Ground flaxseed and cyanide

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As calculated by another forum user above:

2000 calories of huel would mean ingesting 60.7g flaxseed in a day (…) there could be a dose as high as 13.36mg cyanide in 60.7g flaxseed, but probably more like 9mg (…)

This should be put in contrast to two things: the lethal dose, and the Acute Reference Dose (“ARfD”). While the lethal dose is rather self-explanatory, the ARfD is:

“An estimate (with uncertainty spanning perhaps an order of magnitude) of a daily oral exposure for an acute duration (24 hours or less) to the human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime”.

This seems like the most sensible number to use for you, as a producer of a food product.

Let’s start by considering the lethal dose. The lethal dose is about 0.5 to 3.5 milligrams per kg of body weight (source: EFSA). So here are two examples with some very basic math:

  1. Low-tolerance, low-weight individual: 0.5 * 50 kg = 25 mg lethal dose.
  2. High-tolerance, high-weight individual: 3.5 * 100 kg = 350 mg lethal dose.

With an assumption of a daily intake of ONLY Huel giving you 9mg of cyanide (up to 13), that is almost half of a lethal dose spread out over one day for a low-tolerance individual. However, lethal doses aren’t what food manufacturers should use for guidance. Back to the ARfD:

“An acute reference dose (ARfD) of 20µg/kg bw [body weight] was derived from an exposure of 0.105 mg/kg bw associated with a non-toxic blood cyanide level (…) this is 25 times below the lowest reported lethal dose.”

Let’s use the same example individuals as above:

  1. Low-weight individual: 20µg * 50 kg = 1 mg (1 000 µg)
  2. High-weight individual: 20µg * 100 kg = 2 mg (2 000 µg)

Please correct me if I’m wrong, but you are selling a product that if used as a total meal replacement (as you market it) means ingesting 9-12mg of cyanide per day when the European Food Safety Authority has established the Acute Reference Dose to not exceed approximately 1-2 mg per person, per day. Is this statement true, or false?