With Jason's agreement, I am publishing redacted copies of the emails between ourselves and the laboratory involved in the fiasco detailed in
another thread.
We both take the credibility of our businesses and the confidence our customers place in our products as matters of the greatest importance, and I'm sorry to say that that credibility and confidence has been understandably compromised for some, due the the slipshod and unscrupulous actions of the "experts" ,entrusted with this product testing.
I hope these emails will demonstrate that no confidence can be put in these supposed results, and we are already in discussion with another chemist to have these products properly tested (using blind samples and a more robust testing evaluation methodology.)
I think they speak for themselves, though the thread's open, if anyone wants to comment or ask for further clarification.
####
A summary of the emails detailing the F252 nicotine testing fiasco, sorted in date order: external links, personal and work email addresses and references to third parties have been redacted [
in bracketed italics ]. Unredacted copies are available in the event of subsequent legal action or formal complaint(s) to any of the relevant authorities.
v.1.12 - compiled 13:00 25th September 2010
-----Original Message-----
From: Jason Cropper <xxx@xxx>
To: Mike Ellicott <xxx@xxx>
CC: Peter Cole <xxx@xxx>
Sent: Sun, 19 Sep 2010 19:53
Subject: Re: Revised reports F252A, B, C and D
Hi Mike
Ive been looking at the reports more carefully the % of nicotine in the
Platinum Ice should be more like 5.4%.
this stuff is Uk produced and the guy who makes it is pretty red hot, i
would doubt it to be more than a third less nicotine in it than is meant
to be.
Can you double check it for me please..
Jason Cropper
Managing Director
Totally Wicked E-Liquid
The Electronic Cigarette Company
--- On Mon, 6/9/10, Mike Ellicott <xxx@xxx> wrote:
From: Mike Ellicott <xxx@xxx>
Subject: Revised reports F252A, B, C and D
To: Jason Cropper <xxx@xxx>
Cc: Donna Totally Wicked e-liquid <xxx@xxx>
Date: Monday, 6 September, 2010, 9:36
Hi Jason,
I hope this is what you wanted. Please delete the 4 draft
reports sent
earlier today.
Best Regards
Mike Ellicott
_____
From: Peter Cole [mailto: <xxx@xxx>
Sent: 19 September 2010 20:20
To: Jason Cropper <xxx@xxx>, Mike Ellicott <xxx@xxx>
Subject: Re: Revised reports F252A, B, C and D
hi Jason, hi Mike,
I don't have the paperwork immediately to hand, but I have the [
******* ]
and inhouse assays for all the nicotine batches we've handled in the
lab. Could you let me know the batch number of the PI that was tested?
(yellow label on the outer and inner 'juice' boxes.) And as a matter of
interest, was it PG, VG or PEG400-based? (not that that should affect
the assay.)
It should definitely be 5.4%, and since the mixing to final strength is
not a job I ever delegate, and I keep records of every batch, I'm pretty
sure it will be found to be when we sort this out. It should be as close
to target as the Virginian Gold.
I notice the product description in the report reads "
Totally Wicked
Platinum Ice E-mixing Liquid 3.6%" (instead of 5.4%,) so I wonder, could
the wrong column have got pasted into the report at this point or
something? (I've not seen the formatted report mind, just the plaintext
repost on the forum.) It's easily done when compiling and tabulating
results from raw data, I know.
regards,
Peter
_____
From: Mike Ellicott <xxx@xxx>
Subject: RE: Revised reports F252A, B, C and D
To: Peter Cole <xxx@xxx>, Jason Cropper <xxx@xxx>
Date: Monday, 20 September, 2010, 9:54
Hi Peter / Jason,
The cartridge tested showed signs of leakage of the contents which would
affect the results
The cartridge analysis will pick up the 'free' nicotine within the
cartridge tested. If some of the nicotine has been effectively removed
from the nicotine solution by 'adsorption' over time onto the cartridge
materials, then the analysis will not pick this up. It will only pick up
the quantity of nicotine which the customer is likely to see and benefit
from.
We do work for a Pharma company testing their medical wipes, and test
the wipe solution for free active ingredient. The amount of active
ingredient we detected was always 2/3 of the level that was in the bulk
solution as manufactured. They then switched from a crepe paper wipe to
a polypropylene wipe, and the wipe contents increased to the level found
in the bulk solution. In other words the polypropylene wipe did not
adsorb the active ingredient from the solution, while the paper wide
did.
