RECOMMENDATION ON THE PREVENTION OF HEAD INJURIES WHEN CYCLING THE CONSUMER SAFETY COMMISSION, HAVING REGARD TO petition No.

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1 Cité Martignac 111, rue de Grenelle PARIS 07 SP Paris, 16 march 2006 RECOMMENDATION ON THE PREVENTION OF HEAD INJURIES WHEN CYCLING THE CONSUMER SAFETY COMMISSION, HAVING REGARD TO the Consumer Code, in particular Articles L , L , R and R to R HAVING REGARD TO petition No Whereas: I. INTRODUCTION Pursuant to Article L of the Consumer Code the Consumer Safety Commission, asked to consider two petitions concerning the safety of bicycle helmets, has decided to issue a recommendation on the prevention of head injuries when cycling. II. ACCIDENTOLOGY Several findings may be drawn from accident data in France. - Statistical data on cycling accidents are inconsistent and incomplete. In 2001, the road safety authorities recorded 5,501 deaths and injuries on public roads whereas InVS (health watch institute) put the number between 78,000 and 216,000. No information is gathered about the cause and circumstances of accidents 1 (place, factors involved in the occurrence of a head injury). - Available national and regional information indicates that, while the head is not the part of the body most affected in cycling accidents, a cyclist without a helmet runs a greater risk than a cyclist with one. 1 Including whether the injured cyclist was wearing a helmet or not. - 1/13 -

2 - There is overmortality following road accidents for the over 40s, and especially the over 65s and overmorbidity for the under 14s. III. THE WEARING OF HELMETS IN FRANCE III.1. Wearing helmets in races In France, the requirement for cyclists to wear helmets in professional road cycling races was introduced into the regulations of organising bodies relatively late, though under the rules of the French Cycling Federation 2 (FFC) wearing a helmet has been compulsory in all other competitions since It was not until Andrei Kivilev, a member of the Cofidis team, received a fatal head injury following a fall in a race in March 2003 that the sports minister, Jean- François Lamour, called a meeting of all those involved in professional cycling with a view to making the wearing of helmets in competitions compulsory. On 2 May 2005, following the French decision, the UCI ( International Cycling Union) made the wearing of helmets compulsory in all countries and in all professional competitions as of 5 May Nevertheless, riders may discard their helmets at their own risk in the last five kilometres of a climb (if the finishing line is at the top of the climb). Riders who fail to comply with this requirement or who fail to close the chinstrap may be fined 200 Swiss francs. 11 to 15 licensed members of the FFC suffer fatal accidents each year, mostly during training. In 2004, the UCI published a circular on the wearing of helmets which still left some issues unresolved. The document advises riders to ensure that the helmets they use are properly certified, though what that means is not defined. The UCI also warns riders against the lack of certification of certain aerodynamic helmets used in time trials or track racing. III.2. Wearing helmets in leisure cycling In France, unlike in other countries, wearing a helmet is not compulsory. Some leisure cycling associations, like the Fédération Française de Cyclotourisme (FFCT), require minors to wear a helmet for liability reasons and encourage adults to do the same. Thanks to an effective awareness-raising campaign, 90% of FFCT members now wear helmets. The number of cycling-related deaths among FFCT members has fallen from 47 in 2001 to 26 in Half of the fatal accidents are attributable to physical causes (cardio-vascular failure in particular). The over 55 probably most reluctant to wear helmets require members of leisure cycling clubs aged under 18 to do so. 2 The FFC is delegated by the sports ministry to promote and organise cycling competitions in metropolitan France and French overseas dependencies in several disciplines, including road racing, track racing, cyclo-cross, mountain biking, BMX, cycle polo and indoor cycling (including cycleball and artistic cycling). The FFC has some 100,000 licensed members, including 200 professional cyclists. 3 Although the FFC also urged cyclists to wear helmets during training, it is not compulsory. That is why the authors of the bill wanted to introduce the following provision in Article 2: "Helmets must be worn in all cycling competitions. Competitors who fail to do so will be immediately excluded." - 2/13 -

