On October 10, 2018, the New York State Liquor Authority caused a stir within the cane spirits community. The subject: A press release regarding Clairin Casimir, distilled in Haiti and imported to the U.S. by La Maison & Velier, is being voluntarily recalled due to the presence of lead. If you’re a clairin consumer, this naturally might be a cause for concern. Below, I’ve assembled some background information which helps put this recall into a broader context.

First, the basics: Lead is all around us, including in our food and water supplies. If enough lead accumulates in a person’s bloodstream over time, physical ailments including brain damage may result. Lead levels have a particularly bad effect on unborn children and during early childhood development.

Various U.S. government agencies, including the Environmental Protection Agency (EPA) and the Food and Drug Administration (FDA) have defined acceptable lead level thresholds. For liquids, they’re measured in micrograms per liter, or equivalently, parts per billion (ppb).

Per guidelines created by the Environmental Protection Agency in the U.S., public water sources should have less than 15 ppb. A 2017 Federal Alcohol and Tobacco Tax and Trade Bureau (TTB) publication comments on a proposed 300 ppb lead limit for wine, but does not a define a current limit. For context, In 1991, the New York Times reported that the BATF tested many wines at above the 300 ppb level. Even something as innocuous as grape juice has come under scrutiny, with the FDA setting a maximum lead level of 40 ppb.

With that in mind, let’s analyze the key parts of the New York State Liquor Authority’s press release, excerpted below:

MHW Ltd., a spirit’s [sic] wholesaler located at 1129 Boulevard in Manhasset, is voluntarily recalling brand name “Clairin Casimir,” a rum produced in Haiti by Distillerie Faubert Casimir Barraderes, as the product was found to contain elevated levels of lead.… [T]he Federal Alcohol and Tobacco Tax and Trade Bureau (TTB) analyzed the product for the presence of prohibited materials. The results of the tests indicated the presence of elevated levels of lead, in the amount of 138 parts per billion. … The estimated lead exposure from consumption of this rum product containing 138 ppb lead by women of child bearing age presents a health concern for this group, in addition to pregnant women.

It’s worth highlighting that the documents cites risks to a particular group of people: women of child bearing age, as well as pregnant women.

Further details of how the TTB and FDA came this decision comes from an accompanying document:

The blood lead level (BLL) in pregnant women should be no higher than 5 pg/dL to limit lead exposure to the developing fetus.… The dietary lead exposure level required for women of childbearing age (including pregnant or lactating women) to achieve a BLL of 5 pg/dL is approximately 125 pg/day. FDA applied an uncertainty factor of 10 to the 125 pg/day dietary lead exposure level to achieve a level of 12.5 pg/day dietary lead for women of childbearing age. The estimated lead exposure from consumption of this rum product containing 138 ppb lead by women of child-bearing age that are old enough to legally consume alcohol (F 21-49 years) is 17 pg/day at the 90th percentile intake level. This exposure is higher than the level of 12.5 pg/day for women of childbearing age.

This is a challenge to parse, but the brief synopsis is this:

The FDA calculated a maximum safe rate of lead intake per day for women of childbearing age as 125 picograms (pg)/day.

It then reduced that rate by a factor of ten to 12.5 pg/day – the “uncertainty factor” which I highlighted.

A woman drinking Casimir at reasonable levels would take in 17 pg/day of lead, which is more than the 12.5 pg/day value. However, 17 pg/day is far less than the 125 pg/day limit.

In short, it seems like the FDA is exercising an abundance of caution here.

In response to the Liquor Authority’s decision, La Maison & Velier released a letter, which includes the following:

Please take note that this recall is restricted to the US distribution only and does not affect the European consumption, where the levels are found to be within the parameters deemed acceptable by the European Board of Health. It is also important to note that this pertains to Clairin Casimir specifically, and not to the producers Sajous, Vaval and is not reflective of the category of Clairin as a whole.… …we have begun a thorough investigation of the equipment used at Distillerie Casimir in Barraderes, Haiti, to determine the cause and rectify the problem immediately. Testing and analysis is being done to confirm the source and we are working with Mr. Casimir to correct the problem. It is important to note that levels of contamination that have been raised by these health concerns are specific to Distillerie Casimir and not reflective of other producers, villages, operations in Haiti. … Going forward all liquid and distillation methodology will be deeply analyzed to prevent future exposure to contamination and to meet the guidelines specified by individual markets, in the case in regards to the parameters set by the FDA and TTB…. For any questions, please contact Kate Perry at k.perry@lamaisonandvelier.com

Is what we’ve learned surprising? Not terribly so: The older and smaller a distillery, the greater chance that it may have undiscovered ways for lead to creep in. Most distilleries don’t have giant on-site testing labs like the mega-distilleries do, and most governments aren’t set up to perform extensive lab analysis on every distilled spirit sold in their country. The U.S. has not even established a formal maximum lead level in wine, instead choosing to make decisions on a case-by-case basis. There is no specific TTB maximum lead limit provided for distilled spirits that I have been able to find.

What are we to make of this? It’s certainly an unfortunate situation for all involved. However, based on what I’ve seen so far, the U.S.-specific recall seems to be a matter of extreme caution focused on a particular set of consumers – pregnant women and women of childbearing age. Also, it’s important to remember that Casimir has not been recalled in the EU, as the company asserts that it’s within the parameters of EU law. It’s encouraging to hear of their commitment to deeper testing in the future.

I will update this story with any further relevant information as I receive it.