Date: Wed, 17 Jun 1998 21:35:40 -0400 (EDT)

STATEMENT TO THE NATIONAL ACADEMY OF SCIENCES'
	INSTITUTE OF MEDICINE'S
	COMMITTEE ON INJURY PREVENTION AND CONTROL
	by
	PAUL H. BLACKMAN, Ph.D.
	National Rifle Association

	Instead of attempting to refute shoddy research, I'll leave that to my 
handouts to the Committee, including a literature review by criminologist 
Gary Kleck (1995; see also Kleck, 1997) summarizing the findings that 
guns aren't the problem and that gun laws are unlikely measurably to 
impact it, but disarming the law-abiding would aid the criminal since 
guns are used more protectively than improperly, and I'll note  that 
criminal violence is reduced by increasing the certainty, severity, and 
celerity of punishment (e.g., Marvell and Moody, 1997).  I've also given 
the committee a variety of criticisms of the public health approach to 
firearms and violence (Blackman, 1997; Carlson, 1996;  Kates et al., 
1997; see also Kates et al., 1995), since that is the predominant 
substitute for the overwhelming criminological failure to make a case; 
even criminologists who dislike guns tend to posit mixed costs and 
benefits while discussing what would happen to crime absent guns, without 
determining how or if that could be achieved. (Cook, 1983 and 1991)
	I'll simply list briefly some of the failings of public health 
literature on guns and violence, and name a sampling of the researchers 
whose work exemplifies those failings.  If that looks a bit like an ad 
hominem approach, it certainly fits in where Christoffel's response to 
criticism aimed at the American Journal of Public Health was to suggest 
that the Violence Policy Center -- a good choice, I might note -- "dig up 
some dirt" on the critic.1  This is a field where the other half of ad 
hominem -- if the work was in a peer reviewed publication, criticism of 
the work must be invalid -- has helped a small group of criminologists 
get over the modest amount of scientific integrity they used to have and 
hypercriticize pro-gun research while mindlessly defending that of 
self-styled epidemiologists.  Such is some of the criminological work of 
Cook, Reiss, Roth, the National Academy of Sciences, et alles. (Satcher, 
1995; Tarlov et al., 1995; Reiss and Roth, 1993)
	Examples of problems with the public health approach include:  
	Dismissing research data and findings because the results were 
unappealing, as with the 15 surveys showing between 750,000 and four 
million protective uses of firearms annually: Cook, Hemenway, and others. 
(Cook, Ludwig and Hemenway, 1997; Cook and Ludwig, 1997; McDowall and 
Wiersema, 1994)
	Perhaps more seriously, keeping research data secret for years to 
prevent possible independent scrutiny, an act worthy of the opprobrium of 
all honest scientists: Kellermann, Rivara, et al. (Kates et al., 1995; 
Blackman, 1997; U.S. House of Representatives, 1996)
	Taking studies with acknowledged limitations and citing them ad nauseam 
as if they were definitive and nationally applicable:  Kellermann,  
Rosenberg, Mercy, and -- calling preliminary research definitive under 
oath -- Teret. (Kellermann, 1993a and 1994; Kellermann et al., 1991; 
Cotton, 1992; Butterfield, 1995b; Kellermann, 1997; Teret, 1993)
	Using numbers instead of rates for rhetorical purposes -- effective but 
unscientific: Satcher, Mercy, and lots of others. (Mercy, 1993; Satcher, 
1995; Cotton, 1992)
	Using words like "epidemic" for emotional impact without regard to its 
epidemiologic meaning, and sometimes in defiance of that meaning: 
Rosenberg, and Christoffel, who carefully misstated the meaning of 
epidemiology to exclude its real meaning while testifying under oath. 
(Rosenberg, 1993; Christoffel, 1996)
	Routinely glossing over problems of unreliable data; ignoring or failing 
to explain limitations of statistically significant but low odds ratios; 
glossing over massive odds ratios in favor of the alleged problems of 
small odds ratios; pretending, in community studies, that dissimilar 
communities are the same; and ignoring the limitations of inferences of 
matched case-control studies compared to general population controls:  
Loftin et al., Kellermann et al. (Loftin et al., 1991; Sloan et al., 
1988; Kellermann, 1993a; Kellermann et al., 1992 and 1993; Bailey et al. 
1997)
	Assuming the existence of guns in a home implies access to those guns:  
Lee. (Lee and Sacks, 1990)
	Assuming access implies problems, without making any effort to measure 
possible problems of assumed access:  Lee, Hemenway, et al. (Lee and 
Sacks, 1990; Weil and Hemenway, 1992; Hemenway et al., 1995; Hemenway and 
Richardson, 1997)
	Implicitly assuming that a risk factor is causal, where, in reality, the 
finding of risk factors is supposed to be followed by efforts to 
determine whether the relationship is causal, or to determine whether 
another factor explains both phenomena, etc.; and then assuming various 