3 Overall, the wearing of helmets is still not widespread in France. - The road safety agency, ONISR, reckons that there are 5 million bicycles in active use in France. According to the cycle trade observatory, over 3.5 million bicycles were sold in France in 2004 (in all categories: town bikes, racing bikes, mountain bikes, children's bikes, etc.), 6% more than in France reportedly has one of the lowest helmet equipment rates, with an average of one helmet sold for every two bikes and one helmet per bike for children. This is borne out by an opinion poll conducted by INPES, the national institute for accident prevention and health education, in the spring of 2005: 3% wear a helmet regularly in rural areas, 4.5% wear a helmet in urban areas with over 100,000 inhabitants (both including and excluding the Paris region) and 17% always wear a helmet. Although adults generally do not wear helmets, almost half of all children (47%) do so at their parents' insistence. IV. REGULATIONS AND STANDARDS RELATING TO THE WEARING OF HELMETS IN FRANCE Directive 89/686/EC of 21 December 1989 as amended on the approximation of the laws of the Member States relating to personal protective equipment (PPE) defines three classes of PPE: - Class 1: PPE of simple design that covers only minimal risks; - Class 2: protection against serious mechanical, physical or chemical attack or impacts or vibrations that affect vital parts of the body and are liable to cause irreversible injury (bicycle helmets and all other sporting helmets fall into this category); - Class 3: protection against mortal danger. The directive was transposed into French law by texts incorporated into the legislative and regulatory parts of the Labour Code, which constitute the "ordinary law" on PPE, and by decree of 5 August 1994 on the prevention of risks resulting from the use of PPE in sport. For Class 2 and 3 PPE, an approved laboratory (notified body) must test one or more samples of the product to ensure that it complies with the technical requirements. If the tests are positive, the laboratory will issue the manufacturer or importer with an EC typeexamination certificate. All PPE, whatever their origin, must carry the EC mark. The marking indicates that a product meets the requirements of the European directive. They must all include manufacturer's instructions stating conditions for storage, use and care and any other information necessary for proper use of the product. Responsibility for ensuring that products comply with the requirements of the PPE directive lies with the manufacturer if production is located in the European Union or with the importer or agent if the product does not originate from within the European Union. The manufacturer or the importer or agent responsible for first placing the product on the market must furnish proof on request that the PPE they make or distribute complies with regulatory requirements. 5 The European standard applicable to cycle helmets, which gives presumption of compliance with the requirements of the directive, is NF EN 1078 of April 1997, 4 Mountain bikes (48%), racing bikes (23%), hybrid bikes (16 %), children's bikes (6%), town bikes (4%), BMX (3%), toy bikes (1%). 5 Retailers must at the very least ensure the apparent compliance of the PPE they offer to consumers, and in particular that it bears the EC mark and includes instructions for use, which must not under any circumstances be separate from the product. - 3/13 -

4 which applies to helmets both for cyclists and for skateboarders and rollerskaters 6. The standard defines a number of requirements relating to: - manufacturing methods and areas to be protected, - fields of vision to be preserved, - impact absorption properties, - resistance to penetration, - the features of retention systems. The latter three characteristics are laboratory tested under various conditions of heat and humidity. Absorption capacity is assessed by dropping a standard head from a certain height onto an anvil. An accelerometer measures the deceleration, which must not exceed a certain limit. Like the American and Australian standards, and in contrast to the situation with motorcycle helmets, the standard is not based on any traumatological study from which the coefficients of resistance to objective impacts can be defined. Resistance to penetration is assessed by the impacts on the helmet after it has been dropped onto an anvil, but it takes no account of the effects of a sliding fall. There are no requirements for air vents (minimum airflow coefficient, number, size, protection) which, coupled with the lack of specifications for impact points during resistance tests, can lead to approval being given to helmets that are not strong enough. The NF EN 1078 standard warns consumers against the risks of using helmets for purposes other than cycling, skateboarding or roller-skating. For example, children may keep their helmets on when doing something quite different from cycling, such as climbing on a climbing-frame in a playground. The need to keep the helmet in place on the head in the event of an impact on a bike means that the chinstrap system must not release on impact. Conversely, when a helmet is worn for a purpose other than cycling, the chinstrap can get stuck and asphyxiate the child if the retention system does not open easily. Several cases of accidental hanging with helmets intended exclusively for cycling are reported to have occurred in recent years. The standard offers two solutions to this problem. First, if a cycle helmet is to be used for a non-cycling activity, it states that a different type of helmet should be worn, one that complies with the NF EN 1080 standard on protective helmets for young children. Second, it states that the instructions for use must mention that children must not use the helmet for activities in which they could get caught up by the chinstrap. Standard NF EN 1080 as amended in February 2003 (NF EN 1080/A1) lays down requirements and testing methods 7 for helmets intended for children engaging in activities in environments where there is a risk of head injury, ie, either cycling in a "home" environment where there are no motor vehicles or engaging in other play or games where the risk of strangling cannot be ruled out. For these 6 There are also various foreign standards for helmets, notably American, British, Swedish and New Zealand. 7 The impact absorption capacity requirements in EN 1080 are the same as in EN /13 -

