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The FTC defines selling the maximum as basing your claims on optimum performance rather than what is most likely to occur. One thing that the MIA has left hanging for the plucking is their use of the two Snyder studies as the basis for that PR campaign saying that granite a cleanable and safe for food contact surface. I am going to post the critique of the second Snyder study, the one where they tested quartz, granite and marble. There are numerous flaws, one of which is enough to serve as a cause of complaint.
Two ways to go about this, as a regular Joe or Jill filing a deceptive trade practice complaint online with the FTC, or better, collecting $6,000 for the filing fee and filing a complaint with the CBBB, the Council of Better Business Bureau. Sixty days later, after both sides have had their say, they hand down a ruling. Most companies respect the CBBB and make the needed changes, or the CBBB can itself ask the FTC to take action, which the FTC tends to do.
If the company or organization doesn’t fight back, you get some of the filing fee back.
Here is a link to the CBBB, note the dating service that complained about a competitor and got fast results.
For this to work, it would need to be aimed at deep pockets, or at least vulrable pockets, like the MIA. I think they would fold. Start gathering the cash, send them a certified letter stating our objections and set a time line to comply. This thing can not get out of control like a lawsuit could, and is relatively inexpensive.
Individual stone sites that spread lies like “antibacterial granite” could be complained about one by one using the free FTC online form.
We started down the testing road to discredit their claims, yet forcing them to pull the studies and PR material would be just as effective, plus a major publicity coup.
Here is a little about the process.
I would tread lighlty on using the Snyder test as a basis. The stipulation of cleanability are actually not that well defined, but I will wait to read the critique and see what I might have missed.
Maybe I could call Stanley Steamer in to clean my tile and grout then sue their butts for bacterial contamination and retire…
Reuben, here is what I wrote on the 2006 snyder study. I have no reason to have an opinion on this person, might be quite personable and passionate about his work, yet there are so many reasons to question the validity of his work. I will allow that some of the issues in the previous study, funded by the Steel Alliance, were corrected.
What gives me pause is that if I am correct about there being flaws in the study, what could be found by someone with a better understanding of bacterial testing? I don’t begin to claim expertise, more like a more than average exposure to the principles.
Here is what I have written so far. Feel free to point out where it needs attention.
There are major holes in this article, the choice of materials, the lack of sealing both the top which would be normal in a home and the edges and back of the samples, the type of bacteria used for testing,the amount of cleaning solution , the type and quantity of disinfection solution, the method of collecting and measuring the amount of bacteria left on the surface, the time allowed for incubation of the samples before counting the surviving bacteria, the lack of info on the recovery solution, the claim that the test replicated real world sanitizing of home counter tops, the lack of detail allowing the test to be duplicated, and most importantly, the lack to subject this “study” to peer review by publishing in an acceptable trade journal.
So other than that, it was a fine study…….
Lets take the weak points one by one.
Uba Tuba and Dakota Mahogany are both pretty dense stones, hardly Representative of granites in general. They based the selection upon presences of pitting, which sounds would make it more difficult to pass the test, but in reality it makes it easier. The Pitts trap the bacteria, especially with the swab/sponge method of sampling. Had they picked at least one porous stone like Santa Cecilila or Kashmire White, it would have been a more reliable test. The inclusion of a marble is also a red herring, note the tiny size of the particles, .10mm, one of the reasons marble can be used in food prep areas like the Marble Slab ice cream chain uses. Resined stone is the more common stone available, yet they deliberately chose not to use resined materials. Why?
The lack of sealer is also a strike against this study, especially on the sides and back to prevent bacteria from being strained out of the recovery solution. One of the labs that is doing a proposal for us had mentioned this flaw in our proposed protocol, saying in their experience, not sealing the back and sides reduces the amount of bacteria collected from the samples, giving a false count in the end of surviving bacteria. In addition, in our own studies we found that unsealed stone did far better in bacterial tests than the sealed stone samples. Of course Uba Tuba usually isn’t sealed, and I doubt that Dakota Mahogany usually needs it.
Type of bacteria used in the Snyder study, well almost all the dangerous bacteria contaminate the carcass during evisceration of the carcass at slaughter, they don’t normally live in living tissue. They come from the digestive tract, and as such, are generally very acid resistant. Had this test been done competently, a acid resistant bacteria would have been used, not the benign marker bacteria used in this test. Completely different bacteria with different ideal living conditions, susceptibility to acid attack, different reproduction rates and so on.