untested measures will reduce the problem, if there is one: Kellermann 
and lots of others. (Kellermann, 1994; Lee and Sacks, 1990; Wilkinson, 
1993)
	Giving guns magical causal powers rather than look for underlying causes 
of gun ownership, thus having gun ownership cause homicides and suicides 
even when the guns were not involved in the deaths being studied: 
Cummings, Kellermann, and their colleagues. (Kellermann et al., 1992 and 
1993; Cummings et al., 1997)
	Assuming guns are the problem to be addressed even if far more serious 
risk factors are uncovered which dwarf the possible risks of guns, such 
as mental illness for suicide -- or which would undercut assumptions that 
regulation of guns seems a hopeful response, such as drug abuse for 
homicide and suicide:  Kellermann and his colleagues repeatedly. 
(Kellermann et al., 1992 and 1993; Bailey et al., 1997)
	Assuming gun laws curb crime on the grounds that things would have 
gotten worse without the gun laws when the data do not support the 
proposition, such as Loftin et al. regarding Detroit and Washington, 
D.C., and refusing to consider explanations others than guns or gun laws 
for changes in mortality trends. (O'Carroll et al., 1991; Loftin et al., 
1991)
	Assuming the "no guns" position is easily achievable, a preposterous 
concept borrowed from Cook; Christoffel suggested that America should 
emulate the model of Japan, where banning guns was a way, she noted, for 
the ruling class to prevent the rise of democracy. (Cook, 1991; Sacks et 
al., 1994; Christoffel, oral presentation at the annual meeting of the 
American Trauma Society, McLean, Va., May 1992)
	Assuming there is only  pro-gun bias, and that moneys from government 
and foundations are automatically pure and unsullied, despite 
pre-research anti-gun policy statements from the likes of Rosenberg and 
the CDC, the Joyce Foundation, and the California Wellness Foundation.  
In answer to a question, a CDC researcher told me that, yes, the 
ban-handguns decal on his briefcase was symbolic of objective science.2 
(Kellermann, 1993b)
	Pretending protective use of guns hasn't occurred unless there is a 
corpse: Kellermann, Rushforth, and others. (Kellermann and Reay, 1986; 
Kellermann et al., 1993; Bailey et al., 1997; Rushforth et al., 1974; 
Kellermann, 1997)
	Identifying self-defense killings as murders, and self-defense with 
criminal misuse of firearms:  Mercy, Kellermann, and most recently, 
public-health supporter, Zimring, who refers to self defense as a "social 
pathology."  (Kellermann and Mercy, 1992; Zimring and Hawkins, 1997) That 
demonstrates one of the serious problems of addressing violence as a 
public health rather than as a criminological issue: for the medical 
profession, the lives of saints and sinners are equally valuable, and 
public health sometimes sees a young sinner's life as more valuable than 
that of an older saint. (CDC, 1994a)
	Using data dishonestly, by describing as affecting children and youth  
events occurring primarily to 15-19 and 15-24 year olds,3 falsely 
asserting increases in gun-related mortality among women when the rate is 
declining, or pretending data are equally applicable regardless of 
socio-economic status, degree of urbanization, and others: Teret, 
Wintemute, Rosenberg, Mercy, and others. (Teret and Wintemute, 1983; 
Cotton, 1992; Mercy, 1993; Butterfield, 1994a; Koop and Lundberg, 1992; 
CDC, 1994b; Rosenberg et al., 1992)  And rarely, if ever, actually 
measuring trends or demographic variations in gun ownership, and relating 
them to data on gun-related violence or its absence.
	Misrepresenting the research of others.  Kellermann and Mercy are worst, 
citing sources which contradict what they're supposed to support; but 
it's common to cite sources which fail to support the statement for which 
they're cited. (Mercy, 1992; Kellermann et al., 1992; Sloan et al., 1988)
	Pretending no criticism of peer-reviewed publications is valid -- an 
attitude which can be dangerous when treatment of gunshot wounds is at 
issue: Journal of Trauma, AJPH. (Satcher, 1995;  Fackler, 1997a and 
1997b)  The CDC goes further and perceives scientific criticism as 
disloyalty warranting blackballing and censorship:  Rivara, Kellermann, 
Christoffel, Rosenberg. (Personal communications from CDC employees) The 
CDC sees encouraging shoddy research as important enough to defy 
congressional bans on such research and lobbying. (Federal Register 
62:12202, March 14, 1997)
	And, finally, rhetorically comparing gun and violence research to 
tobacco research, perhaps hoping to validate lousy research by citing 
research by others in a different field, which has been somewhat more 
successful: Kellermann, Rosenberg. (Butterfield, 1994b; Raspberry, 1994; 
Kellermann, 1997)
	Instead of further muddying the water, this committee should remove 
criminal violence and intentional injury from its purview.  Thank you.