5 two types of activity, the helmet must therefore be equipped with a self-releasing retention system that will open on violent impact. In 2004, the European Commission, pursuant to Article 6.1 of Directive 89/686/EC, issued a draft formal objection against NF EN 1078 on the grounds that the standard did not fulfil the health and safety requirement set forth at Article 1.2.1, "Absence of risk and other inherent nuisance factors". The standard could not confer the presumption of compliance for helmets intended for children under the age of 7. After monitoring the market for cycle helmets for young children, the Commission found that manufacturers were very reluctant to comply with the requirements of NF EN 1080, especially those recommending that helmets for children under 7 should be equipped with a self-releasing retention system. It therefore considered, a contrario, that NF EN 1078, could allow for the design of helmets that represented a risk for children since it did not cover automatic release of the retention system. The federation of sports and leisure industries, FIFAS, opposed the Commission's draft resolution, arguing that it was unacceptable to create a risk (a young child losing the helmet on falling from a bicycle) in order to eliminate another risk (that of strangulation). Helmets that comply with NF EN 1078 are designed not to come off after an initial impact, thus avoiding a secondary impact to the head if the helmet is ejected. For FIFAS, only full and fair consumer information about the functionalities of both types of helmet was justified as recommended by CEN Guide 11 on product information relevant to consumers. FIFAS also pointed out that there were virtually no helmets with self-releasing chinstraps on the French market. The draft formal objection filed by the Commission was rejected. However, the debate is not over since two draft amendments to the two standards are currently under discussion. Although the aim is to improve consumer information, certain representatives of the CENTC 158 Technical Committee on Protective Helmets would like to reintroduce the Commission's suggested age limit of 7 into the warnings. FIFAS is also opposed to this measure, arguing that the 7-year age limit is arbitrary and is not based on any study of psychomotor development in children. IV.1. Supervision of regulations and standards Following a national survey in 2004, the government considers that the regulations are broadly respected, even though more still needs to be done. Of 326 helmets tested, 11 failed to comply with certain requirements and test methods of the NF EN 1078 standard, 9 of them because of lack of impact absorption capacity or insufficiently strong retention systems. Two helmets were deemed dangerous. The inspectors also noted that instructions for use rarely accompanied the products displayed on the shelf: "the notice attached to the helmet often gets caught in the display when the customer takes the helmet and is torn off." The notices are also not often in French. V. THE PROPER USE OF HELMETS From a physiological standpoint, Dr. M., at a Commission hearing, pointed out that a helmet in all events offers only partial protection. Extreme risks can be minimised only by specialist materials that fulfil specific requirements of resistance - 5/13 -

