Transcript First do no harm - Safe Work Australia

Federal Chamber Of
Automotive Industries
Safe Work Australia
ATV Engineering Controls Meeting
October 19
The guiding principle of safety
interventions:
First do no harm
FCAI
Represents the majority of ATV importers
• Cameron Cuthill - Motorcycle Manager FCAI
• Robert Toscano - Director Honda MPE
From the Specialty Vehicle Institute Of America
• Paul Vitrano - Executive Vice President
From Dynamic Research Inc.
• John Zellner - Director
FCAI
• We remain concerned about the number of ATV fatalities
and injuries
• Companies have strong safety credentials and a history of
involvement
• Our products continue to evolve and improve
• Proven administrative controls are being overlooked or
specifically excluded from discussion in favour of unproven
engineering options which may add further risk to riders
ROPS / CPDs
• We build other vehicles with ROPS
• Our only reason for opposing ROPS on ATVs is
rider safety
• There is NO evidence from any tests with an
appropriate injury monitoring crash dummy that
suggests the injury risks are less than the injury
benefits with CPD fitment. The contrary is true
ROPS / CPDs
• It is unacceptable for any accessory product,
without evidence of efficacy, to be installed on
a vehicle not designed for it and assumed to
be a “safety" enhancement
• Physical and simulation research shows
ROPS/CPDs will result in a net increase in
injuries and fatalities on ATVs
Review of Design and
Engineering Controls
Paul C. Vitrano
Executive Vice President
Specialty Vehicle Institute of America
October 19, 2012
Preventing Roll Over
• Lateral Stability Specification – CPSC twice studied and found
no correlation between lateral stability measures and roll
over; rider-activity; mobility/utility
• Active Stability Controls – not technologically feasible; SUVs
are able to disable in off-highway conditions to improve
traction and braking
• Passive Stability Control Systems – slow to react resulting in
inaccurate measures in dynamic off-highway environment
• Fundamentally Change Vehicle Geometry (increase track
width/wheel base; lower center of gravity) – will reduce
unique mobility/utility of ATVs; alternatives already exist
Preventing Children from Operating
Adult Vehicles
• Control Access to the Key – if owners keep keys away from
children, they will not be able to operate
• “Child-Proof” Ignition Safety Locks – concerns over feasibility,
effectiveness and potential hazards
Preventing Passengers
• Reducing Seat Size
– Larger seats are necessary to enable rider-activity required to
safety operate the vehicle
– Although larger than motorcycle seats, generally not large
enough to carry passengers
– No correlation between seat length and incidence of passengers
Roll Over Protection
• CPSC and others repeatedly have concluded
that ROPS/CPDs are inappropriate for ATVs
• Benefits of ROPS/CPDs have not been
scientifically proven
• ROPS/CPDs likely would cause many
unintended consequences, including new
safety risks
• ROPS are appropriate for alternative side-byside vehicles
CPSC Conclusions Against ROPS
1991 Federal Register Notice
• “The rider . . . must be able to move
forward and back and side to side[.]”
• “Thus, the restraint would have to allow
for such movement, and the roll cage
would have to extend far enough outward
and upward to prevent the looselyrestrained operator from contacting the
ground[.]”
• “The resulting roll cage would likely
greatly extend the width and height of the
ATV. . . . [T]his increased size might
significantly adversely affect ATV utility
and may increase the likelihood of
collision[.]”
• “[P]resently-available data
do not allow an estimate of
how many riders would use
the restraint system.”
• “[P]resently-available data
do no allow an estimate of
how many injures could be
prevented by roll cages[.]”
• “[O]r how many injuries
might be caused by new
hazards introduced by
these devices.”
“There is no support for a conclusion that the benefits of such
devices bear a reasonable relationship to their cost.”
* 56 Fed. Reg. 47,166, 47,172 (Sept. 18, 1991).
Others Have Raised Concerns About
ROPS/CPDs
•
•
•
Rechnitzer (Monash) (2003)
– “Simply put, the two types of protective structures modeled [U-bar and T-bar]
are totally inappropriate and do not form an effective Rollover Protective
System for ATVs irrespective of whether restraints would have been fitted or
not. The report [Van Auken (1996)] and analyses conducted convincingly
demonstrate that a poorly designed Rollover Protection System is probably
worse than not having a ROPS.”
Zellner (2012b)
– [With a helmeted operator,] “[t]he Quadbar would cause approximately as
many injuries and fatalities as it would prevent.”
– [With an unhelmeted operator, the device] “would cause statistically
significantly more injuries and fatalities than [it] would prevent.”
Grzebieta (2007)
– “[T]he Quadbar appears to be an increased risk in frontal rollovers as the
Quad-bar may come into contact with the rider when the full weight of the
ATV is behind it.”
Van Ee (2012) Quadbar CPD results in direct
contact with a previously uninjured rider.
Benefits of ROPS/CPDs Have Not Been
Scientifically Demonstrated
• No comprehensive, scientifically based, peer
reviewed research supporting net benefits of
ROPS/CPDs
• No evidence that ROPS/CPDs will prevent
more injuries than they will cause to such a
degree as to warrant their addition
(risk/benefit)
Unintended Consequences/Risks
Van Ee (Design Research Engineering) (2012)
• Impede ability to dismount to the rear
• Create additional hazard during crash
– Impact with rider’s body parts, including head and torso
– Alters and makes unpredictable/different path of ATV
during roll and/or potentially more violent roll
• May reduce rider’s ability to avoid ATV
• May cause contact between ATV and rider where it would not
otherwise occur
• May increase impacts and/or forces between rider and ATV and/or
ground
Unintended Consequences/Risks
Other concerns
• Alters center-of-gravity, reduces stability
• Potentially impedes ability to remove ATV from top of rider
• Potentially interacts with vegetation and other terrain
features
• Compromises rider-activity (belted ROPS)
ROPS Are Appropriate for Alternative
Side-by-Side Vehicles
• Many SVIA members and others already manufacture other side-by-side
vehicles with comparable performance that have ROPS which have low
risk in comparison to their benefits when properly used
• These vehicles provide an alternative for users who prefer non-rider-active
models with ROPS
Comprehensive Approach to ATV
Safety
• Robust voluntary standard (now mandatory) for design,
configuration and performance of ATVs (e.g. footwell design),
reviewed at least every five years to facilitate its evolution
– But resist the calls to impose design restrictive engineering
controls under the unproven assumption that they will improve
safety – first do no harm
• Legislation to mandate recommended behaviors and education to
reinforce
–
–
–
–
Wear a helmet
No children on adult ATVs
No passengers (on single rider ATVs)/overloading
Take hands-on training