The American Lung Association of California agrees that the proposed LBAM spraying appears to follow the principles of integrated pest management and to represent a less toxic alternative to insecticides.  However, the Lung Association is concerned that some potential risks remain with aerial spraying and urges the California Department of Food and Agriculture  (CDFA) to continue to carefully examine the effectiveness of non-spray pest control approaches to determine whether spraying is necessary. 

Concerns have been raised that some ingredients in the spraying may contain respirable particles and these concerns should be carefully evaluated.  Prior to a determination to begin LBAM spraying, the Lung Association urges completion and careful review, including outside peer review, of additional studies being conducted by state and federal  agencies, including  the U.S. Department of Agriculture, to further evaluate the toxicity impacts of the LBAM spraying. 

The Lung Association also recommends additional study of the particulate matter impacts of LBAM aerial spraying formulations.   Furthermore, the Lung Association agrees that an environmental impact report should be completed prior to any spraying, in order to further analyze health and environmental impacts of the spraying as well as alternative  pest control approaches, and to provide for meaningful public involvement in the decision.

In the case that spraying is conducted, the Lung Association urges CDFA to take the steps below to minimize any potential residual harm. The CDFA should ensure that all voices in the community are represented in their advisory task force and take special effort to listen to and work with those who are legitimately concerned about the spraying. 

The recommended precautions are:

 1) Provide substantial warning to residents in the area of the scheduled aerial spraying.  Advise people with lung diseases and groups with higher risk for lung health problems to stay indoors and to avoid exercising outdoors during the spraying and immediately afterward.  

In particular, these groups should be considered at risk, and should be encouraged to check with their physicians about specific steps to reduce their risk:

a)      Individuals with lung disease, including asthma and chronic obstructive pulmonary disease (COPD)
b)      Children under the age of 18
c)       Older adults age 65 and older
d)      Individuals with a cardiovascular disease, including coronary heart disease, stroke, hypertension, angina pectoris, and heart attack.
e)      Individuals with diabetes.

2)  The CDFA should institute ground-level monitoring during the eradication process to identify the presence and extent of respirable particles and health complaints.  This should include establishing a system to track and report health complaints, including use of clinical personnel who can respond to questions.  The CDFA should also provide regular reports to the community of the monitoring results.

 3) The CDFA should continue to explore and use where appropriate alternatives to aerial spraying, including ground-based spraying and non-spray methods of control. The CDFA should continue to avoid the use of pesticides.

Andy Weisser
Vice President
Communications
American Lung Association of California
P.O. Box 16400, Encino, CA 91416-6400
P: 818.703.6444
F: 818.703.6466

http://californialung.org