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The Demise of Fermented Cod Liver Oil: Smear Campaign or Fact?

The Demise of Fermented Cod Liver Oil: Smear Campaign or Fact?

Have we been taking an inferior product touted as one of the best supplements known to man all along?

This post may contain affiliate links.

Discovering Fermented Cod Liver Oil (FCLO)

It was fermented cod liver oil that brought me to the real food world. Several years ago, my son began facing some health issues. Bronchiolitis, asthma, allergies, tooth decay. Vain or not, it was the tooth decay that kept me wide awake in the wee hours of the night searching for answers. I found Dr. Ellie’s system and tried that because it seemed simple enough. It helped for a little while, but then his teeth began yellowing. She tried to help but I found her difficult to follow at that point. I stumbled on the Mothering forums, and had a crash course in how diet affects us. I learned about WAPF, and from the WAPF website I learned about GAPS, which I realized could help all of his issues.

I ordered fermented cod liver oil, and I began giving him double or triple the dose for a couple weeks, with immediate, amazing results for his teeth and skin. We took it a step further and went on a “mostly-GAPS” diet where we had many positive results, including healing my own tooth decay without the use of the FCLO, as I could only afford enough for him at the time. He was allergic to dairy and I didn’t want to risk trying it at such an expensive price tag, so he never had the butter oil until we bought the coconut-oil infused blend a couple years ago. Instead, I gave him his cod liver oil with egg yolks, coconut oil, tallow, etc. which would provide him with a good amount of fat-soluble vitamins.

His health improved so much and so quickly that I couldn’t help recommending FCLO, WAPF, GAPS, and Paleo to almost anyone with a health issue. I’ve personally witnessed many friends and their children improve overall health by switching to real food diet, and experience positive benefits from taking the fermented cod liver oil. While I never had an issue with the smell or taste of the FCLO, perhaps because I’m a big fan of red herring, some of them complained about the taste or the smell. Not everyone is a fan of every food, though, so it didn’t seem strange to me. I personally can’t stand the smell of eggs.

FCLO is not a health product… wait, what???

With the release of the free e-book by Dr. Kaayla Daniel on August 22, 2015, I am forced to rethink recommending Green Pasture’s products. Are the products safe or is she slanderous? It may take some time to conclusively determine whether or not Green Pasture products are safe. There are some deeply concerning allegations being made, and while I am in no position to say who is right or who is wrong, I have read over the report and can offer you a summary so your family can make an informed decision whether or not you want to continue taking what product you’ve already purchased.

Here are the most troublesome allegations:

  • It is not possible to ferment fish livers
  • FCLO may be a rancid, putrefied oil
  • FCLO may not be cod liver oil after all, rather Alaskan Pollock or something else
  • The fish, whatever it may be, used for FCLO is from Alaska, not a special source
  • FCLO may be cut with low quality, inflammation-causing, trans-fatty vegetable oil
  • Butter oil may be rancid
  • Butter oil may be from Argentina, NOT the Northern Great Plains

Does the report support these allegations?

In order to determine whether or not the report’s initial findings are credible, we will take a look at a few points.

Is it possible to ferment fish?

Dr. Daniel’s report “Hook, Line and Stinker!: The Truth About Fermented Cod Liver Oil” states that FCLO cannot be a fermented product because the pH ranges from 5.8-6.2, which is not acidic enough to preserve the oil. It states the pH needs to be 4.6 or lower for a true ferment. She also states that carbohydrate is necessary for fermentation, and that the amount of glycogen, which can be a carbohydrate source for lactic acid bacteria (LABs), found in cod livers is minimal (Daniel, 2015, pg. 14).

Cultures for Health recommends a pH of 4.6-5.0 for fermenting meat and fish. They do corroborate that sugar and starter cultures may be necessary to feed the bacteria while the meat or fish cultures.