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The amount of washing solution used was 5 ml of soap in two liters of water. Sample size is unknown, one of the reasons that the test can not be exactly duplicated to prove or disprove the study, but it is known that the contaminated a 9 x 9 inch area of the sample. That is .5625 square feet of sample. Average counter top is 75 square feet in area, so 75 square feet divided by .5625 = 133.33 units (comparing how many of these samples would fit on an average counter top). Five milliliters of soap x 133.333 units = 666.65 milliliters of soap, or 176110298 US gallons or 2.81 cups of Dawn dish washing soap per average counter top. Can you imagine cleaning up that much soap off a counter top? How much water would it take? Well, they tell us..
They used two liters of water along with that 5 ml of soap per sample. Two liters x 133.33 units = 266.66 liters or 70.44 gallons of water used on an average kitchen counter top. Can you imagine the state of your floor and cabinets? Plus the time to do all of this?
Oh, forgot the rinsing of the samples, add another 70.44 gallons of water to the amount used, so so far the total is 2.81 cups of liquid soap and 140.88 gallons of water just to wash and rinse.
Note at this point, the Dakota Mahogany has reached a 3.17 log reduction, far short of the five log reduction required by law. The Cambrian White marble has .achieved a 4.55 log reduction, which is closer, the Uba Tuba has almost made the 5 log reduction at 4.99 log, and only the Cambrian Snowden white has reached the 5 log reduction being at 6 log reduction. So just wiping the counter down with soap and water on a dish rag isn’t good enough. Only after the equiv lent of 140 gallons of water are used does the 5 log reduction happen. The chart was quite cleverly done, it appears that most of the materials passed on soap only, but doing the math proves otherwise.
The disinfection solution. Type of solution, the MIA has a page warning not to use vinegar on a stone till you know if it will harm the stone. They recommend stone soaps or plain soap and water. Why then wasn’t that used instead of vinegar? If you pay for the tests, you get to set the protocol, or how the test is performed. An unscrupulous organization will pick the method that makes their product come out on top instead of one that is real world and thus more fair.
Amount of disinfection solution was 8 ounces of .05% vinegar in 72 ounces of water, so we take the 133.33 units of sample in an average counter top and come up with 1066.64 fluid ounces of vinegar used, or 8.33 US gallons. Add the 72 ounces of water and you get another 74.81 gallons for a total of 83.14 gallons of sanitizing fluid per average counter top. Added to the wash water and you get 224.02 gallons used to sanitize an average kitchen.
Two hundred twenty four gallons…….. that is 6.22 average bathtubs full of water…. would anyone do this in their kitchen?
Method of collecting bacteria for the count.
Swabbing samples to collect bacteria, like this test used, just pushes them around or worse, into a pit or crevice. This was mentioned by the lab that was doing a proposal for us, in addition to the sealing of sides and backs of samples. They recommend a buffering solution be used to rinse off the bacteria for an accurate count instead of the swabs which in their experience will give a low count of actual bacteria present. This alone would invalidate the results of the test.
Incubation time allowed before counting. In general, the more dangerous bacteria will grow more quickly than less dangerous bacteria, one of the reasons why they are more dangerous, they can multiply faster than your body can destroy them. In most tests, the count isn’t started before two days, 48 hours, to allow all the dangerous bcteria to become countable. Wait past three days, and the benign bacteria begin to show up, as well as molds, which would make the count inaccurate. Counting at 24 hours again gave an inaccurate count of bacteria that survived washing and rinsing and then again on the sanitized samples. Poor science, justifiable only if you are pleasing a paying customer and have few scruples.
Lack of information about the recovering solution. The study mentions that one ml of the recovery solution was used, it doesn’t mention how many ml were used in the swabbing of the samples. As an example, if you have a high bacteria count sample, such as river water, you do sometimes do a partial sample, say 5 ml of a 100 ml sample. In that case, you would multiply the amount of bacteria grown from the 5 ml sample x 20 to come up with the real count of bacteria present on the sample. Snyder’s study did not mention this, and it is unknown how much or what kind of recovery solution were used. Some sort of sterile solution was needed to rinse out the stomacher (kind of like a blender) so as to recover all of the bacteria in the swab. This again points to a major flaw in the results of this test, inexcusable in any scientific study.
