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. VitranoExecutive Vice President

Specialty Vehicle Institute of AmericaOctober 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-by-side vehicles

CPSC Conclusions Against ROPS1991 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 loosely-restrained 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/RisksVan 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/RisksOther 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