Comment on the Rulemaking for Safety Standard for Bicycle Helmets

Jan. 20. 1998 BELL SPORTS R & D No. 0078 P. Z/5BELL Bm--.-_. - --___-- .- --- . -____ _ _. .---m19/l 198U. S. Consumer Product Scsfety CornmissIonc/o Scott HehProject ManagerDirectorate for Engineering SciencesWashtngton, D. C, 20207Dear sirs and Modoms,We CII~ very happy that the “Safety Standard for Bicycle HeIrnets” Isand difficultready to be fincllized and approved, ,If has been a Ionprocess. Scot Heh and his staff should be congrutulate3 for the effortthey applled dong the wa;y, We also thank the commission for provldInga process that Involved industry and consumer advocate groups.Moreaver, the ASTM bicycke helmet task group, which I chair, has beenallowed to be fnfuentlal in thfs procs The ASTTVI group is comprfsed ofIndustry, Independent test iab people, medical people, consumeradvocates, 01 Iawyer and, of course, Scott Heh. We hope that this newstandard Is implemented as qutckly as poss!bie.However, there Is one chunge In this last dtcrft standard that we stronglyoppose: The change of test head&m mass to 5 kg for Infants/t&d&s. 1hove been a strong advocate of Iower headfotm mass fof yeurs andfeei #hat I have mole infomnatlon than fs lndlctied in tab D of the briefingpackage. Moreover, the ASTM standard for Infants and toddters that Idrafted would have been In effect at least one year ago If not forodministrotlve over sight at ASTM. It b now approv# and going forwardwithamassof 3.2kgfortheAstzeheadfomrand4.0kgfortheEstreheudform, We have ...