The hazelnut is a classic Oregon icon—the state produces ninety-nine percent of the U.S. crop, valued at $63.4 million, and also exports hazelnuts abroad, most notably to Asian countries.1 Nut aficionados around the world herald Oregon’s hazelnuts as being high quality. The vast majority of hazelnuts are conventional, but a growing number of organic farmers are finding a foot hold in the market and are experiencing high demand for their nuts. Forecasts indicate that U.S. exports of conventional and organic nuts will increase at least seven percent in coming years.2 One of the reasons that Oregon is a leader in hazelnut production is that the state’s farmers and agriculture research centers have painstakingly breed blight-resistant varieties through trial and error for many decades. This diligent work yielded several hearty varietals that are now highly sought after both domestically and internationally.3 The Oregon hazelnut industry has eschewed transgenic modifications throughout this process, relying on traditional methods of plant breeding. Many view this as a prudent long-term tactic for the hazelnut industry, as many countries around the world will not accept imports of “GMO” or genetically modified products.4
Although Oregon’s hazelnut growers are cautious about producing genetically modified varieties, they have been slow to embrace the full range of organic farming methods. Approximately 28,000 acres of hazelnuts are planted in the Willamette Valley5 but organic acreage accounts for less than 200 of this total, though interest in organic hazelnuts is fast growing.6 However, several issues hinder the growth of the Oregon organic hazelnut market. For one, despite organic products becoming more mainstream—often in tandem with the adoption of “sustainability” measures—the additional costs associated with organic production still pose a considerable challenge to farmers and consumers alike, something the organic hazelnut industry feels acutely. (A pound of organic hazelnuts can fetch $12.)
The debate between organic and conventional crops is lively, but largely, conventional agriculture largely relies on federal subsidies, especially for U.S. commodity mainstays like corn, soy and wheat. As a result of these subsidies, products made from these crops do not reflect the true cost of the food, nor the environmental harms associated with the industrial agriculture system that produces them. As a result, consumers have grown accustomed to the artificially low prices they command and often balk at the higher prices that organic producers charge. The organic prices are a result of higher production costs, and the prices associated with environmental internalization. While some consumers are willing and able to pay for the “true” cost of food, many others either cannot or prefer to spend their money otherwise
Linda Perrine of Honor Earth Farms, the second largest organic hazelnut farm in Oregon, explains this dichotomy to customers at the farmers markets in Eugene, where she sells her nuts. The cost of Perrine’s inputs in terms of fertilization and pest management are at least three times higher than those for conventional growers. Further, since Perrine isn’t able to rely on chemical inputs like Roundup to kill weeds, she has to weed whack around the 3500 trees in her orchard, which leads to extra labor and diesel costs. In addition, organic growers pay more to process their nuts on top of their significantly higher production costs. Facilities that handle organic nuts require their own organic certification, the cost of which is passed on to the growers, at least in part. Further, it is more expensive to process organic nuts because they are not as uniform in size or as cosmetically sound as conventional nuts and therefore take more time to sort and shell.
In addition to the increased production and processing costs, other issues create challenges for Oregon’s organic hazelnut industry, such as: organic certification costs; inconsistent federal subsidies; “one-size-fits-all” food safety regulations; and the inability of Oregon’s organic hazelnut farmers to sell their nuts through WIC and Farm Direct, two programs that aim to provide low-income segments of the population with nutrition assistance. Each challenge will be discussed below.
