Thank you very much Gavin for your response to my questions (which I have posted below as they are not apparent in your response). As a business owner, I am sympathetic that employees while meaning well, may not give accurate information and that this is often outside of the control of management. I also can appreciate your position regarding Cloud 9, although I am sure that in hindsight, it would have been a better outcome had 5P proactively just supplied the test results you had in your possession at that time.
I also understand that you have been reformulating your liquids continuously, and I assume that at least part of the reason was to eliminate potentially harmful ingredients. I applaud that. With regards, to GC-FID testing, it is also my understanding that IF pre-calibrated for the compounds being tested for, it can be at least if not more accurate than uncalibrated GC-MS. I also commend you for your investment in scientific research, on behalf of vapers and their safety. Regarding Mark Burton, I hope you can understand the concerns that prompted the question. I have no qualms with Mr. Burtons open letter as long as he truly believes that what he espouses is in the best interests of Vaping, and not just out of financial self interest. If he had further incentive in helping a friend, well, in my opinion there is a certain amount of valor in that as well.
I only have just a couple more questions, if you will be so kind as to further entertain my curiousity. Diacetyl is a naturally occurring compound, typically created as a by-product of fermentation. I believe the following to be true. It's how it possibly came to be in Eliquid in the first place, likely without any malice on the part of flavor makers. Acetyl Propionyl (Pentandedione) on the other hand, is not naturally occuring. It was initially used in this industry to replace Diacetyl to emulate the creamy qualities, in the mistaken belief that a potentially harmful compound was being replaced by one not potentially harmful. So on to the questions:
Acetyl Propionyl (Pentandedione) can not in any way occur in Ejuice without it being intentionally and knowingly added. By your own test results, 7 of your 10 liquids tested positive. One in particular was as high as 628 ug/ml. Is this added at your own facility, or was it present in flavorings purchased commercially? If commercially purchased, were you aware of these levels prior to marketing them? Do you hope to completely eliminate this compound in your line?
Thank you again for your previous response, and in advance for the answers to these new questions. I am satisfied with the responses you have supplied, and look forward to your responses, and complete transparency regarding these kinds of concerns from your company in the future. This has been my only cause for consternation in this matter regarding Five Pawns and I hope it serves as an example for all manufacturers to be pro-active in disclosing this information. What individuals choose to do with it, and the choices they make, is rightfully then theirs.
Thank you again and best regards.
- Did any employees of 5 pawns state to customers via phone, email or any other means that your products did not contain DA or AP?
Unfortunately yes, a small number of people received an inaccurate response to questions specifically relating to the presence of 2,3 butanedione (diacetyl) and / or 2,3 pentanedione (acetyl propionyl). After much investigation and having to scan all outgoing email from a customer service computer, we unknowingly found that responses sent prior to testing were being sent out between 5/27/14 and 10/19/15. Other than these small numbers of responses, we are not aware of any additional responses that occurred over the phone or otherwise. We feel terribly that these people were misinformed and have reached out to each and every one of them directly. Five Pawns has never advertised, marketed, or promoted the absence of these compounds in our liquids. We’ve only stated that we’ve never added diacetyl to our liquids. Unfortunately the diacetyl being detected was naturally occurring.
- Did Cloud 9 request test results prior to their own testing, and if so, what were they told exactly?
We did have a conversation with Cloud9 where they asked for our results. We explained to them that Five Pawns does not release testing results currently because there is no real standards for testing or validated monographs for testing. We did explain that we have different test from multiple labs that were coming back with different results depending on the methods used. Some were coming back with non-detectable levels of certain compounds, where others were showing varying amounts in PPM. Until there was a better understanding of these test results and what the true exposure issues could be, we felt it was unclear what any of this data meant and needed to understand why there are so many variables for testing. We have spent tremendous resources consulting with chemist and researchers to better understand our products and how we can better standardize these methods. While in the UK for Vape Jam, we tried repeatedly to meet with Cloud9 in person and they unfortunately weren’t interested in meeting with us.
- Has the formula for any of your liquids changed in the past year up until today, resulting in a change in levels of AP or DA?
Yes, and without customers even being aware. We have performed multiple recipe “tweaks” to our formulas over the past year. We’ve only done this when we’ve been able to evolve our products without sacrificing experienceand flavor profile.
- From what I have read about GC testing, GC-FID testing CAN accurately show diketone concentration but only IF the equipment was calibrated specifically for AP and DA prior to testing. Was this calibration done in the case of your GC-FID test results?
Yes, and we currently subscribe to the theory that GC/FID is a much more pinpointed test when calibrated to look for these components. Another poster stated they thought GC/MS would give even higher readings. Our CG/MS readings have always proven to show lower levels of detection than that of GC/FID.
- Does your company contribute monetarily to any scientific research relating to the safety of ingredients that you use in your eliquids?
Yes, we are currently funding ongoing studies which we’re excited to share in the not so distant future. We have financially contributed to a Dr. Farcilinos study, have funded e-liquid studies, inhalation studies, and white paper research on comparing occupational exposure of the compounds we’re discussing here as compared to vaping. We’re interested in what’s in the vapor vs. what’s in the liquid and what the exposures are with so many different variables in using the product.
- Do you, or any executive member of Five Pawns have any relationship with Mr. Mark Burton, the author of the letter below, that involves him with Five Pawns as a lawyer, investment banker, or consultant other than strictly in his role as "Co-President of Southern California SFATA"? An Open Letter to The Ecig Industry Regarding Accusations | The Vaping Militia
- Does Mr. Burton have any personal investment or financial interest in Five Pawns?
We know Mark Burton and consider him a friend. We also feel that Mark has a positive voice within the vapor industry. Mark has absolutely no affiliation with Five Pawns legally, financially, or in any kind of a consulting basis.