Could you tell me the materials that the nicotine solution comes into
contact with please?
Black body?
Cap?
Felt material?
Could you supply a sample of the bulk nicotine solution to test, and I
will repeat with another cartridge?
Cheers
Mike Ellicott
_____
From: Peter Cole <xxx@xxx>
To: Mike Ellicott <xxx@xxx>, Jason Cropper <xxx@xxx>
Sent: Mon, 20 Sep 2010 13:02
Subject: Re: Revised reports F252A, B, C and D
hi Mike,
the only materials the Platinum Ice comes into contact with at this end are HDPE (in the MIPI 30L jerrycans our stock solution is delivered in and the 5L mixing vessels for the bottling machine,) Masterflex C-flex elastomer tubing in the mixing pumps, and MDPE tubing in the vacuum bottling machine, and the glass bottles we ship the finished product in (the cap seals for these are nylon I believe, or possibly HDPE.) They are the same materials we use to mix and bottle the Virginian Gold which was also tested, and we do perform random chemical assays of bottled product inhouse, which haven't so far indicated a problem with preferential adsorption in the processing.
I'm a little confused when you mention cartridges though, because we don't fill carts with Platinum Ice here (it's too strong for direct use, and is intended for end-user dilution,) but if it has been supplied to you in prefilled cartridge form, the standard industry filler is polypropylene fibre. I haven't seen any indication of problems with this material in other tests, but that's not to say it might not be an issue in some circumstances.
If you need any more clarification of our production methods and testing protocols, I'll be happy to oblige.
regards,
Peter
[
note: no request for further clarification was received after this email, no product batch number has been provided, and Peter Cole was mysteriously left off the mail list for all subsequent emails from Mike Ellicott ]
_____
From: Jason Cropper <xxx@xxx>
Sent: 20 September 2010 15:35
To: Mike Ellicott <xxx@xxx>
Cc: Peter Cole <xxx@xxx>
Subject: RE: Revised reports F252A, B, C and D
Mike
There seems to be some confusion here
I sent 4 x samples
1 Was an 11mg Titan Cartridge, this is the Product for testing you refer
to here.
The description of this is incorrect..You called it Med 14mg, its a
Medium 11mg.. Your results clarify this and the product packaging states
this.
The Second thing is the serious issue
The Platinum Ice
This product you called Platinum Ice 3.6% and your test sort of
reflected these figures..
However the fluid is 5.4% , it has been tested before and has always
reflected its correct %, its impossible that it cannot be around the
5.3% to 5.5% mark.
Mike I need this rectifying, these were not inexpensive tests but i can
see two glaring errors already.. My customers will have no faith in
these results unless you can supply a reason why the in accuracies are
present.
Thanks Mike
Jason Cropper
Managing Director
Totally Wicked E-Liquid
The Electronic Cigarette Company
_____
From: Jason Cropper <xxx@xxx>
To: Peter Cole <xxx@xxx>
Sent: Tue, 21 Sep 2010 21:22
Subject: Fw: RE: Revised reports F252A, B, C and D
FYI
Jason Cropper
Managing Director
Totally Wicked E-Liquid
The Electronic Cigarette Company
--- On Tue, 21/9/10, Mike Ellicott <xxx@xxx> wrote:
From: Mike Ellicott <xxx@xxx>
Subject: RE: Revised reports F252A, B, C and D
To: Jason Cropper <xxx@xxx>
Date: Tuesday, 21 September, 2010, 9:29
Hi Jason,
Report F252A does contain an error that was introduced by [
TECC ].
The letter that arrived with the samples stated 14 mg not 11 mg. So the
error on [
TECC ]'s behalf was transferred into the report. Please find
report F252A1 attached which replaces this report.
Report F252B does contain a typo error on my behalf. It should have
stated 54mg not 3.6%. Apologies for this error. The result of 37.0561
mg/g does appear lower than expected. I will organize a re-test of the
sample in duplicate. My explanation of why the result was lower than
expected was ill thought out as I momentarily thought we were talking
about cartridges and not a bottle as is actually the case. I will revise
the report F252B when this is complete.
