A Big Dose of Codswallop

cod cod liver oil dr. weston a. price fermented cod liver oil fish liver oil green pasture hilda gore marine stewardship council phenols ppnf price-pottenger nutrition foundation rancid oils rancidity randy hartnell rudi moerck sally fallon morell sylvia onusic trans fats wapf weston a. price foundation Jul 13, 2018

Sally Fallon Morell, president of the Weston A. Price Foundation (WAPF), sent a letter this week to members of her non-profit organization assuring them once again that Green Pasture Fermented Cod Liver Oil (FCLO) is safe. For anyone with doubts, she recommends listening to a podcast she produced last winter to rebut critics, educate consumers and “dispel the confusion” about the product.   

That podcast is nothing more than an  “informercial” in which Fallon Morell spends 30 minutes defending and praising David Wetzel, his company Green Pasture and the Fermented Cod Liver Oil product. 

Sylvia Onusic, PhD

Fallon Morell’s letter followed the resignation last week of Sylvia P. Onusic, PhD, formerly secretary and member of the Board of Directors of WAPF. Sylvia’s resignation was precipitated by Fallon Morell’s insistence that Green Pasture Fermented Cod Liver Oil be included as an ingredient in a homemade infant formula recipe despite massive evidence showing the potential for harm. As she put it, “I cannot in my heart and conscience support that product.”


 She furthermore stated that she learned science was of “little consequence” at WAPF unless it could be found to support the opinions of Fallon Morell. To read Sylvia’s full letter, click here.


I will discuss the points made in the WAPF “infomercial” shortly. First some background for those new to the FCLO controversy:


In 2015, I tested Green Pasture Fermented Cod Liver Oil at five of the world’s top laboratories because of mounting concerns about product safety and growing evidence of serious harm to consumers. I reviewed the data with many of the world’s leading marine oil and fats experts, all of whom concurred that it was rancid, putrid and low in the fat-soluble vitamins A, D and K. Furthermore, DNA testing showed the livers were not from Nordic cod, but from cheap Alaskan pollock, a case of mislabeling that many consumers consider fraud. Worse, the labs provided evidence that the product had been diluted with a vegetable oil that contained trans fats of a type found ONLY in vegetable oils.

It’s been nearly three years now since I released these findings in my report Hook, Line and Stinker: The Truth about Fermented Cod Liver Oil.  Not long after, Green Pasture — facing probable investigation by the FDA and other agencies — scrubbed its website of unwarranted health claims, questionable data about vitamin and other nutrient levels, and incorrect statements about its manufacturing processes. No matter. Fallon Morell, in her role as Green Pasture’s marketing arm, allows that information to remain on the Weston A. Price Foundation’s website. And she avidly promotes the product with articles, podcasts and at conferences.

At some point after 2015 Green Pasture switched from making its “cod liver oil” from Alaskan pollock to Alaskan cod. In all probability, the company took this action to avoid fraudulent labeling charges. The decision proved helpful as well to gain a stamp of approval from the Marine Stewardship Council (MSC). Although the MSC stamp of approval leads many members of WAPF to conclude that all is now well with Green Pasture, the bottom line is MSC cares only that the fish livers in question come from Alaskan cod and were sustainably fished.

The Marine Stewardship Council couldn’t care less about whether the product is “fermented” from fish livers in Nebraska or processed with other Alaskan cod liver oils in a manufacturing facility in Alaska. MSC is not interested in whether the true levels of fat-soluble vitamins in the product match the data posted on the Weston A. Price Foundation’s website, whether or not the product is rancid, or if phenols naturally exist in the product.


The podcast’s host, Hilda Gore, starts out by assuring listeners that Sally Fallon Morell taped the podcast to “dispel the confusion” about cod liver oil.

In fact, Fallon Morell delivers 30 minutes of misinformation about the research of Weston A. Price DDS, traditional and modern fish liver oil manufacturing processes, and the fat-soluble vitamins A, D and K. She slanders my professionalism and motives and also those of Rudi Moerck, PhD, one of the world’s leading marine oil experts and a regular expert at Dr. Joseph Mercola’s website.

