daughter also has cavities in her back teeth, one is a large hole! I give her 1/4 teaspoon twice a day and it seems to have stopped the decay, however the hole has gone black which looks unsightly but is a good sign that its not spreading. We also drink raw milk, eat organ and offal meats from deer we hunt ourselves in the untouched national park on Stewart Island/Rakiura New Zealand. We live on Rakiura with an aprox population of 400 people surrounded by pristine national park, we grow some of our own vege and have some chickhens for eggs and meat…. I’m a petty lucky person really. I’d be really keen to keep in touch and see how your childs teeth go, my daughter still experiences some discomfort, and when this happens I up her I take a bit and it seems to work. I don’t understand how she got the cavities, she doesn’t eat junk or fast food… It must have been a lack of something in her diet, not sure what. Anyway, keep in touch if you want

  34. Dr. John Keils says:

    2 months ago I was very surprised to find my own vitamin D level was only 26 on the blood test! My diet has always been strong in most of the “usual” sources for “D” yet my levels were way too low. To raise my levels I supplemented with 6 tabs of Standard Process vitamin D daily and 10 drops of PRL liquid D. In 2 months I raised my D level to 88. Which is optimal now.

  35. Sheena says:

    Thank you for explaining this really well. We’re would be the cheapest place to order the butter oil and fermented cod liver oil online. I can’t take pills, I need liquid. I also have factor v leiden and worry about vitamin k making my blood thicker and giving me a clot. Could you please give me advice on this?

    • David says:

      Sheena I guess nobody is replying. From what I have found if you want “Green Pasture” then buy directly from them. They offer the longest expiry date (freshest) and best prices (most sales, best discounts).

      It just makes financial sense too. When a manufacture makes it then sells it they don’t have the markup of an extra middleman. This is not always the case, but mostly when there is an extra “person/business” in the middle that costs extra money. The more people the more cost!

      If you are not talking about Green Pasture, then I don’t know what you are talking about since this whole page is about that one product. Maybe next time you can list what you are talking about. Maybe you will get more replies too. I took time to guess, many others wouldn’t (if I wasn’t on holidays I woulnd’t either)

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