Cheers
Mike Ellicott
_____
From: Jason Cropper <xxx@xxx>
To: Peter Cole <xxx@xxx>
CC: Mike Ellicott <xxx@xxx>
Sent: Thu, 23 Sep 2010 11:02
Subject: Fw: Complaint - Revised report F252B1
Hi Mike
Thank you for taking the time to double check it is appreciated.
I have copied Peter in on this reply as he manufacturers the fluids, i know he will be concerned that the nicotine content is low.
I will await his reply and liason with yourself.
Re the Cartridge Report can we ammend so it reflects accurately the fact you received and tested an 11mg Titan Cartridge not a 14Mg.
Thanks Mike.
Jason Cropper
Managing Director
Totally Wicked E-Liquid
The Electronic Cigarette Company
--- On Wed, 22/9/10, Mike Ellicott <xxx@xxx> wrote:
From: Mike Ellicott <xxx@xxx>
Subject: Complaint - Revised report F252B1
To: "Jason Cropper" <xxx@xxx>
Date: Wednesday, 22 September, 2010, 16:19
Hi Jason,
I have now taken the matter as a complaint within our quality system,
and revisited the work completed in August and repeated the work in
duplicate on the same sample in September (today).
The density of the sample at between 1.2020 - 1.2072 g/ml at 20oC would
appear to be consistent with the sample being an aqueous mixture of
glycerol with the glycerol content about 77%.
The Nicotine drug standard is clearly within expiry date (December 2010)
and has been supplied by an ISO 9001 accredited supplier (SIGMA), and
stored correctly between use. Only the Platinum Ice sample reported to
be 54 mg Nicotine/ml (or 5.4% w/v) has been analyzed apparently 'low' in
report F252B at 44.54 mg Nicotine/ml, while all other samples reported
at the same time appear close to where they should be at (reports
F252A1, F252C and F252D) across a range of cartridges and bottled
e-liquids.
The whole Nicotine Assay procedure has been reviewed, and the
specification checked carried out on the pipette used to measure out a 1
ml sample of the e-liquid, and all has been found to be satisfactory.
The Nicotine Assay procedure has now been repeated in duplicate on the
Platinum Ice sample, and reported in F252B1 (see attached report). Again
similar results have been determined. Results of 45.6 and 44.9 mg
Nicotine/ml have been determined. These results are consistent with the
results reported in report F252B.
Obviously this does not solve your problem of the results being lower
than expected.
Perhaps you could supply me with the recipe and formulation details so I
may look at reasons why the product does not meet the 54 mg Nicotine/ml
quoted on the packaging.
It may be something as simple as being made up as:-
* 45 mg instead of the 54 mg,
* The freebase nicotine USP is weaker than the specification
supplied
* Or something more unusual such as loss of continuity of volume.
By the latter I mean if you measure out by volume the ingredients, there
can be an anomalous change in total volume once ingredients are mixed. I
know alcohol-water mixtures suffer from this, but perhaps glycerol-water
mixture may also do? If you mixed 75 litres of Glycerol and 25 litres of
water, ideally you would get 100 litres total volume. But if solvent
interactions come into play you could get say 120 litres total volume
effectively diluting any ingredient within such as Nicotine?
I am confident that the low results are not related to our testing
procedures.
Best Regards
Mike Ellicott
_____
From: Peter Cole <xxx@xxx>
To: Jason Cropper <xxx@xxx>
Sent: Fri, 24 Sep 2010 1:04
Subject: Re: Complaint - Revised report F252B1
hi Jason,
"
Or something more unusual such as loss of continuity of volume.
By the latter I mean if you measure out by volume the ingredients, there
can be an anomalous change in total volume once ingredients are mixed. I
know alcohol-water mixtures suffer from this, but perhaps glycerol-water
mixture may also do? If you mixed 75 litres of Glycerol and 25 litres of
water, ideally you would get 100 litres total volume. But if solvent
interactions come into play you could get say 120 litres total volume
effectively diluting any ingredient within such as Nicotine?"