The Marble Institute claims that this study shows that granite is among the easiest to clean and sanitize, that it meets FDA approval for food contact surfaces. Were this true, the industry would have applied for FDA approval immediately, as well as NSF 51 rating, which is the UL label of many different materials. Even plumbing fixtures have to have a NSF 51 approval. Quartz and solid surface have it, but granite does not. No way the granite industry would miss any chance to get FDA or NSF 51 approval. Yet the MIA has used this study as part of a public relations campaign, including charts and posters touting the study as valid. Stone salesmen quote this study on their websites and on consumer forums as well, all the while being ignorant of the major flaws in the “study”.
The study in general lacks enough detail for another scientist to duplicate the study, one of the hallmarks of science, being able to disprove or prove another study by replicating it. The amount and type of buffering solution and the actual size of the samples used were missing, although other items used in the test were described in great detail. Nor was there any mention of who provided the samples that were used or who paid for the testing to be conducted.
One thing they did right was reporting that the Uba Tuba failed the sanitizing method test. They theorized that something in the stone neutralized the weak acid in the vinegar solution, resulting in no reduction past washing and rinsing. In fact, their numbers prove that the bacteria multiplied 31% in the time it took to sanitize and count the bacteria in test one of Uba Tuba and increased 253% in test two of Uba Tuba. The remaining test showed a 78% reduction caused by the vinegar solution, so apparently some sections of Uba Tuba are able to be sanitized with vinegar solution.
The finial major issue to this “study” is the lack of publication and review by peers of the scientist. Most studies are published, if they make it past the review board for the journal or magazine. Was there ever an attempt to publish? Was it rejected? Most professionals would have published the “study” for professional credit. Why was this one held back?
I believe that the author knew that this article didn’t rise to the quality of a study, and knew full well other scientists would savage the article for it’s numerous problems and inaccurate conclusions.
All in all, this was a very, very, poor test, written up as an article and sold to a stone industry association to be used for marketing purposes. The major poblems in this article again are , the choice of materials, the lack of sealing both the top which would be normal in a home and the edges and back of the samples, the type of bacteria used for testing,the amount of cleaning solution , the type and quantity of disinfection solution, the method of collecting and measuring the amount of bacteria left on the surface, the time allowed for incubation of the samples before counting the surviving bacteria, the lack of info on the recovery solution, the claim that the test replicated real world sanitizing of home counter tops, the lack of detail allowing the test to be duplicated, and most importantly, the lack to subject this “study” to peer review by publishing in an acceptable trade journal.
Few would use this article in good conscience in a marketing campaign.
Al,
I will take some time to re look at some of the points. I have some of the same questions you did and am going to see if I can have them answered. The main ones I had was clarification of the rinsing process. How I understood this is that the amounts were in the bowl only and that is what the dish cloth was put in, much like a mop bucket, did not actually use that much water on the samples. I feel the short count time is a fence type item given we are looking for just this species of E. coli and memory serves right will grow that fast and the type ager used should of aided the growth damaged cells recovered still in that time.I agree longer time for molds etc. but not what main point study was for IMO. I read the log reduction I guess different than you that it showed exactly as stated in the words, did not need vinager wash to get log reduction. Has the lab you talked to said anything about the dilution factor as to the key here?
In recovery process he did state a neutralizing buffer was used (international Bio Products, Redmond, Wa).
Did not see in the paper that I am looking at stating replicating homeowner situation. May be missed it, but I am planning re-reading the study again.
Used vinager as a personal choice, that I do know, tough to say much about that, except I would like to see if bleach creates any real difference. I do not think it will, but would hesitate to use it without knowing the stone. However I do not feel hurting the finish was the main objective here at all.
Non – sealing I see as a curious point, but like you did these stones show it.
I will stop for now re look at some of the points we are both questioning. I think this is a point where I can say this test could be slighly adjusted to be better and I am sending the question out to see if i get any answers. Oh. the peer reveiw thing I have to agree with as funny, but when others pay for test they control the results and what one can comunicate about them, if memory serves me correct on that.
Let me know if you want my further research posted here or sent directly to you.
Reuben
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