Please copy the following sample letter (below the dotted line) and either paste into an e-mail or print/mail separately to USDA Secretary Mike Johanns.
IMPORTANT: Individualized letters are much more effective than copied template letters. If you have the time and motivation, we would encourage you to customize this letter. You can insert one or two lines as to why you feel this rule should not go into effect.
A very short handwritten note might even carry more weight!
Examples: I believe that uncooked foods, or “living foods,” offer substantial health benefits. I am outraged/saddened/disturbed by the fact that I will not be able to purchase truly raw almonds after September 1.
I am very concerned that I will no longer be able to know how my food was processed, and that “raw” will no longer mean “raw.”
If you are an industry professional (farmer, retailer, distributor, or manufacturer), it is important that you state this in your letter. You can do this below your typed name/signature and address.
Thank you for taking action in the interest of authentic and healthy food!
Mail to:
Secretary Mike Johanns
United States Department of Agriculture
1400 Independence Ave SW
Whitten Building – Suite 200A
Washington, D.C. 20250
Email:
TO: agsec@usda.gov
CC: kurt.kimmel@usda.gov
Michael.durando@usda.gov
……………………………………………………………………………
Dear Secretary Johanns,
As a consumer of raw almonds, I am very concerned regarding the final rule (7 CFR Part 981, Docket No. FV06-981-1 FR) amending the almond marketing order to require that all almonds be "pasteurized." As a citizen, I was not aware of the rule when it was proposed, and feel that my concerns, and those of others with a similar interest, were not considered.
The availability of raw almonds is important to me, and I regret the loss of freedom to purchase truly raw almonds.
I am also disturbed by the required misleading labeling that will allow pasteurized (processed) almonds to be labeled as “raw,” when they have undergone a chemical and/or heat treatment.
There are several concerns that I feel were not fully evaluated during the initial public comment period:
1. This rule will impose financial burdens on small-scale and organic farmers. The costs of the chemicals and heat treatments, in addition to the costs of extra transportation and reporting, will be disproportionally taxing on smaller producers. This is unfair since none of the reported salmonella cases in 2001 or 2004 were traced to small-scale or organic farms.
2. This rule does not address the dangerous and unsustainable methods of industrial-scale farms that lead to food contamination, nor does it adequately take into account the effect of pasteurization on almonds.
3. More research, conducted independently of the Almond Board, might show the direct link between industrial-scale farming and the contamination of the food supply, justifying an exemption based on scale for smaller producers.
4. One of the options for "pasteurization" is treatment with propylene oxide. This substance is classified as “possibly carcinogenic to humans” by the International Agency for Research on Cancer. Propylene oxide treatment of foods is banned in Canada, Mexico, and the European Union. And even organic almonds will undergo heat treatments. Only the Almond Board and its constituents have researched the pasteurization of almonds, reporting that there is no significant reduction in their quality or nutrition. Independent research in this area is necessary before universal implementation of this rule.
5. Considering the chemical and heat treatments, it is misleading to label pasteurized almonds as “raw.” Many consumers wish to purchase truly raw, unprocessed almonds. A reasonable alternative to the new rule might be to allow for and clearly label unpasteurized almonds, as is allowed with certain fresh fruit and vegetable juices.
I am aware that there was a formal 45-day comment period prior to the publication of the final rule; however, concerned consumers and other stakeholders, with the exception of almond handlers, were not aware of this proposed rule. Of the very few comments received on the proposed rule, none were submitted by consumers or retailers. This is a reflection not of our apathy, but our lack of awareness and the lack of transparency of the process.
I, as well as many other concerned citizens, feel that we were deprived of an opportunity to participate in the rulemaking process regarding an issue that is truly important to us. I am writing to request that the USDA postpone implementation of the almond pasteurization requirement and reopen the formal public comment period.
Sincerely,
P.S. Secretary Johanns, please forward this correspondence to:
Michael Durando
Chief of Marketing Order Administration Branch,
Fruit and Vegetable Programs, AMS, USDA
1400 Independence Avenue, SW., STOP 0237
Washington, DC 20250–0237
Kurt J. Kimmel
Regional Manager, Marketing Order Administration Branch,
Fruit and Vegetable Programs, AMS, USDA
2202 Monterey Street, Suite 102B
Fresno, CA 93721
Prior to signing the petition for keeping raw almonds raw with truthful package labeling, I had also pestered the Almond Board in CA. regarding this issue. Reason being that I found their website link from a newsletter, and California is the primary (if not sole) State that distributes Almonds to the remainder of the U.S.