6 and envelopment. 8 For the ordinary cyclist, a "good" helmet must at the very least protect the fragile areas of the cranium (face, zygomatic arch, occiput at the midmastoid) at speeds corresponding to reasonable traffic conditions (between 10 and 30 kph on average). Provided these conditions are met, the two helmet designs found on the market are acceptable: - helmets where protection is ensured by closely surrounding the parts to be protected. In this case, the aim is to minimise the effects of an impact on the head either by giving the materials of the shell uniform thickness ("aggressive" rollerblade or BMX helmets) and few vents, or by strengthening just the parts corresponding to the most fragile bone regions. For Dr. M., however, the only guarantee of real protection for the face and neck was a visor and good close protection of the occiput, which is not always to be found in these models; - helmets where protection is based on the mass of the helmet all around the cranium. The rim of the shell avoids direct impact to the face, temples or back of the neck from still or moving objects. This type of helmet is now the most common. The vents may or may not have protective webbing against insect bites. 9 Even though Article 4.4 of NF EN 1078 states that the back of the cranium must be protected, Dr. M considered that few helmets give sufficient protection to the occiput and even wondered whether certain systems for adjusting the head size might not be dangerous. Chinstrap resistance measurements were satisfactory for the expected use 10 since they showed that the chinstraps resisted a pull of 250N. 11 Measurements of the fastening system itself showed considerable differences in the amount of force needed to open clips or buttons. However, it remained below a limit of 90N, 12 which guarantees that a child and hence also an adult can manipulate the fastening system if necessary. V.1.1. Characteristics of the helmets available on the French market Adjustment of the size of the helmet to the head Although NF EN 1078 requires the head size to be marked in centimetres, the criteria for defining the size of helmets differ from one manufacturer to another and from one model to another. Thus, there are age ranges, ranges by size in centimetres and American sizes (XS/S/M/L). 13 Dr. M. considers that beyond a range of two sizes and for a head corresponding to the stated minimum, the use of adjustment systems on their maximum settings can 8 Such as integral helmets for high-speed downhill racing. 9 In practice, when they do not have protective webbing, cyclists often thread padlocks through them to attach the helmet to the cycle, which may damage the shell. 10 To prevent the helmet from being torn off in the event of a violent pull or impact. 11 N: Newton, a standard unit which is the force required to accelerate one kilogram by one metre per second squared. 12 In the toys standard, the pull force limit guaranteeing that a child cannot separate one element of a toy from the whole (eg, the eye of a soft toy). 13 A survey by consumer magazine Que Choisir, published in issue no. 363 of July/August 2005, warned (after laboratory tests) of the approximate nature of all the sizes. - 6/13 -

7 reduce the level of protection. For example, with foam strips or a repositionable velcro strap, reducing the head size raises the helmet, which then leaves sensitive areas like the temples and the back of the neck uncovered. Dual-clip ratchet systems increase the risk of unsymmetrical adjustment. Adjustment of the chinstrap either side of the head There are two methods for attaching the side straps of the chinstrap to the shell of the helmet. In one case, the chinstrap consists of a single strap that goes into the shell of the helmet or the headband and is held by a single anchor point. 14 The strap slides inside the helmet on adjustment. In the other case, the chinstrap has one or two straps but two anchor points which, in Dr. M.'s opinion, is better for the even distribution of pressure on the cranium. Closing the chinstrap Article of the standard states that the chinstrap must not include a chinpiece. None of the helmets found on the market had one. Markings on almost all the helmets complied with NF EN However, the lettering of the markings is often too small to be read easily. Some manufacturers affix warnings not provided for by the standard, relating to use of the helmet on motorised devices. There are two main types of warning: "This helmet is designed for cycling only. It is not for use with mopeds or motorcycles" and "This helmet is intended only for non-motorised sports: cycling, roller-skating, skateboarding." Five helmets out of twelve did not include any instructions at all, contrary to the provisions of Chapter 7 of NF EN Only three sets of instructions complied fully with the standard. In the light of the difficulties encountered in tests, it is regrettable that the instructions should give so little information about how the different adjustment systems work, or about how to position them correctly and the chronological order of operations. V.2. Tests in use 24 cyclists divided into two groups of 12 (four children and eight adults) were recruited to test cycle helmets in use. The cyclists in the first group, all of them helmet users, were each given several models which they tested for several days. They then gave their impressions to the LNE (National Testing Laboratory) coordinators (ease of use, comfort, etc.). The second group, all of them not helmet users, were asked during tests at the LNE to put on a helmet and take a short ride. Each participant tried three helmets according to the same protocol and each helmet was used by three different people. An LNE coordinator fitted the helmet and asked the users for their first impressions. V.2.1. Assessment criteria for the proper fit of a helmet The criteria for the proper fit of a helmet were determined by Dr. M. according to physiological factors. Once adjusted to the circumference of the head, the helmet must not show 14 This is consistent with NF EN 1078, Article of which states only that "retention systems must be solidly attached to the helmet". - 7/13 -

