Submission to Safe Work Australia in response to the

Submission to Safe Work Australia
in response to the
Public Discussion Paper: Review Of
Design and Engineering Controls
For Improving Quad Bike Safety
Federal Chamber of Automotive Industries
Level 1, 59 Wentworth Avenue
KINGSTON ACT 2604
Phone: +61 2 6229 8217
Facsimile: +61 2 6248 7673
Contact: Mr Cameron Cuthill
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INTRODUCTION
The Federal Chamber of Automotive Industries (FCAI) is Australia’s peak
organisation for the automotive industry and represents importers of ATVs and
motorcycles as well as car manufacturers and importers.
The FCAI and the industry it represents will continue to refer to All Terrain Vehicles
by that (correct) name. The slang term “quad bike” has become popular in some
quarters in recent years, but only because of an unfortunate confusion between
“terrain”, on the one hand, and “topography”, on the other.
The ATV industry in Australia is concerned about the number of deaths and injuries
associated with ATV use and has always been a willing and collaborative contributor
to forums aimed at developing strategies and actions to improve safety.
Our involvement has included participation in a lengthy Coroner’s inquiry in Victoria
and Tasmania and, over the past few years, in numerous workshops which
culminated in the development by the Heads of Workplace Safety Authorities of an
ATV safety strategy that was released in 2011. The industry will also be involved in
recently announced research into ATV safety which will commence later this year in
New South Wales.
Throughout this time, the industry has supported proven safety measures including
mandatory wearing of helmets, comprehensive training and appropriate use of ATVs
and particularly the banning of children under the age of 16 from using adult-sized
ATVs.
The industry has investigated potential engineering safety enhancements ever since
ATVs were first put into the market place. Any proposed engineering change must
take into account the inherent design of the ATV as a vehicle that is actively ridden
like a motorcycle and hence the rider is not restrained. The industry will continue to
seek engineering improvements where they can be proven to be safe and effective.
To that end, the industry cannot support the fitment of ROPS (including so-called
“crush protective devices”, or CPDs) to ATVs based on current international research
evidence. Put simply, these devices do not meet world standards as a safety
intervention. ROPS on ATVs have an unacceptably high injury risk and can cause
more injuries than they prevent. As mentioned above, the industry supports further
scientific research – including into ROPS. But, as matters currently stand, the
industry is of the view there is no credible research which indicates a ROPS is
beneficial to ATV rider safety.
The ATV industry believes more needs to be done to promote proven safety
interventions. No attempt has been made to mandate helmets; training offered by the
industry is largely ignored; and there has been inadequate publicising of the
responsibility adults must show for the safety of children, by ensuring they do not ride
an adult-sized ATV.
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DISCUSSION PAPER PROPOSALS
The FCAI would like to make the following specific comments in relation to the
Discussion Paper:
Foreword
Australia is a very small part of the world market for ATVs so introducing design
elements just for Australia is generally unwarranted. When design elements are
tested and proven to have a safety (or other) benefit they are quickly integrated into
new models and rolled out across all major markets.
In the automotive sector, international standardisation and regulation has become the
norm and the days of unique design rules for Australia are over, as what is proven
safe and effective for one market generally applies to all. In the same way, the ATV
industry aims to provide the best product for all consumers regardless of geography.
Some 29 ATV engineering design, performance and safety features are already
required by mandatory regulations in North America, the region where the vast
majority of ATVs are manufactured and sold. It is also, without doubt, the region
who’s legislators and regulatory bodies have scrutinised ATV design and use more
thoroughly than any other over the past three decades. From this they have
developed a “world’s best” design standard (ANSI/SVIA-1) which was updated less
than two years ago. Australia should leverage that vast and unparalleled experience
and adopt for itself those ATV engineering standards, which the majority of the
industry already comply with voluntarily, rather than attempting to reinvent ATV
standards.