	REFERENCES

Bailey, J.E., A.L. Kellermann, et al. 1997. "Risk Factors for Violent 
Death of Women in the Home." Archives of Internal Medicine 157:777-782.

Blackman, P.H.  1997.  "A Critique of the Epidemiologic Study of Firearms 
and Homicide."  Homicide Studies 1:169-189.

Butterfield, F. 1994a. "Teen-age Homicide Rate has Soared." New York 
Times, Oct. 14, p. A10.

Butterfield, F. 1994b. "New Tactics Used in Fight Against Crime." New 
York Times, Oct. 16, p. A25.

Carlson, T. 1996. "Handgun Control, M.D." The Weekly Standard, April 15, 
pp. 23-26.

CDC. 1994a. "Firearm-Related Years of Potential Life Lost Before Age 65  
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CDC. 1994b. "Homicides Among 15-19-Year-Old Males -- United States, 
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Christoffel, K.K. 1996. Deposition in case of E. Gaffney v. City of 
Chicago et al., No. 91 L 16289, Cook County Circuit Court, January 
26-February 2.

Cook, P.J. 1983. "The Influence of gun Availability on Violent Crime 
Patterns." Crime and Justice: An Annual Review of Research 4:49-89.

Cook, P.J. 1991. "The Technology of Personal Violence." Crime and 
Justice: A Review of Research 14:1-71.

Cook, P.J., J. Ludwig, and D. Hemenway.   1997. "The Gun Debate's New 
Mythical Number: How Many Defensive Uses Per Year?" Journal of Policy 
Analysis and Management 16:463-469.

Cook, P.J. and J. Ludwig.  1997.  Guns in America: National Survey of 
Private Ownership and Use of Firearms. National Institute of Justice 
Research in Brief, U.S. Dept. of Justice (May).

Cotton, P. 1992.  "Gun-Related Violence Increasingly Viewed as Public 
Health Challenge." Journal of the American Medical Association 
267:1171-1174.

Cummings, P., T.D. Koepsell, D.C. Grossman, J. Savarino, and R.S. 
Thompson. 1997.  "The Association between the Purchase of a Handgun and 
Homicide or Suicide." American Journal of Public Health 87:974-978.

Fackler, M.L. 1997a. "Wound Ballistics Literature Review #2." Wound 
Ballistics Review 3:36-43.

Fackler, M.L. 1997b. "Wound Ballistics Literature Review #4." Wound 
Ballistics Review 3:46-48.

Fingerhut, L.A. and J.C. Kleinman. 1989. Firearm Mortality Among Children 
and Youth. NCHS Advance Data No. 178 (Nov. 3). CDC National Center for 
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Hemenway, D., S.J. Solnick and D.R. Azrael. 1995.  "Firearms Training and 
Storage." Journal of the American Medical Association 273:46-50.

Hemenway, D. and E. Richardson. 1997.  "Characteristics of Automatic or 
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Kates, D.B., H.E. Schaffer, J.K. Lattimer, G.B. Murray and E.W. Cassem.   
1995.   "Guns and Public Health: Epidemic of Violence, or Pandemic of 
Propaganda?" Tennessee Law Review 62:513-596.

Kates, D.B., H.E. Schaffer and W.C. Waters IV. 1997. "Public Health Pot 
Shots: How the CDC Succumbed to the Gun 'Epidemic'." Reason, April, pp. 
24-29.

Kellermann, A.L. 1993a.  "Preventing Firearm Injuries: A Review of 
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9(suppl.):12-15.

Kellermann, A.L. 1993b. "Obstacles To Firearm And Violence Research." 
Health Affairs 12(4):142-153.

Kellermann, A.L.  1994.  "Do Guns Matter?" Western Journal of Medicine 
161;614-615.

Kellermann, A.L. 1997. "Gunsmoke -- Changing Public Attitudes toward 
Smoking and Firearms." American Journal of Public Health 87:910-913.

Kellermann, A.L. and D.T. Reay. 1986. "Protection or Peril?: An Analysis 
of Firearm-Related  Deaths in the Home." New England Journal of Medicine 
314:1557-1560.

Kellermann, A.L. and J.A. Mercy. 1992. "Men, Women, and Murder: 
Gender-Specific Differences in Rates of Fatal Violence and 
Victimization." Journal of Trauma 33:1-5.

