Latest CPSC Helmet Standard
    and US Fatality Trends

    by Thomas H. Kunich, Fremont, CA

    As of March 10, 1999 all helmets manufactured in the United States for use on bicycles or those marketed as "multi-use helmets" that could conceivably be used on a bicycle must pass the latest testing standards instituted by the Consumer Product Safety Commission. The standard - CPSC 16 CFR Part 1203 has been published in the Congressional Record.

    One of the most important items addressed by this standard is the printed warnings to be required on the helmet. Among the latter are:

    "(4) A warning to the user that the helmet may, after receiving an impact, be damaged to the point that it is no longer adequate to protect the head against further impacts, and that this damage may not be visible to the user. This label shall also state that a helmet that has sustained an impact should be returned to the manufacturer for inspection, or be destroyed and replaced."

    So it can be seen that even helmets that pass these so-called stringent standards can be damaged beyond use and this damage may not be visible. Given this, how is the average consumer to tell whether his new helmet is undamaged and usable from the store?

    "(5) A warning to the user that the helmet can be damaged by contact with common substances (for example, certain solvents [ammonia], cleaners [bleach], etc.), and that this damage may not be visible to the user."

    Again, the inability of this helmet to provide protection may not be visible to a user. To me, a standard that doesnít provide for some means of detecting a non-operational helmet is to all intents and purposes worthless.

    The impact testing, the most important piece of information that could be printed about the standard allows the tests to be accomplished in such a manner that no area receives more than a single blow. While it is plain why this is done, it most assuredly does not mimic the real world where a person falling off a bicycle may have his head bounce down the road several times before stopping. And in a vehicular collision there is the case where the head strikes the vehicle and the cyclist then falls to the ground again striking his head. In either case there is a sharp possibility that the impact to the helmet will be in the same region.

    The impact tests performed are virtually identical to the present Snell B-95 tests. While the Snell tests are the most stringent of the standards in use, there are plenty of reasons to believe that they are substantially below real world values. Moreover, the Snell standard and the 16 CFR Part 1203 standard contain not a trace of means for testing for limitation of rotational energy. Rotational accelerations are the most dangerous of all head injuries and, it is thought, account for the largest percentage of serious and fatal head injuries. There are also reasons to believe that the odd shapes being used in helmets these days add to conversion of linear impacts into the much more dangerous rotational impacts.

    Maybe more importantly, there is really no third party testing requirements. While the Snell standards may have been less than what would really be required, the testing was ongoing and helmets capacities to pass the standard were verified regularly. The 16 CFR Part 1203 requires certification-only testing to be performed by the manufacturers themselves.

    For instance:

    " (a) General Manufacturers, as defined in Sec. 1203.32(b) to include importers, shall conduct a reasonable testing program to demonstrate that their bicycle helmets comply with the requirements of the standard."

    Or, in effect, we must take the manufacturers word that the helmets pass the requirements and the only way of demonstrating that they donít is to undertake an extensive and expensive test series.

    In regards to all helmets and standards to this date it is important to realize that statistics available for countries and municipalities havenít demonstrated any positive effect after mandatory helmet laws have been enacted or even when voluntary use of helmets has risen to as high as 80%.

    See "Cycle Helmet Laws - Facts, Figures and Consequences", by Dorothy L. Robinson and "Is there Any Reliable Evidence That Australian Helmet Legislation Works?" by Bruce Robinson (no relation). Both papers were presented at The International Bicycle Conference, Velo Australis, Freemantle, October 1996. Also see the landmark study "Trends in Cycle Injury in New Zealand under Voluntary Helmet Use" by P. Scuffham and J. Langley, Accident Analysis and Prevention, Vol. 29, no.1, pp.1-9,1997.

    With Dorothy Robinson's work in mind I graphed the statistics available from the U.S. Department of Transportation, National Highway Traffic Safety Administration for pedestrian and bicyclists fatalities for the eleven years 1986 to 2000 to obtain the following:

      US Cyclist & Pedestrian Fatalities 1986 - 2000


    This chart shows that despite an increase in bicycle helmet use from near zero to 30% or more during the period, the trend in fatalities is virtually the same for both groups. Somewhat disturbing is that the rate of reduction in cycling deaths has not been quite as rapid as for pedestrians.

    There are studies that suggest that helmets can cause injuries as well as mediate their effects ("The use of helmets increases the size and mass of the head. This may result in an increase in brain injury by a number of mechanisms. Blows that would have been glancing become more solid and thus transmit increased rotational force to the brain." National Health and Medical Research Council , Football injuries of the head and neck, AGPS, Canberra, 1994.) There are even studies that show a significant, if not understood effect after mandatory helmet laws were passed in Australia. Robinson's analysis put it that "if similar numbers of child cyclists had been on the roads in 1993 as before the law, deaths and serious injuries to child cyclists would have increased by 21 per cent, compared with a decrease of 21 per cent for child pedestrians and 20 per cent for child road users in general."

    Therefore we need to seriously question whether helmet standards that require energy absorption values significantly below the known average collision speeds in the majority of fatal and serious accidents are not working counter-intuitively and are causing risk compensation above and beyond the small safety margin possibly added by helmets.

    It is the belief of the author that bringing standards to the helmet market is merely a preliminary to an attempt to force mandatory helmet legislation for all bicyclists. Federal standards mandating essentially worthless "safety" devices nonetheless make attractive legislative targets for representatives eager for some form to publicly demonstrate their zeal for the general health and welfare of their constituency.

    All governments need to get out of the habit of declaring public safety hazards where none can be detected by unequivocal statistics. Not just hard won freedoms are involved, but possible deaths through bureaucratic experimentation on the populace.

    Additional Notes: In the period of time from when this document was first written nothing has changed. If anything, the additional four years of statistics from the Department of Transportation show even more vividly that helmets have no detectable effect on fatalities.

    Copyright: Thomas H. Kunich 2002

    June 2002
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