ATV sales continue to grow in Australia and around the world, providing the industry
with every incentive to pursue continual improvement in ATV design. There ought be
no doubt that the industry will introduce additional engineering solutions if and as
they believe them to be both safe and effective, as safety is the industry’s highest
priority.
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What design solutions and/or engineering controls could improve quad bike
stability and safety?
As part of any discussion on “improving” ATV stability and safety, it is necessary to
consider where the class of vehicles called ATVs sits in the continuum of vehicles
used in agriculture and recreation.
Motorcycles, side-by-side vehicles, 4x4 vehicles, utility vehicles, tractors and trucks
are all used in agriculture, with the latter three to a lesser extent in recreation.
From a design perspective, motorcycles and ATV’s are considered as “rider active”
vehicles, for which appropriate movement of the rider’s body position is critical to,
and intrinsically linked with, the relative stability, mobility, utility and safe and effective
use of the vehicle. This is largely due to the relatively large percentage which the
rider’s weight contributes to the gross vehicle mass. Design elements which normally
characterise these rider active vehicles are:
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“Sit astride” seats with footpegs/ footrests [as per ANSI/SVIA-1] where the
rider’s legs are either side of the engine and/or gearbox and their feet are
placed on individual footpegs or footrests. This allows the rider to place
appropriate weight on either foot (often by standing) and to move their body
weight both fore and aft and side to side on the seat in order to control the
vehicle, particularly when ascending, descending or traversing slopes. This
combination of sit astride seat and footpegs /footrests also enables the rider
to separate from the vehicle due to natural forces in the event of overturn, and
allows the rider the option of separating from the vehicle in a controlled
manner if the riding situation requires it (e.g., stalling whilst ascending a steep
slope or potential instability whilst traversing a slope).
Handlebars (as opposed to a steering-wheel) which are used both to turn the
front wheel(s) and to provide two hand grip points (similar to what the
footpegs /footrests provide for the feet) to assist the rider in moving their body
weight to control the vehicle. They also allow the rider to move their body
weight forward “above” the handlebars, particularly when ascending slopes.
In addition, the handlebars assist in allowing the rider to shift their body
weight to the “uphill” side of the vehicle when traversing slopes.
A smooth seat. This normally continues both forward and behind the rider’s
“neutral” seating position, allowing them to “slide” their weight forward and
backward (and to a lesser extent side to side) to enable appropriate body
position to be achieved when ascending and descending slopes.
A relatively narrow track and short wheelbase (compared to a side-by-side
vehicle or 4x4) to allow high manoeuvrability and mobility in restricted space
or changing environments (such as when mustering livestock).
Hand operated accelerator.
Hand operated brake(s) and clutch, if fitted. In addition, one or more brakes
(and gears if fitted) may be operated by the foot.
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By contrast, vehicles such as side-by-side vehicles, 4x4s, utilities, trucks and tractors
are not rider active (or driver-active). That is, occupant weight is small in comparison
to the vehicle, and they do not require the driver to shift their body weight to
effectively control the vehicle. Consequently, they have fixed seating positions for the
driver and any passengers. Design elements which normally characterise these
types of “non-rider active” vehicles are:
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A fixed seat (normally of “bucket” design) which provides a single fixed
position for each vehicle occupant within a protective space engineered by
creating protective structures around vehicle occupants. These structures
often include, but are not limited to, a rigid body shell or chassis or frame with
roof pillars, a roof, floors, sometimes doors, limb restraint nets (i.e., netting
“doors”), ROPS, etc. The one exception to this are tractors under 560kg, for
which there is no requirement for any protective structure.
A restraint system (“seat belt”) to restrain each vehicle occupant in their fixed
seating position, and within the protective space of the vehicle, when driving
on rough terrain or in a crash or rollover situation.
A steering wheel, fixed at a point relative to the driver’s seating position,
designed to steer the vehicle.
A relatively wide track and long wheelbase, providing a high degree of
stability (i.e., reduced manoeuvrability and mobility) to allow for increased
passenger and payload carrying capacity.
