TWELVE OAKS MEDICAL TOWER
4126 SOUTHWEST FREEWAY, SUITE 1616
HOUSTON, TEXAS 71027

To whom it may concern:

As one of two board-certified medical toxicologists in Houston, I have interested myself in the recent proceedings against Robert G. Arwady. These involve alleged lead pollution secondary to metallic lead from bullets at the Southwest Tactical Training Range in Fort Bend County.

In my opinion, these proceedings are a gross Misapplication of both the environmental pollution laws and of the science of toxicology.

In addition to my prior work in heavy metal poisoning, I have reviewed the data collected from the site and the scientific literature on environmental lead poisoning and have come to the following conclusions:

First, metallic lead (e.g., in the form of lead Bullets, shot, etc) is not a significant source of environmental lead contamination. This is for several reasons. Among these are the relative inertness of lead in metallic form. Thus, for example, lead containers are used in sulfuric acid manufacture because of the relative insolubility and inertness of lead even to strong acids. This is combined with the relative insolubility and Immobility of lead salts in the soil environment. Thus, lead levels in water leaving the site were only 20 ppb.

Lead contamination and/or lead poisoning can come from a Variety of sources. These include such well known sources as the use of lead salts in ceramic glazes and paint chip ingestion by children. Such exposure involves actual oral consumption of non-metallic lead.

As for metallic: there have been a few cases of probable mild chronic lead poisoning secondary to retained Bullets following gun-shot wounds. These are rare enough to be “reportable”. They illustrate the relative non-toxicity of metallic lead even under the extreme conditions.

In my literature search of over 5,000 papers, I could find no reference to outdoor shooting ranges as significant sources of environmental lead. However, there are debatable questions about chronic inhalation of particulate lead in poorly ventilated indoor shooting ranges. Perhaps someone got things confused.

Thus, I must conclude that the proceedings brought against Mr. Arwady and his shooting range lack any scientific basis. I am willing to testify to such if necessary.

Please call me if you have questions or comments.