I, Jerome A. Lackner, M.D., hereby declare: I am a physician, licensed to practice in the State of California. I have practiced for twelve (12) years. My practice is devoted to internal medicine. For over five (5) years I practiced medicine intermittently in Delano, California. During those five (5) years my patients were the farmworkers of that agricultural area.

I am thus quite familiar with the tool used in agricultural work called the "short-handled hoe". I am likewise familiar with the postural position the farmworker must be in to use such a hoe.

There is no question in my mind that the use of this barbaric instrument, which is designed to increase the accuracy of hoeing and weeding at the expense of human health, is a physical, emotional, and spiritual detriment to all those who must earn their living by its use.

Furthermore, there is no question in my mind that the severity and frequency of the back disease among field workers exceeds that in other populations. The causes for this excessive frequency and severity are multiple and include poor nutrition and long hours among other factors. Prominent among these factors is the use of the "short-handled hoe" and other forms of prolonged stooped labor.

Any reader of this declaration who doubts the veracity of these observations is invited to test the effects of this instrument of torture on his own body by spending six to ten hours in its use. I am certain that if those who have the power to set health standards and working conditions for farmworkers would spend a day working in the fields with such a hoe in their hands we would see the speedy abolition of this insalubrious anachronism.

I declare under penalty of perjury that the foregoing is true and correct.

Dated: August 23, 1971