8 too much slip movement from front to back or sideways, spontaneously, under light pressure or in the event of a violent impact, and must be uniformly in contact with the cranium. The helmet must be worn horizontally, the head must be covered to the mid-mastoid and above the line of the eyebrows. The chinstrap must be vertical. With the straps forming a "Y", the point of the "v" must be located under the ears but must not cover them. The chinstrap must not slide onto the throat. Properly adjusted, there must be room only for a single finger between the chinstrap and the skin. V.2.2. The tests Preliminary interviews before the tests produced the following information. - The perception of risk depends on the type and frequency of cycle use. The risk of falling or hitting a blunt obstacle seems real when mountain biking or racing and justifies wearing a helmet. On a bike ride or on the road (urban or country), consumers see the risk as minor. - Many cyclists do not give the matter of wearing a helmet any thought: it is not a reflex. People who have never or rarely worn a helmet do not think of buying one or, if they have one, forget to wear it. Without a parental model, children become more reluctant to wear a helmet after the age of 8. - Image concerns deter cyclists from wearing a helmet. The image must be as positive as possible for everyone, adults and children alike, and reflect the person's membership of the community they identify with. 15 If helmets are not compulsory, wearing one becomes a personal choice that reveals individual concerns, as does the choice of model. Depending on the individual's perception, wearing a helmet may be "soft" or responsible, modern or sporty. Standing out or going too far are other concerns: excess is not appreciated. Wearing a highly sophisticated helmet when cycling around town seems ostentatious or ridiculous. In all events, the helmet must not detract from the person's self-image and look. For young people, not wearing a helmet, in full knowledge of the risk, also has the attraction associated with risk-seeking behaviour and the desire to experience strong feelings. - For the average user, the feeling of safety is first and foremost linked to the way a helmet surrounds the head. With cycle helmets, the need to protect the face and back of the neck with extensions of the shell beyond the cranium is not felt spontaneously. 16 Polystyrene and plastic 17 do not have the image of sufficiently impact-resistant materials. At this level, cycle helmets are seen in exactly the same way as helmets for motorised two-wheelers. For some adults unfamiliar with the constraints and risks of cycling, lack of confidence in the materials is sufficient to justify their reluctance to wear a helmet. 18 In contrast users, feeling that the protection offered is limited, do not show greater willingness to take unconsidered risks even if they are wearing a helmet. 15 This is the "tribe" effect, familiar to mobile phone operators, for example. 16 This also explains why, when choosing a helmet, rollerblade helmets are greatly appreciated (as well as being fashionable) even though paradoxically they are not necessarily the most suitable for ordinary cycling. 17 Especially when they have air vents. 18 Though they do not display the same reluctance when it comes to protecting children. - 8/13 -

