Curveballs: have the dangers to young arms been exaggerated?

Mark Hyman reports in the NY Times on two new studies:
[They] evaluated more closely than before the effects of curves on young arms [. . . and . . . ] compared the forces across the elbows of pitchers as they fired fastballs and curves. [. . .] Each study concluded that curves are less stressful than fastballs and, based on the data collected, contributed little, if at all, to throwing injuries in youth players.
I don't buy it, partly because of this bit from later in the article:
[Dr. James] Andrews cited several limitations of the study. The fact that it was conducted entirely in a lab also needed to be considered, he said. Under game conditions when youth pitchers are fatigued, Andrews suggested, curves could be dangerous.

“I just operated on one kid this morning,” he said. “At age 12, he tore his ulnar collateral ligament in two. His travel ball coach called 30-something curveballs in a row. He became fatigued. Then he threw one that snapped his elbow.”
Mark wrote an excellent article but the headline (written by a someone else presumably) was simplistic and misleading:
Studies Show That the Curveball Isn't Too Stressful for Young Arms

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