#Consumer Affairs
USDA and the Almond Board of California
United States of America

Please post a link to this petition on your websites. Thanks!

1) USDA MANDATE MADE WITHOUT HEARING PUBLIC: As of September 1, 2007, all raw almonds in North America are being pasteurized due to USDA mandate. This mandate came when the Almond Board of California requested it to the USDA. Before a decision like this is ever made, there is a window of time for the public to be heard on the subject; however, in this case, the Almond Board moved so quietly and behind the scenes, that the public missed the opportunity for their voices to be heard. UPDATE: WORD IS, THERE HAS BEEN AN EXTENSION ON THIS MANDATE TO MARCH 2008. HOWEVER, IT IS ONLY BECAUSE THE INDUSTRY DOES NOT HAVE THE PASTEURIZATION PROCESSES IN PLACE. WE WANT TO REOPEN THE DISCUSSION FOR PUBLIC COMMENT ON THIS ISSUE.

2) FALSE LABELING: These almonds will continue to be labeled as raw. The USDA and the Almond Board believes that labeling them as pasteurized will only "confuse consumers."

3) CARCINOGENIC PASTEURIZATION PROCESS: The process for pasteurizing almonds involves the use of carcinogens known to be far more dangerous than the two outbreaks of salmonella that have occurred in almonds in the last 150 years.

4) DETRIMENTAL COST IMPACT ON THE SMALL AND ORGANIC ALMOND FARMER: Pasteurizing almonds will have a detrimental impact on the small and organic almond growers of California who will not be able to cost-effectively implement a pasteurization system and stay in business.

5) DETRIMENTAL IMPACT ON RAW FOODISTS AND OTHER HEALTH ADVOCATES: Pasteurizing almonds will have a detrimental impact on health advocates and a growing movement of raw foodists. They maintain that living and raw foods are not only essential to a long life with vitality, but that raw almonds are a large and important staple of a 100% raw diet. The fats, proteins and enzymes in these almonds and other nuts are critical to maintaining their healthy diet choices.

Initial Reason for Pasteurization Request:
The Almond Board of California requested the mandate to avoid any potential legal ramifications in their future. They were concerned about two outbreaks of salmonella that occurred in the last 150 years (one in 2001 and one in 2004). In both cases, the almonds in question were processed in large manufacturing sites. No organic almonds grown by small farmers in the area have ever caused a problem.

The pasteurization process that is in place employs the use of a highly toxic and carcinogenic substance that was once used as racing fuel. It was found to be too dangerous for race cars so it is no longer used, but it is ok to spray it all over our almonds. This substance is called Propylene Oxide. Propylene Oxide is outlawed for food use in almost every country but the United States.

In addition to using Propylene Oxide to pasteurize one of nature's best natural foods, a steam and heat process will be involved that will essentially break down the living organisms in the almond, turning it from a "raw and living food" to a "cooked and dead" food.

Health advocates and especially raw foodists take issue with this mandate because the integrity of the almond-infrastructure will be severely destroyed. Raw almonds have living enzymes that are known to cure and prevent disease such as heart disease and cancer.

Small and local farmers of this important California heritage will be impacted most. Implementing a pasteurization system is too costly (approximately $.5 to $2.5 million dollars). Mandating this system will effectively drive the small organic farmer out of business. Consumers will be left with non-organic almonds that are processed in large manufacturing plants, heated, cooked, steamed, and sprayed with a carcinogenic substance that is outlawed for food use in almost every country but the United States.

Consumers no longer have a choice to eat the almonds they want, because they are not being told that the almonds they are eating are pasteurized. In fact, are now being misled by false labeling that states that the almonds are raw.

For more info, please go to: http://www.cornucopia.org/almond/Almond_News_Release.pdf

To the USDA: Please reopen the discussions on your recent mandate for pasteurization of all raw almonds. The decision was made before anyone had a chance to find out about it and comment.

My issues are:

1. False Labeling -- current mandate says that all almonds will continue to be labeled as raw which is misleading to the public. There is absolutely no reason that pasteurized almonds cannot be labeled as such, other than the small financial impact of reprinting almond packaging. Perhaps the Almond Board is afraid of losing money by turning away consumers with words like "pasteurized." Don't underestimate the public! We are not confused by the difference between big words like "pasteurized" and "raw."

2. Healthy Food Choices Taken Out of the Hands of Consumers -- I want to be able to choose between truly raw (and organic) almonds and pasteurized ones. A very reasonable proposition has been put on the table over and over again. Simply establish two lines of almonds: Pasteurized and Raw. There have only been two outbreaks of salmonella since raw almonds have been cultivated for public purchase. In both of those cases it was due to poor handling by large almond factories, NOT at the small, organic-farmer level. There have been many more cases of salmonella outbreaks in chicken, beef, and a handful of produce. Yet, the government cannot control a few unfortunate incidents that are bound to happen everywhere. Your efforts to "protect us" are appreciated, but misguided. All we ask is that you give us the choice and hear our voice on this subject again.

3. Carcinogenic Pasteurization Process -- The very process that you believe is going to protect us is likely far more harmful than the two cases of salmonella outbreak in question. Propylene Oxide has been outlawed for use in food by almost every other country. Why would you mandate implementation of a pasteurization process that has far more health ramifications than the small health concerns you are trying to protect the public from? This needs to be thought through, and I believe that the opportunity for intelligent discussions on this topic should be reopened.

A Message To the Almond Board of California: I believe you have gone behind the backs of consumers to protect your own interests. Clearly, your only objective was to protect yourself from lawsuits. There is not one press release on your site that shows when you originally requested the mandatory pasteurization process. The first press release on the subject appears to be on August 20, 2007 -- one week before the September 1, 2007 mandate. By then it was obviously too late for consumer comment. These disingenuous actions are thinly veiled. Because of your quiet actions to petition the USDA to protect you from potential lawsuits, you have jeopardized the integrity of one of California's greatest heritages -- the California Almond. You have jeopardized the livelihood of the small almond growers of California who offer top quality and organic product. You have taken CHOICE out of the hands of consumers. You have been assigned to represent California almonds, yet it would seem as though you have no idea what almonds are. Perhaps you have forgotten about the health benefits that you so proudly announce in press release after press release on your site. You do not seem to know the difference between raw, roasted, cooked, steamed, processed, heated, sprayed and pasteurized almonds. If this is the work you do, I do not believe you should be representing California's great heritage. If you do not work hard at undoing the damage you have done by selfishly rolling out a toxic pasteurization process on the public; if you do not at least find a way to allow truly raw almonds to remain available to consumers and LABELED correctly, I predict a consumer backlash that far outweighs any potential lawsuit from a rare outbreak of salmonella. After the numerous petitions that you consistently ignore, you may be seeing large-scale lawsuits and boycotts next. Ask yourself these questions: How many pounds of raw almonds are purchased by naturalists, health advocates and raw foodists every day? What market share to they represent in this industry? Where will they go now for their almonds? What financial impact will that have on the California almond industry? Will you be responsible for huge financial losses in the industry, and more importantly, will you be held accountable? If you don't already know the answer to these questions, then someone over there has not done their homework.

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The Maintain the Integrity of Our Raw Almonds petition to USDA and the Almond Board of California was written by Julie Wilson and is in the category Consumer Affairs at GoPetition.