Foot-operated accelerator, brake and clutch. (If fitted.)
As can be seen by this comparison, and as the “quad bike” description suggests,
ATVs have much more in common with motorcycles than with side-by-side vehicles,
4x4’s or tractors.
Hence, in considering any proposed design solutions and/or engineering controls, it
is important to consider how the ATV design has evolved to its current point in the
continuum of available vehicles, and how changing the design will necessarily affect
its utility and operating characteristics.
Given its single track, a motorcycle is the most manoeuvrable of the vehicles
commonly used in agriculture. It has the narrowest track and requires significant rider
intervention by way of body weight shift and control input to follow a desired path. In
agriculture or off road recreational use they are primarily a single user vehicle with
high mobility but very limited load carrying capacity.
An ATV has a track that is wider than a motorcycle. By its nature, it therefore has
greater lateral stability. However, there is no evidence to suggest that greater lateral
stability is a valid measure of ATV safety. Whilst still primarily a single person vehicle,
ATVs have greater load carrying capacity than motorcycles but, as they are also
“rider active”, this capacity is still significantly less than the longer, wider and more
stable “non-rider active” vehicles such as side-by-sides and 4x4s.
As the track width and wheelbase length of vehicles increase, they become more
stable, heavier and consequently less manoeuvrable and less mobile. The
fundamental utility of the vehicle thus changes and the nature of the manner in which
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they are controlled must also change. A (comparatively) wide track, long wheelbase
vehicle can no longer be rider active and thus requires a steering wheel, fixed seating
and consequential protective structures to surround, as well as restrain within it, all
parts of the driver and passengers. By widening and/or elongating an ATV, the
engineering adaptations which need to be added (i.e., bucket seat/s, an occupant
restraint device, ROPS, a steering wheel, change in control positions, etc.)
essentially change the vehicle from an ATV into a side-by-side vehicle (two or more
seats) or a single seat buggy.
These wider and longer types of side-by-side vehicles with ROPS have already been
designed and are freely available for sale in Australia, primarily originating from the
same manufacturers who build ATVs. Choosing the correct vehicle for the application
is of prime importance as, whilst they do have points of usage crossover, they are not
identical in usage profile.
With regard to lowering the centre of gravity of ATVs to make them less likely to
rollover, there are already ATVs available, with shorter suspension and lower profile
tyres, which have a lower centre of gravity than the more utility focused ATVs. But
this naturally affects available ground clearance and thus the mobility and utility for
which the vehicle was likely employed in the first place. Whilst a rider on a sand dune
or MotoX track may value a low centre of gravity ATV and not require much ground
clearance, a dairy farmer in rutted tracks in a muddy paddock requires exactly the
opposite, and would often “high-centre” and become stuck if riding such a low sprung
vehicle.
With regard to “active stability controls that can automatically take control of vehicle
systems to minimise roll over risk”, there are presently no such systems available
(i.e., it is beyond the state of technology). On-road vehicles that have electronic
stability control (ESC), for example, implement them via antilock brake systems
(which off-road vehicles do not have for safety reasons). Moreover, on-road and offroad tyre force characteristics are very different (essentially opposite in terms of their
force/slip characteristics). So, while on-road ESC systems rely on applying brakes to
increase roll stability, in an off-road situation this would increase tyre forces and
decrease roll stability. While it is conceivable that such systems may be developed in
future years for off –road vehicles such as ATVs, they are presently beyond the
scope of current technology.
With regards to “passive stability control systems like operator warnings that sound
when slopes that increase roll over risk are encountered”, an observant rider should
be able to easily observe that they are approaching a slope, how steep the slope is
and to position their body accordingly, if they are trained to do so. For any passive
system to recognise a slope (say with an inclinometer) the vehicle would already
have to have been on the slope for a period of time. Thus, if relying on the warning
device, it may be too late for the rider to make the decision not to ride on to the slope
in the first place, unless of course the system is measuring slope well ahead of the
vehicle.