In the paper “Fermented Meat Products: Production and Consumption” by Ockerman and Basu of Ohio State University, the process of fermenting meat is explained. The paper expresses that “…whale, fish, rabbit, by-products and other tissue from a variety of species can be used to make fermented meat products.” It tells us how:

Lactic acid which accounts for the antimicrobial properties of fermented meats, originates from the natural conversion of glycogen reserves in the carcass tissues and from the added sugar during product fermentation… Glycogen in meat can also act as a carbohydrate source and contributes slightly to acidity.

In the same paper, we learn that a pH of 5.3 or less is optimal. 5.0 or lower is considered shelf-stable in the United States, while a pH above that requires refrigeration. In the section titled “Fermented products made from unusual animal parts,” we see that sun-drying is sometimes used as a method and “[t]he flavour is usually challenging.” We also see that

…pH for beef ranges from 5.5 to 5.7, for pork pH 5.7 to 5.9 [dark firm and dry pork (DFD) usually has a pH greater than 6.0-6.2 and pale, soft and exudative pork (PSE) usually has a pH 5.3-5.5)], and poultry pH ranges from 5.8 to 6.0. Beef, lamb, and pork have more saturated fat and less moisture… and therefore… are less susceptible to rancidity and off flavours… (Source)

While the paper does not address the livers taken from cod specifically, we see that there is a wide variety of pH ranges for fermented meat products and that rancidity cannot be determined from the pH alone, rather the composition of meat product(s) and processes used plays a role.

Kayla Grossman also researched fermented cod liver oil and found that it was a traditional process, get more information here.

Is FCLO rancid?

This greatly depends on who you ask. If the train of thought that cod livers can be safely fermented proves correct, then it may follow that the oil extracted is also safe for use.

Green Pasture has lab data showing that the oil is not rancid. However, Dr. Daniel states in her report that the measures used are not the correct measures for a fermented product. She says her new data suggests “…Green Pasture did not achieve non-rancid results by fraudulently submitting cleaner-than-usual samples or cod liver oil from his competitors” but rather “[they use] the wrong kind of testing for a long-term “fermented” product.” (Daniel, 2015, pg. 18-19)

The markers used for Green Pasture’s testing are Peroxide Value and p-Anisidine Value. Neither is very reliable. These are the same measures the report uses to label Butter Oil as rancid. The Total Oxidation value is found by multiplying the peroxide value by two and then adding the p-Anisidine value, and therefore is also considered unreliable when the results are within range for FCLO. Thiobarbituric acid tests are also considered unreliable, even though 1/3 labs found results that suggest rancidity (p. 21).

The markers Dr. Daniel suggests using are fatty acid levels and acid value. The fatty acid levels were found to be quite high: 16.2%-40.1%. The acid value (which is the fatty acid level multiplied by 1.99) were in turn found to be high, with a range of 32.3 mg/KOH/g – 79.8 mg/KOH/g. A normal fatty acid value is 3 mg KOH/g or less (p. 24).

What kind of oil is FCLO after all? And is it cut with inflammatory veggie oils?

The only lab that received a sample of Green Pasture’s cow lick to test concluded “[t]he liver is “100 percent Alaskan pollock” (p. 49). The cow lick is the fermented livers sans oil left over from FCLO production, so would most accurately tell us what kind of fish is actually used. Without receiving a cow lick sample, other parties could only analyse the data provided to determine what kind of fish FCLO may come from, as “DNA procedures do not work well with oils” (p. 48). Nuclear Magnetic Resonance (NMR) spectroscopy testing could only conclude that the fish used as “similar to cod, wild…” (p. 48). The EPA to DHA ratio leads to the conclusion that Arctic Cod is not the real fish, rather something else like Peruvian Cod or Alaskan Pollock, but more than likely the Alaskan Pollock (p. 46-47).

One of the most worrisome concerns is whether or not there is indeed inferior, inflammatory vegetable oils added to the product. Apparently, this can be done for antioxidant protection (p. 51). These are questions only further testing, or transparency from Mr. Wetzel, can answer once and for all.