9 Comfort, though a concern for users, did not seem to be a major obstacle to wearing a helmet. V.2.3. User perception of helmets On completion of the tests, no user, whether child, accompanying parent or adult, correctly adjusted the helmets to the cyclist's head, whatever the adjustment systems or combinations of systems. Users adjust helmets without method. Many 19 read neither the markings nor the instructions, even if they experience difficulties. They consider it unnecessary for such a simple product. They do not take the time to study the adjustment systems before the tests and sometimes force them, either through frustration or because they do not understand how the systems work. Adjustment wheels proved to be the best method for adjusting the helmet to the circumference of the head, especially for children. Whatever the design of the helmet, it is clearly difficult, even after reading instructions and studying diagrams, to position a helmet properly alone. The most frequent difficulties experienced or errors made by users were as follows. - Adjusting the size of the helmet to the cranium was sometimes overlooked and some users merely tightened the chinstrap to apply the top of the shell to their cranium. - The chinstrap was wrongly adjusted (too tight or too loose) in half of all cases. Over-tightening the chinstrap, despite the predictable discomfort, is due to the fact that the chinstrap is seen intuitively as the only way of fastening the helmet to the head. - Only one user understood where and how to adjust the side straps (in a Y with the buckle under the ears). The others did not understand the point of this adjustment in balancing the helmet on the head and distributing the protection over the entire surface of the cranium. - However, the adjustment is easier to make when the straps are fixed at two points at the front and back of the helmet rather than at just one point, either at the front or at the back. It is doubtless one of the main reasons for the difficulties users experience in adjusting helmets. - On closing the chinstrap, the retention straps were twisted on several occasions because, the ratchet system being perfectly symmetrical, the two male and female parts lock whatever their position in relation to each other and there is nothing to enable the wearer to notice. - Ratchet and button systems, though effective because very precise when it comes to adjusting the chinstrap, are uncomfortable for the throat (risk of pinching and rubbing) and cyclists do not like them. 19 A third of the sample. - 9/13 -

10 ON THE BASIS OF THIS INFORMATION Having heard M. L., president of the FFCT, in session. On accidentology and the need to wear helmets Whereas in order to measure the true accident rate associated with cycling there is a need for nationwide statistical data that does not include only cycling accidents reported by the police and gendarmerie on public roads (4,594 dead and injured in 2004); Whereas it would be helpful to confirm or refute the statistical extrapolation by InVS, which puts the annual number of cycling accidents within a wide bracket of 78,000 and 216,000; Whereas cyclists over 65 have a greater risk of fatal accident when cycling than those in other age groups, estimated at 4.9 deaths per million people in 2004 (46 deaths); Whereas road safety and InVS statistics show an overmorbidity for cyclists aged under 20; Whereas it transpires from accident research that head injuries to cyclists are less numerous but potentially more serious than the other injuries they suffer most frequently in the accidents in which they are involved and that head injuries are responsible for deaths each year among cyclists not wearing a helmet; Whereas professional cyclists are required to wear a helmet when racing and have accepted that obligation; Whereas within the Fédération Française de Cyclotourisme (French leisure cycling federation), cyclists aged under 18 and mountain bikers are required to wear a helmet; Whereas in 2004 as many cyclists were killed in urban areas (81 deaths) as elsewhere (86 deaths), justifying the utility of wearing a helmet in both urban and non-urban environments; Whereas a young child carried on a bicycle seat may be a passive victim of a cycle accident and, strapped into a seat, cannot evade a head impact in the event of a fall; Whereas according to a recent opinion poll by INPES only 3% of cyclists in rural areas, 4.5% in urban areas with over 100,000 inhabitants excluding the Paris region and 20% in the Paris region say they wore a helmet the last time they rode a bike; Whereas the requirement for minors, and especially children under 15, to wear a helmet would be a step forward in improving the safety of all cyclists, becoming a habit for children who will have worn a helmet since they first started to ride a bicycle and for the adults who encourage them to do so; Whereas policies that encourage cycling, in particular for reasons of public health, energy saving and environmental protection, should include measures designed to improve safety for cyclists; - 10/13 -