Let’s now take a look at some specific information found in this “infomercial.”


Fallon Morell says “Cod liver oil is a good part of Dr. Price’s work.”

This is not true.

Accurate information about Dr. Price’s research on cod liver oil can be found at the Price-Pottenger Nutrition Foundation in San Diego, CA. In 2015 PPNF shared with me every line Dr. Price ever wrote about the topic from his letters, journal articles and his book Nutrition and Physical Degeneration.  All his words are quoted and referenced in Section VI in my report Hook, Line and Stinker. 

While Fallon Morell is right that traditional peoples had high levels of A and D in their native diets, Dr. Price expressed reservations about the use of any cod liver oil. Although he found it could be helpful taken short term in limited quantities by extremely malnourished individuals, he was seriously concerned about rancidity, a common problem with fish liver oils in his day. Dr. Price’s research also makes clear that he would never, ever have recommended a “fermented” cod liver oil.  In fact, Dr. Price rarely used the word “fermentation” at all in his writings except in connection with wine and poi. 


Fallon Morell states that “fermentation allows us to get oils without compromising the nutrient content of the livers.”

This statement contains several errors, starting with her claim that fish livers can be fermented. They cannot. Cod livers and pollock livers are only one to three percent carbohydrate, which is insufficient to maintain a ferment. Furthermore, fermented products require an acid pH of 4.6 or lower. FCLO’s pH, as tested at two laboratories, came in high at 5.17 and 5.8. Green Pasture owner David Wetzel himself has said (on video and in conversation) that the pH of FCLO is even higher, at 6.1 or 6.2. Whether or not the oil was actually obtained through “fermenting” of the livers, the evidence is clear that it’s not being preserved by an acid pH. And if it’s not being preserved, it’s going rancid.

Even if it were possible to ferment livers, fermentation only modestly increases levels of vitamins in any product. The nutrient content for Vitamins A, D and K formerly posted on the Green Pasture website —  and still reported on the WAPF website — defies common sense. It was not only disproven by the top laboratories I enlisted to prepare my Hook, Line and Stinker report, but according to some of Fallon Morell’s own testing. 


Fallon Morell assures us that FCLO is not rancid and she proved it with testing she arranged at a laboratory in the United Kingdom.

First of all, the laboratory chosen by Fallon Morell does not specialize in marine oils. In accepting their findings, Fallon Morell chose to disregard findings of leading marine oil laboratories in the United States, UK and Norway, all of whom found the product to be extremely rancid. Her refusal to accept their findings is in keeping with a letter she wrote in Fall 2014, in which she stated she would not accept the results of any laboratories that were “unfair to Dave.” According to her point of view, “unfair” is any laboratory that finds the Green Pasture product to be at odds with her opinions of it. According to Sylvia Onusic, PhD, WAPF recently accepted funds from Green Pasture to pay for more testing at that laboratory.


Fallon Morell states that the Weston A. Price Foundation recommends only cod liver oil brands that do not use heat in their manufacturing process.

If Green Pasture products are in fact “fermented” in vats in Wetzel’s solar facility, the bottom line is they are heated. Whether heated naturally by the sun or artificially with a furnace, heat is a cause of rancidity. Visitors to the facility and ex employees have reported extremely high temperatures there.


Fallon Morell states “First, I’d like to give you a little history on my own experience with cod liver oil . .  .  I was very concerned about my eyes. I had very poor night vision, and floaters.  This was of great concern to me. When I started taking this fermented cod liver oil, the floaters went away and my night vision been perfect since. I was thrilled. This is a wonderful product based on my own experience so I encouraged him (Dave Wetzel) to continue with the product.”

In addition to “encouraging” Wetzel, Fallon Morell has used her non-profit organization to serve as Green Pasture’s marketing arm, an action that is, at best, borderline legal for a non-profit organization.  