What about high-vitamin butter oil (HVBO)? Is it rancid? From Argentina?

According to Daniel’s report, HVBO contained the highest vitamin K2 levels of the products tested, with a range of 393.84 ng/g – 431.11 ng/g. Next up was a high-quality, grass-fed ghee with a range of 324.36 ng/g – 335.70 ng/g. A competing brand of butter oil had levels of 250.65 ng/g – 259.89 ng/g. Other butter oils ranged from 196.37 ng/g – 263.70 ng/g. Other ghee samples ranged from 268.37 ng/g – 367.45 ng/g. All of the ghee samples contained around double the amount of K2 found in regular butter, or the equivalent of 1 egg yolk. In increasing order, soft cheeses, hard cheeses, goose liver pate, and natto all had significantly higher levels of K2 than Green Pasture’s butter oil (Daniel, 2015, pg. 66).

Dr. Daniel supposes that the activator, or “X factor,” that Dr. Price highly touted is not Vitamin K2. She says this because grass-fed butters also tested high in vitamin K2, and Dr. Price was specific that butter oil contained the activator and not plain butter. Her reasoning leads her to believe further testing is necessary to find out what’s different about butter oil that makes it work alongside cod liver oil so well (p. 68).

But is it rancid? From cross-referencing results of butter oil in the report (3.6 mEq/kg) with what Wikipedia says about rancidity levels, lab-wise it appears that it could be OK. “Peroxide values of fresh oils are less than 10 milliequivalents/kg; when the peroxide value is between 30* and 40 milliequivalents/kg, a rancid taste is noticeable.” (Source) Further research on the acceptable values for butter oil and similar milk products allow peroxide values ranging from 0.1-1.0, which means HVBO would be considered rancid for several different countries. (Sources: 1, 2, 3, 4)

The p-Anisidine level for Butter Oil according to the report is 4.1. This source says that’s OK “[f]or fish oils the p-Anisidine value must be lower than 30, in other sectors less than 10 AV is required.” (Source)

Is it from cows grazing on pasture in Argentina? Dr. Daniel supposedly has conclusive evidence that the butter is imported from Argentina.

What About the Vitamin Content?

It appears that there has actually been major inflation of the content of Vitamin A and D in the fermented cod liver oil. The lab providing the high results uses a unique method known as High Performance Liquid Chromatography (HPLC) that utilizes ultra-violet light detection and does not produce results that can be replicated. The lab’s method of testing and analysis may be quack science (Daniel, 2015, pg. 35-36).

What about fermented foods in general?

I found it interesting reading the following quote:

It’s also a myth that Dr. Price found healthy people in primitive cultures eating lots of fermented foods. The truth is he mentioned fermentation only twice in Nutrition and Physical Degeneration… Dr. Price rarely mentioned fermentation in his other writings either. (Daniel, 2015, pg. 57)

Is there an anti-fermentation movement going on? An anti-WAPF movement? Certainly ferments in general are not under attack as well? Whether Dr. Price mentioned ferments or not does not take away the incredible health benefits they confer.

Who Can We Trust?

We are all waiting to hear what Dave Wetzel from Green Pasture and Sally Fallon and the rest of the Weston A. Price Foundation have to say. It will take them some time to pour through the research. Additional testing and a fair amount of transparency from Mr. Wetzel may be warranted. I know many of us want this to be a bad dream. We want to wake up tomorrow and know with certainty that this product we may have been taking and giving to our loved ones for years is nothing short of a miracle food. There aren’t many guarantees in life, but when we make a choice for the betterment of our health based on plenty of seemingly credible research and positive anecdotes, we very much want it to be true.

Will Dave and the WAPF gang give us unbiased, credible information? Can Dr. Daniel’s findings be trusted? Dr. Ron was quick to pull Green Pasture’s products, but at the end of Dr. Daniel’s report we find that he, along with other WAPF members, helped fund her research. She does say she advised she would publish her report regardless of her findings, but other sources say she seemed dead-set on finding Green Pasture’s products unworthy.