Here is their letter back to me below: and now I am making up a polite rebuttal letter in response because they patronizingly , totally missed our point on this.
Dear Ms. _________:
We appreciate your comments and suggestions about the pasteurization of raw almonds.
The almond industry strives to provide consumers with a product that they can enjoy, that is safe, and that can benefit health. With consumers’ health and safety as its number one priority, the Almond Board of California worked with the United States Department of Agriculture to institute the pasteurization program. The purpose of this program is to ensure consumers are provided with safe, wholesome food products free from potentially harmful levels of unsafe bacteria.
You can be assured that pasteurized almonds are as nutritious and delicious as unpasteurized almonds. The almond industry invested in independent nutritional lab analyses of pasteurized versus unpasteurized almonds. Those tests did not reveal any degradation of the taste, quality or nutritional value of treated almonds. Pasteurized almonds are still nutrient dense, a good source of protein and fiber, an excellent source of vitamin E and magnesium, and still help maintain a healthy cholesterol level.
We understand there have been questions whether the industry pasteurization program has consumer labeling implications. These new industry regulations do not pertain to consumer labeling. Manufacturers and retailers will continue to determine how to label their products in line with FDA regulations.
We hope you will continue to enjoy almonds knowing that they are the same wholesome food that you have enjoyed for so long.
Sincerely,
The Almond Board of California
We appreciate your comments and suggestions about the pasteurization of raw almonds.
The almond industry strives to provide consumers with a product that they can enjoy, that is safe, and that can benefit health. With consumers’ health and safety as its number one priority, the Almond Board of California worked with the United States Department of Agriculture to institute the pasteurization program. The purpose of this program is to ensure consumers are provided with safe, wholesome food products free from potentially harmful levels of unsafe bacteria.
You can be assured that pasteurized almonds are as nutritious and delicious as unpasteurized almonds. The almond industry invested in independent nutritional lab analyses of pasteurized versus unpasteurized almonds. Those tests did not reveal any degradation of the taste, quality or nutritional value of treated almonds. Pasteurized almonds are still nutrient dense, a good source of protein and fiber, an excellent source of vitamin E and magnesium, and still help maintain a healthy cholesterol level.
We understand there have been questions whether the industry pasteurization program has consumer labeling implications. These new industry regulations do not pertain to consumer labeling. Manufacturers and retailers will continue to determine how to label their products in line with FDA regulations.
We hope you will continue to enjoy almonds knowing that they are the same wholesome food that you have enjoyed for so long.
"I appreciate your reply, but I still do not totally agree.
Yes, the minerals in almonds will remain intact, because 152 degrees of heat or chemical pastuerization will not effect minerals.
However, the molecular structure of the polyunsaturated and mono-unsaturated fatty acids is changed by heat from a flexible, bent shape that is easy for the body to utilize into a straightened form. This form is similar to the shape of the less-reactive saturated fatty acid and cannot be efficiently processed biologically because it is more stable and less chemically active, thereby clogging the metabolic pathways.
The fatty acids found in naturally occurring unrefined oils in nuts and seeds are more readily digestible and more beneficial to the body than those that have been heated to the point where their shape is dramatically changed.
And Last but not least, Heating also destroys the beneficial enzymes that are naturally found in the nuts and seeds . These enzymes, such as lipase, are needed to digest the fat. When nuts and seeds are roasted or the friction during grinding creates excess heat, the natural enzymes found in the nuts and seeds are destroyed, which forces the body to produce the necessary digestive enzymes and diverts energy away from producing enzymes that aid in rejuvenation of the body. Oil extracted from the seeds or nuts, even if cold pressed, has had many nutrients and enzymes removed or destroyed that would otherwise aid in digestion. With low-temp ground nut and seed butters, almost all of the nutrients, the fatty acids and the enzymes needed to digest them are kept intact while their delicious taste is enhanced.
So I still stick with my former opinion that you should set aside certain lots of organic or non-roasted almonds for NON pastuerization for the health conscious consumer and state so on the packaging so the consumer is "warned" that they are not pastuerized. Pastuerize all the rest , and you will keep ALL consumers happy. Then I will and many others will buy these almonds while everyone else will happily purchase the pastuerized version.
Thank you for taking the time to respond to my comments
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Online Petition to Keep Raw Almonds Raw! 