Although she trusts her own anecdotal evidence, Fallon Morell has summarily dismissed hundreds of anecdotes and clinical case studies from consumers who believe they were harmed by the product. She has castigated people who have been sickened or even died from the product for the “stupidly” of taking too much even when those amounts were the doses she recommended to people for years. To read my 2015 blog on this topic, click here.   

Today Fallon Morell continues to discount reports of people who have become chronically ill or died from heart disease, cancer and pulmonary embolism, even when those people have reported clear cause and effect through stopping and starting the product and with “before and after” lab tests. Now that the product has been on the market for more than ten years, this list of victims is growing. In addition to the death of Dr. Ron Schmid ND and hundreds of people reporting heart arrhythmias, we have multiple reports of glioblastoma and other cancers cropping up in the real food community among people who have regularly consumed that product either at high or lower doses.

Given that Fallon Morell has chosen to introduce the topic of her own health, it’s fair to point out here that in the ten years FCLO has been on the market, she has gained a considerable amount of weight — well past the one dress size she considers appropriate for older women. Many doctors and health practitioners have noted that she also shows signs of chronic inflammation. As for her eyesight, it may well have improved thanks to FCLO, a product that lab testing shows to contain modest levels of true Vitamin A.  

With human subjects, it’s almost impossible to prove cause and effect with chronic illness. Many other dietary and lifestyle factors could be in play. Correlation does not equal causation. However, the FCLO connection is sobering and precautions are warranted. As I reported in Hook, Line and Stinker, experts at leading marine oil laboratories reported the Free Fatty Acid  levels in FCLO to be the highest they’d ever seen in a fish oil or fish liver oil product. High Free Fatty Acid levels in lab testing indicate advanced product breakdown and extreme “end-stage” rancidity. FFAs have been linked to cancer and other serious disease in multiple peer-reviewed journal articles, articles that Fallon Morell has chosen to ignore in favor of David Wetzel’s claim that his oil comes “predigested” and can only be beneficial. 

Science does not support the opinions of Fallon Morell and Wetzel. Virtually all fats and oils in the plant and animal kingdoms start out in the triglyceride form, in which three free fatty acids are attached to a glycerol backbone. As the oils start to go rancid, the fatty acids begin to break free in a process called “lipid hydrolysis.” The percentage of TAGs (triacylglycerols, the term for the most prevalent form of triglycerides) then decreases and the percentages of DAGS (diacylglycerols) and MAGs (monoacylglycerols) increase.

According to independent marine oils expert Anthony P. Bimbo, the allowable limit of Free Fatty Acids (FFAs) for crude fish oil is in the range of one to seven percent, but typically at two to five percent. The percentage of Free Fatty Acids in FCLO is higher — much higher. The data shared in Hook, Line and Stinker revealed Free Fatty Acids in one sample at 16.2 percent and in another at a whopping 40.10 percent. Green Pasture’s own test data (as posted on its website in 2015) also came in high at 19.2 percent and 25.3 percent.


Fallon Morell often speaks of FCLO being the “most shelf stable” cod liver oil available.  In the informercial, she asks us to consider the question of why FCLO is so stable and says: “We think it’s phenols created during the fermentation process.” 

The reason FCLO is so stable is that it has reached end stage rancidity. It has reached the point where its traditional use in Norway was to paint houses or varnish furniture. For my discussion of phenols, see below.


Host Hilary Gore asks “is FCLO diluted with vegetable oils?”  And Fallon Morell responded: “The accusation that Daniel made was Green Pasture was adding trans fats. First let me say, All marine oils contain trans fats produced by fungus in the ocean that the fish feed on.  And why should we be surprised.  All animal fats contain trans fats too.  We know that the trans fats in dairy are beneficial .  .  .  We don’t know anything about trans fats in CLO or fish oil but they are natural and it is not a sign that it is vegetable oils added. In fact we’d know immediately if these were trans fats from vegetable oils because we’d find a lot of these rancid breakdown product and we didn’t find any.”