Are there any positives?

The report is preliminary, and further investigation is necessary. The report found that the product is not contaminated by unwanted bacteria, perhaps because it is an oil with low moisture content (p. 9). This would, of course, also explain why counts of beneficial bacteria are low in the product, even if they were in the ferment prior to extracting the oil. There does not seem to be antibiotic contamination or added vitamin E, either (p. 43).

If the fish is Alaskan Pollock, it is a relatively clean and sustainable fish unlike “most true cod liver oils requir[ing] extensive processing to reduce toxicity” (p. 51).

There are still thousands of people who have had positive results from taking the fermented cod liver oil. While this does not mean one should continue taking an inferior product if these allegations are found to be true, it does mean there is little need to worry about what is already done. It still can’t possibly be as bad as cooking with inferior oils.

Majority of the testing found the levels of biogenic amines extremely low, including histamine. One lab’s results “showed extremely high levels of tyramine, tryptamine, putrescine, phenyletylamine and cadaverine” and Dr. Daniel says it is a mystery but Green Pasture may be using better processes now as only an older sample showed worrisome levels (pg. 31-32).

There also wasn’t any trace of antibiotics or GMOs found in the butter oil, so regardless of origin it likely is really from healthy cows on pasture (p. 68).

What Should We Do Now?

Many of us are deeply disturbed by Dr. Kaayla Daniel’s findings on fermented cod liver oil. I want to remind you that it is a supplement, not an essential. If you have concerns, stop taking it and instead opt for wild-caught fish, pastured liver, egg yolks, tallow, lard, ghee etc. If you can do dairy, raw milk kefir is an excellent option (so are other fermented foods such as hard cheeses, sauerkraut and natto!). I am closely following this topic, and will update on the Facebook page as soon as more information becomes available.

Feel free to leave a comment with your thoughts, I’d love to hear how this news has affected you and your family.

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michelle v

Wednesday 30th of December 2015

Hi--do you have any updates on this? Thanks!

Teri Sue Wright

Wednesday 26th of August 2015

Look at the intention behind counterattack - it is not very professional as to inquiring, it is literally a fear based attack. That always gets me wondering... then as a scientist myself I look at the first bit of information. I have not read her book so am somewhat reluctant to speculate, but first off, how does she know the pH of the fermented cod liver oil - does she just assume or has she visited David Wetzel's process. Maybe he lists it somewhere... I should look into this further obviously. I can just feel her intent through the comments posted and am already on WAPF and FCLO's side. Alternatively, as a practitioner, I always treat the patient, not the paperwork. If it's working for the patient, which indeed the FCLO IS WORKING - for countless families and children, then use it!! I have met David Wetzel personally and I can tell you his intent IS NOT to sell more FCLO and other products. His intent is truly to HELP PEOPLE! And then comments about funding - who is funding Dr. Daniel - will seal this case. From knowing who David Wetzel is to comparing it to Dr. Daniels' fear based attacks, I can easily tell who is being truthful and who is being harmful. Maybe some of her points are somewhat accurate, but it doesn't undermine the fact that FCLO is superior in every way. I certainly haven't changed my mind an iota and we take A LOT of FCLO in our family : )


Thursday 27th of August 2015

She supposedly had labs ran on several of Green Pasture's products. All the labs' information are blacked out because they all wanted to remain anonymous :/


Monday 24th of August 2015

I have been planning to order FCLO for a long time now. I find the timing of this all very suspicious, since the anti-vaccination movement is being fought so hard, and supplements and natural health alternatives are apparently beginning to take a noticeable toll on the medical industry in general. People are starting to wake up to what is really going on. Unfortunately, it's far too easy to spread misinformation, and the very tools we have been using to uncover the truth are now being used to hide and distort it. I don't know who to believe anymore, but I tend to think that if the majority of medical professionals follow it, I'd better be very, very careful...