11 Whereas wearing a helmet cannot be the sole measure for preventing cycling accidents and that steps should be taken to encourage and accelerate the provision of cycle lanes in urban areas, early instruction in road safety, effective and longlasting lights on bicycles and the wearing by cyclists of other items of individual protection such as reflective clothing by day and at night, gloves, etc. On the outcome of experiments in other countries Whereas experience and studies in other countries show that wearing a helmet systematically reduces the seriousness of face and head injuries and consequently the number of deaths caused by cycling accidents; 20 Whereas in the countries concerned, the compulsory wearing of a helmet has not had an adverse effect, or a lasting adverse effect, on cycling; On the characteristics of helmets Considering the need to tighten up the requirements of standard NF EN 1078 on helmets for cyclists and users of skateboards and roller-skates, as regards both the quality of protection and the conditions for safety inspections; Considering the possibilities for improving helmet design, especially in order to achieve better protection of the face and back of the neck; Considering the difficulties experienced by consumers in tests of satisfactorily adjusting helmets to the head and hence guaranteeing an optimum level of safety. ISSUES THE FOLLOWING OPINION: On wearing a helmet For the attention of the public authorities - improve statistics on cycling accidents, whether in terms of the number, causes and circumstances, injuries suffered and behaviour of equipment (cycle, accessories, helmet); - make wearing a helmet compulsory for minor cyclists and, at least initially, for cyclists under the age of 15 and for carried passengers, every time they ride or are carried on a bicycle; - continue campaigns to raise awareness of helmet-wearing and the prevention of specific risks associated with cycling directed at other categories of cyclists than those for whom wearing a helmet would be compulsory, especially senior citizens; - give particular emphasis in such campaigns to the importance of adjusting the helmet properly. 20 As statistical data collection methods are not homogeneous, it is difficult to give any coherent figure. - 11/13 -

12 For the attention of consumers - wear a helmet whenever they ride a bicycle; - choose the size of helmet best suited to their head size, in particular so as to limit adjustments with the various adjustment systems with which the helmet is equipped; - seek advice from a professional, since choosing the right helmet and adjusting it properly are essential safety elements when cycling; - ensure that instructions for using the helmet are provided with the product and read the operating instructions before adjusting the helmet to their head; - use all the adjustment systems (headband, side straps) to ensure uniform pressure over the entire cranium; - regularly check the state of their helmet and change it systematically after a violent impact or after any accident and in accordance with the manufacturer's recommendations even if the helmet is used normally and is not involved in an accident. On the characteristics of helmets For the attention of standards bodies: - start work on a revision of standard NF EN 1078, especially the following points: - limit the range of head size adjustments of each helmet, especially for children's helmets, which may impose a position that provides less protection, - fix the chinstrap retention system to the shell of the helmet so that on adjustment it ensures that the helmet presses evenly on the head; - not use buckles, buttons or press studs that do not work if the side straps are twisted; - stop using adjustment systems (head size and chinstrap) that require the user to take the helmet off in order to adjust it; - give consideration, in terms of safety, to air vents, visors and the need to provide the best possible protection to fragile areas of the cranium, back of the neck and lower face; - improve impact tests; - consider whether it would be appropriate in the standard to distinguish between the specific requirements of cycling, skateboarding, roller-skating and scootering. - 12/13 -

13 For the attention of helmet designers and manufacturers - fulfil the requirements of NF EN 1078 while integrating ergonomic concerns into the design of helmets and their adjustment systems so that consumers can be offered products that are effective and easy to understand and use, including by children; - with cycle manufacturers, study secure arrangements to ensure that the helmet is immediately available whenever the cycle is used. This would mean that cyclists would always have their helmet to hand, avoiding the risks of loss or impact if they have to carry it with them; - take appropriate steps to improve protection to the back of the neck and lower face, also ensuring that adjustment systems do not cause injury; - clarify the wording and presentation of manufacturers' instructions in order to encourage users to read them. For the attention of helmet distributors - train staff so that they are able to advise and better assist consumers when choosing and adjusting cycle helmets; - systematically propose the acquisition of a helmet to consumers when they buy, maintain or repair a bicycle; - offer free help with adjusting any helmet purchased in their stores. ADOPTED AT THE SESSION OF 16 MARCH 2006 BASED ON THE REPORT BY MR. DOMINIQUE POTIER AND MR. JEAN-PIERRE STEPHAN assisted by Ms. Odile FINKELSTEIN, Ms. Muriel GRISOT and Mr. Patrick MESNARD, technical advisers to the Commission, in accordance with Article R of the French Consumer Code - 13/13 -

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