Your April 22 editorial, "U.S. No. 1 in firearm fatalities," claimed that if as many persons being killed on airlines or in "other industries or activities" as with guns, they "would be shut down immediately for a complete overhaul."

The April 15 issue of the Journal of the American Medical Association included a study that found that during 1994 between 1.7 million and 2.7 million people were hospitalized by adverse drug reactions (ADRs), while between 76,000 and 137,000 died.For comparison, there were 38,166 firearm-related deaths that year (in 1996, the number dropped to 34,234). To be consistent, you will ignore the benefits of drugs (just as you ignore the estimated 2.5 million-plus defensive uses of guns each year) and urge that the drug industry be "shut down immediately for a complete overhaul."

The editorial also compared the U.S. rate of gun deaths (14.24 per 100,000) with that of Japan, where guns are strictly controlled (.05 per 100,000). That culture, not firearms availability, is the main factor was evident in a study that found during a two-year period that only 21 of 48,695 arrests for murder and non-negligent manslaughter in the U.S. were of Japanese-Americans (1.04 per 100,000 Japanese-American population annually).

For that same period, the annual homicide rate in Japan averaged 2.45 per 100,000 population. As Florida State University criminologist Dr. Gary Kleck (a lifelong Democrat and member of the American Civil Liberties Union) notes in his recent book "Targeting Guns," "controlling for Japanese culture ... indicates that in Japan, where civilian gun ownership is virtually nonexistent and gun control laws are extremely strict, the homicide rate is 2.3 times as high as it is among Japanese-Americans living where guns are easily available and gun laws are far less restrictive."

Dr. Kleck also points out that in Britain, which also has fewer gun-related fatalities than does the U.S., the "rates of killings with hands and feet are also far lower than the corresponding rates in the United States, but no one is foolish enough to infer from these facts that the lower violence rates were due to the British having fewer hands and feet than Americans."

Robert W. Lee

Murray