1. Organic growers must become certified through the USDA’s National Organic Program (NOP),7 which can cost thousands of dollars. In the past, Perrine and other organic farmers in Oregon were eligible to have their organic certification costs reimbursed, at least in part, as per the NOP’s Organic Cost Share Reimbursement Program—a rare bit of assistance for organic growers in a sea of conventional commodity subsidies. The program relies on funding from the Farm Bill and unfortunately, starting in 2013, Oregon stopped participating in the program and organic farmers who want to maintain their certification must now do so entirely out of pocket.8
2. The “one-size-fits-all” food safety regulations for shelled nuts place exceptional hardships on organic growers. Outbreaks of Human Salmonellosis associated with the consumption of tree nuts (originally with almonds in California, but also with Oregon’s hazelnuts in 2009 and 2010) led to the implementation of more stringent food safety regulations for the nut industry by the FDA. The exact sequence of events leading to salmonella outbreaks from the consumption of hazelnuts is not well understood,9 though the outbreaks in Oregon were traced back to a conventional farmer-owned cooperative processor in Cornelius, Oregon.10
3. While food safety is certainly important, blanket regulatory approaches often do not take into consideration small farms, which frequently employ the most sustainable farming practices available. The food safety regulations promulgated by the FDA for the shelled nut industry mandate techniques considered toxic by organic growers and consumers, including irradiation and fumigation. Pasteurization can also be employed, but according to Perrine, many organic consumers and chefs demand raw nuts in order to maximize freshness and the nutritional profile of the nut. While safety concerns are obviously of critical importance, when organic farmers need to adhere to the same standards as large, conventional farms, they suffer direct economic harm. When similar regulations were imposed on California’s nut industry, many small organic almond growers went out of business.11 Oregon’s hazelnut industry was quick to respond to the outbreaks, and has implemented standards for both shelled and unshelled nuts that go beyond what the FDA requires.12 While this has been a further strain on the state’s organic hazelnut growers, the increased tracking and record keeping of the nuts in order to identify contamination sources, has enabled the organic growers to prove that they are not the problem.13
In fact, it might not be a problem with the nuts at all. The Cornucopia Institute, which promotes economic justice for family-scale farming, attributes many of the salmonella outbreaks in California and Oregon to contamination from large-scale industrial agriculture—a claim that was also made in the e-coli outbreak in the organic spinach industry in California.14 The institute believes that the FDA overlooks the primary sources of many of the fecal associated pathogens found on food—industrial agriculture and Concentrated Animal Feeding Operations (CAFOs). Highly infectious zoonotic pathogens escaping from these large-scale enterprises via transmission vectors such as air-blown dust, water, and run-off could actually be the sources of the disease-causing pathogens on nuts and other produce and the FDA should shine their light in that direction.15 Last summer the FDA requested comments regarding the assessment of risk of Human Salmonellosis and tree nuts, with the commenting period ending in December, 2013.16 Organic hazelnuts farmers and their supporters did submit comments, including raising concerns about escaped pathogens being the culprit. However, Oregon’s small organic hazelnut industry is unlikely to be heard over the roar coming from “Big Ag’s” well-heeled lobby.
4. The final policy challenge facing organic hazelnut farmers trying to sell their nuts directly to consumers at farmers markets around Oregon is the fact that the farmers cannot accept WIC and Farm Direct payments for their particular product. Unfortunately, WIC and Farm Direct do not allow nuts as part of their nutrition assistance programs—only non-organic peanut butter in 16- or 18-ounce containers.17 While it is understandable that the state seeks to control costs around these assistance programs, the fact that nuts and most organic produce are excluded from these programs while many “Big-Food” brand-name, non-organic products are included (for instance Post’s Honey Bunches of Oats),18 raises questions about the long-term sustainability of Oregon’s food policy practices.
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Notes
1 Agricultural Marketing Resource Center, Hazelnut Profile (last visited Feb. 1, 2014).
2 Id.
3 Feb. 11, 2014 Organic Hazelnut presentation by Jeff Olson, OSU professor and horticulturist at Friends of Family Farmers inFARMation event in Portland, Oregon.
4 Oregon’s wheat industry suffered considerable losses when a strain of GMO wheat was found in an Oregon field in the summer of 2013 and European and Asian countries immediately banned imports of Oregon wheat for fear of contamination and spread of GMOs in their countries.
5 Agricultural Marketing Resource Center, Hazelnut Profile, supra note 1.
6 January 28, 2014 phone interview with Linda Perrine, organic hazelnut famer, on file with the author.
7 USDA, National Organic Program (last visited May 8, 2014).
8 See ODA Agricultural Development and Marketing; see also National Organic Program (last visited May 8, 2014).
9 Federal Register Vol. 78, No. 138 July 18, 2013 at 42964.
10 Gretchen Goetz, Hazelnut Safety Improves in Wake of Outbreak and Recalls, FOOD SAFETY NEWS, July 12, 2012.
11 See supra note 6.
12 See supra note 3.
13 See supra note 6.
14 For more in-depth explanation of the phenomena of zoonotic pathogens typically associated with animal hosts contaminating fruits, vegetables and nuts see PLANT FOOD SAFETY ISSUES: LINKING PRODUCTION AGRICULTURE WITH ONE HEALTH (last visited May 8, 2014).
15 The Cornucopia Institute, Crushed Nuts/Rotten Apples “Pasteurized” Nuts and GMO Apples—Tell the FDA and USDA No, Dec. 6, 2013.
16 See supra note 8.
17 Oregon WIC Program Food List; see also WIC & Farm Direct Eligible Produce Guide (last visited May 8, 2014).
18 Id.