Fallon Morell is right when she says “we don’t know anything about trans fats in CLO or fish oil,” but wrong when she claims they are “natural.”

In 2015 a leading Norwegian cod liver oil expert reviewed the data on FCLO’s fatty acids provided by a respected laboratory. He pulled no punches when he wrote: 

“No authentic raw or mildly processed cod liver oil will contain trans fats. There should also be none present if the cod liver oil is mildly refined. The presence of trans C18:3 indicates that another oil has been added to this oil. This other oil must obviously be in sufficient quantities to detect the presence of these trans fats.”

 In the unlikely event that research ever shows 18.3 trans fats produced by fermentation by fungi or microbes, Green Pasture is not off the hook. Why, after all, would anyone want to take a fish liver oil that contains 18:3s identical to those found in partially hydrogenated vegetable oils? These are the types of trans fats linked through thousands of studies to cancer, heart disease and many other health problems. The National Academy of Sciences Institute of Medicine has concluded that the only safe level of such trans fats is zero. The 3.22 percent trans fats in FCLO exceeds the 2 percent limit allowed in food and supplements sold in Denmark and other European countries.

For a full discussion of Fallon Morell’s codswallop re trans fats — including a weak argument made on her behalf  by Chris Masterjohn PhD — read my blog here.

Fallon Morell’s statement that “we’d know immediately if these were trans fats from vegetable oils because we’d find a lot of these rancid breakdown product and we didn’t find any” is correct. The reason she “didn’t find any” is because she has purposely chosen laboratories where she knew the technicians would neither seek nor find the products of end-stage rancidity. 


Fallon Morell asserts that FCLO is high in phenols similar to those found in extra virgin olive oil.

It’s understandable that Fallon Morell would like to find phenols in Green Pasture Cod Liver Oil given that the phenols found in fresh extra virgin olive oil serve as antioxidants and also contribute to the peppery “burn” characteristic of a true olive oil. Phenols — if anyone could actually find them in an unadulterated cod or pollock liver oil— could thus explain two major problems associated with the FCLO: its rancid brown color and the fact that so many consumers have reported a burning in their throats. 

However, the likelihood that phenols similar to those found in extra virgin olive oil would naturally appear in Green Pasture, or any other fish liver oil, products is remote. With few exceptions, phenols are found in plant foods. Yes, polyphenols such as the secoiridoids and phlorotannins appear in fish that eat large quantities of algae. But the problem is this: cod do not eat algae. Nor do pollock, an important point given that DNA testing in 2015 showed Green Pasture’s arctic cod livers to be Alaskan pollock. Although the feeding patterns of cod and pollock differ somewhat, both are “generalist predators” that feed on a wide variety of fish, invertebrates .  .  . and even their own young.  (Yes, they are cannibals.)  

If phenols are found in FCLO, they almost certainly have been added.


Fallon Morell states “I’d like to be able to say there are a hundred companies making a hundred fermented cod liver oils. I am not trying to support one company.”    

The reason other companies have not moved into this niche is obvious: Marine oil experts agree that the product is unsafe and rancid based on taste, smell, color, texture and laboratory analysis. In 2016 Randy Hartnell, owner of Vital Choice Wild Seafood and Organics, traveled to the Canary Islands to attend a conference organized by the Global Organization for EPA and DHA (GOED). He talked to several company representatives who told him they had investigated the idea of fermenting cod liver oil after noting the profits of the Green Pasture line. However, all dropped the idea after finding it to be the most rancid oil they’d ever tested, and said they wouldn’t give that product to a dog.

For full detailed discussion and references, read Hook, Line and Stinker: The Truth about Fermented Cod Liver Oil and the blogs listed below.   Pressed for time? Learn key points from the Infographic. 

The Truth about FCLO Infographic 

Fermented Cod Liver Oil: Still on the Hook

Will the Real Dose Stand Up?

The Most Shocking Finding: Trans Fats  

Legacy of a Health Warrior 

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