I'm sorry, but this is complete bullshit. Just how stupid do these people think we are? First preferential nicotine adsorption into hypothetical cart filler [
note: the sample was provided in a bottle, not a cartridge ], and now magically expanding ejuice? You cannot possibly expect to add 75 litres of glycerol to 25 litres of water, and end up with 120 litres of liquid! People's bottles would be spontaneously overflowing when they mixed with VG at home! Even in the most extreme cases of reactive or incompatible chemicals 20% volume distortion would be absurd, let alone glycerol and water (which are indeed the co-solvents in this case, as is listed on the bottles, but perfectly miscible.) This is just a load of alchemical mumbo-jumbo to pull the wool over people's eyes if there are awkward questions, and they probably get away with it most of the time, because most of their customers are businessmen, not chemists.
It's just one stupid excuse after another, and it's reflecting badly on the credibility of both our businesses. I inevitably have to conclude that they are bad liars, and too stubborn to know you should stop digging when you're in a hole.That they mistakenly recorded the product description as 36mg, and simply invented a figure close to it without bothering to test it at all really is the only explanation that makes any kind of sense to me.
Below they state: "
Only the Platinum Ice sample reported to e 54 mg Nicotine/ml (or 5.4% w/v) has been analyzed apparently 'low' in report F252B at 44.54 mg Nicotine/ml, while all other samples reported
at the same time appear close to where they should be at"
And yet in the copy of Report F252B you posted on the forum, "
The nicotine solution in the Totally Wicked Platinum Ice E-liquid has been determined as 3.71%". That's 37.1mg/ml. Not 44.54mg. Where on earth does 44.54mg come from? These people can't even lie consistently!
The first report claimed a figure of 37.1mg/ml, and now they're saying "
Results of 45.6 and 44.9 mg Nicotine/ml have been determined. These results are consistent with the results reported in report F252B."
These figures are self-evidently NOT consistent with the previous figure: 45.6 is not 37.1 - it's a long way from 37.1. In fact 45.6 is actually closer to 54 than it is to 37.1!
It bears all the hallmarks of an attempt to make it less incriminating by just splitting the difference, now they've been caught out (and a blatant attempt to rewrite the original measurement of 37.1mg reported in F252B - I assume in an attempt to make it look a bit less bad.)
This kind of slipshod approach to testing hazardous products could kill people (not just with ejuice, but with any toxic materials they're supposed to be testing and aren't,) and I'm not at all sure that, if this is the typical standard of their work, a complaint to Trading Standards, the RSC and/or UKAS wouldn't be well in order. If you've already paid them the money, I'd say you should demand a full refund, and take them to the small claims court if they won't cough up. And if you haven't paid them yet, I wouldn't give them a penny.
One thing's for sure - [
***** ] will never, ever use these guys for testing (there's been some ongoing discussion of setting up a formal scheme, and they were on the list of possibles.)
Before we send any more samples off for testing, I really think it would be a
very good idea to develop a blind testing methodology, where the lab (a different lab obviously,) doesn't get to see the product label at all or have any indication of the strength, but just a code number for the sample - they couldn't bullshit us then. And it would also be a
very good idea not to publish these reports on the website right away when there are such serious problems with the results.
I'll put together some proposals when I get time, so we can formalize and anonymize the testing procedures and stop this kind of malarkey ever happening again.
I'm compiling all our QA assay and batch records, all the [
********* ] Certs of Analysis for the nicotine, and detailing our methodology in case you need it. It would help if I knew the batch number (yellow sticker on the outer and inner boxes, or possibly on the bottle if it's an older batch, but they kept falling off, so we moved them to the inner juice box,) or it's going to take some time to compile all our VG PI records for the last year.
Sorry to rant, but I've so had enough of this. If you have to sue them to get your money back, or if you just want a second opinion (I'm right, but I certainly can't claim to be impartial,) I'm sure any of the professionally qualified and experienced chemists on the forums would be delighted to give you their expert opinion of this nonsense - they've had more than enough rope now. I think you already know [
******** ] and [
******** ], and there are several others out there who'd probably respond to a post requesting assistance. Show the reports and these emails to any of them (or ask for help on any chemistry forum [
example ],) and any chemist worth his salt will find them utterly laughable.
Well, I wrote this this afternoon, and thought "I'd better wait before I send this, just in case I calm down later and consider it, on reflection, to be a bit harsh."
On reflection - no, I just keep finding new reasons to be even harsher (though I've deleted a couple of unnecessary expletives,) so I'd better send it now before I really lose my temper with these clowns.
regards,
Peter