Kellermann, A.L., R.K. Lee, J.A. Mercy and J. Banton. 1991. "The 
Epidemiologic Basis for the Prevention of Firearm Injuries." Annual 
Review of Public Health 12:17-40.

Kellermann, A.L. et al. 1992.  "Suicide in the Home in Relation to Gun 
Ownership." New England Journal of Medicine 327:467-472.

Kellermann, A.L. et al. 1993. "Gun Ownership as a Risk Factor for 
Homicide in the Home." New England Journal of Medicine 329:1084-1091. 

Kleck, G.  1995.  "Guns and Violence: An Interpretive Review of the 
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Kleck, G.  1997.  Targeting Guns: Firearms and Their Control.  New York: 
Aldine de Gruyter.

Koop, C.E. and G.D. Lundberg. 1992.  "Violence in America: A Public 
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Lee, R.K. and J.J. Sacks. 1990. "Latchkey Children and Guns at Home." 
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Loftin, C., D. McDowall, B. Wiersema and T.J. Cottey. 1991. "Effects of 
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McDowall, D. and Brian Wiersema. 1994.  "The Incidence of Defensive 
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Mercy, J.A.  1993.  "The Public Health Impact of Firearm Injuries." 
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O'Carroll, P.W., C. Loftin et al. 1991.  "Preventing Homicide: An 
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Rosenberg, M., P.W. O'Carroll and K.E. Powell. 1992. "Let's Be Clear: 
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Rushforth, N.B., C.S. Hirsch et al. 1974. "Accidental Firearm Fatalities 
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Sacks, J.J., J.A. Mercy, G.W. Ryan, R.G. Parrish. 1994. "Guns in the 
Home, Homicide, and Suicide." Journal of the American Medical Association 
272:847-848.

Satcher, D.  1995. "Gunning for Research." Washington Post, Nov. 5, p. C2.

Sloan, J.H., A.L. Kellermann et al. 1988. "Handgun Regulations, Crime, 
Assaults, and Homicide: A Tale of Two Cities." New England Journal of 
Medicine 319:1256-1262.

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Tarlov, A.R., P.J. Cook, J. Kelsey and M. Moore. 1995. Firearm Injury 
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Research on Firearm Injury Prevention that has been Supported by the 
National Center for Injury Prevention and Control, Centers for Disease 
Control and Prevention.

Teret, S.P. 1993.  Testimony, John Doe & Jane Doe v. Portland 
(Me.)Housing Authority, Cumberland County Superior Court, Docket No. 
92-1408 (December).

Teret, S.P. and G.J. Wintemute. 1983. "Handgun Injuries: The 
Epidemiologic Evidence for Assessing Legal Responsibility." Hamline Law 
Review 6:341-350.

U.S. House of Representatives. 1996. Hearings Before a Subcommittee of 
the Committee on Appropriations on Departments of Labor, Health and Human 
Services, Education, and Related Agencies, Appropriations for 1997, Part 
7, 104th Congress, Second Session, March 6.

Weil, D.S. and D. Hemenway. 1992. "Loaded Guns in the Home: Analysis of a 
National Random Survey of Gun Owners." Journal of the American Medical 
Association 267:3033-3037.

Wilkinson, F. 1993. "Gunning for Guns." Rolling Stone, Dec. 9, pp. 35 and 
39.

Zimring, F.E. and G. Hawkins. 1997.  Crime is Not the Problem: Lethal 
Violence in America. New York: Oxford University Press.
     1As the recipient of an open letter from Edgar A. Suter, M.D., 
Doctors for Integrity in Policy Research, K.K. Christoffel's Internet 
response in attempting to forward the message to her colleagues at 
Northwestern (July 16, 1997, 11:23:52 EDT) was: "Does this group have a 
web page; if so, does it list members?  Might VPC dig up some dirt on it."
     2Re: Rosenberg and the CDC: Fingerhut and Kleinman, 1989; Raspberry, 
1994; Butterfield, 1994b; Surgeon General's Workshop, 1985, pp. 52-54. 
Re: Joyce Foundation: remarks of Deborah Leff, Steve Teret, and its 
contributions to such anti-gun "educational" groups as Handgun Control's 
Center to Prevent Handgun Violence and the HELP Network.  Re: California 
Wellness: Explanation of its grant to the Rand Corp. by Rand's Peter 
Greenwood at the 1996 annual meeting of the Homicide Research Working 
Group, Santa Monica. Personal communication from CDC researcher at the 
Third National Injury Control Conference, Denver, April 1991.     
     3This has been politicized by the President, who espouses virtually 
all firearms proposals based on alleged utility in protecting children, 
an effort assisted by the CDC's politicization of firearms research and 
Mark Rosenberg's role both as head of that research and advisor to the 
presidential firearms working group. (Wilkinson, 1993)