However, the slope of the terrain is just one (albeit major) determinant of tipping
point. Many other inputs to the system would also be necessary to make the tipping
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point warning valid, given the significant rider active nature of ATVs. Such systems
would need to monitor the weight and body position of the rider as well as any load
being carried, as well as transient bumps being encountered and incorporate that
information to calculate the point at which turnover may occur on that particular slope
and situation. This of course assumes constant speed, direction, slope and body
position, none of which can be assumed in such a dynamic riding environment. Key
well-known limitations of such systems – which may work on heavy, slow-moving
earthmoving equipment operating on gradually changing, more uniform slopes include the inherent time delays of the sensing system; the inherent time delay for
the operator to react (which is important if a vehicle such as an ATV is moving across
complex, varying terrain) and the nature of the warning (i.e., visual, audio, etc.).
Obviously a visual display is inappropriate for a vehicle such as an ATV as it would
require the rider to look downward, away from the forward terrain at a moment when
it is critical that their visual attention be directed toward the terrain. An aural warning,
in the presence of engine sounds, can conflict with use of an appropriate helmet and,
like other warnings, has the inherent issues of delay and occurrence of nuisance
warnings when, for example, the vehicle traverses rough (bumpy) terrain, even when
there is no risk of overturn. Riders would have to learn how to interpret and when and
whether to react to such nuisance warnings. As an example, a rider traversing a
slope with correct body position – i.e., leaning up the hill – could traverse a much
steeper slope without tipping than could the same rider with incorrect body position.
Without such inputs as rider weight and body position, an operator warning system
would give a rider with incorrect body position a false sense of how far the vehicle
could lean (i.e., it would overestimate the tipping point) while, conversely, it would
underestimate the tipping point for a rider with correct body position. If speed, slope,
direction or riding position change, then of course so does the tipping point.
They key to avoiding tip over on slopes is for riders to identify potentially hazardous
slopes BEFORE they attempt to ride on them. In addition, on any slope (or in any
turn) ATV riders should use a correct combination of body position and speed to
ensure they have the maximum margin in which to react, and the maximum margin
for error should conditions change. As a last resort, having the correct riding position
will in most cases allow a safe separation away from the path of the vehicle if a tip
over eventually does occur.
The only way that riders can appropriately identify and deal with hazards is if they are
significantly experienced or trained to do so. As with a motorcycle, the rider’s weight
and body position has a significant effect on the behaviour of the ATV. Regardless of
engineering modifications to the ATV, the rider and their ATV are intrinsically linked
and the safe operation of the vehicle is dependent on the rider knowing how to make
the correct inputs to the machine and then making those inputs.
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What engineering controls could improve operator protection in the event of a
roll over?
In the event of a rollover, correct riding position and a lack of obstructions are key to
the rider separating from the vehicle in a controlled manner.
ATVs are designed with flat, smooth surfaces, free of obstructions, to facilitate the
movement of the rider away from the path of the ATV. They are now also required to
be designed (under ANSI/SVIA 1- 2010, with which all FCAI members comply) with a
standardised protective “foot environment” to minimise the chances of lower
extremities being inadvertently placed between footpegs and the wheels or body of
the vehicle.
However, given the intrinsic relationship between rider and safe control of the
vehicle, it is critical that riders place themselves in the correct riding position prior to
any tip over risk occurring (“uphill” of the vehicle on slopes and to the “inside” of the
corner in turns.) In the vast majority of cases these simple but essential techniques
will prevent the tip over from occurring in the first place. If, despite these precautions,
tip over does occur the rider will be in the safest position to move away from the path
of the vehicle.
Given that head injuries are significantly overrepresented in roll over events, and one
of the major causes of death, the obvious engineering control to improve operator
protection in a roll over would be to mandate that all riders wear a properly
engineered motorcycle helmet.
With regard to the fitting of ROPS or so-called “crush protection devices” (CPDs), the
FCAI is unaware of any reputable research, worldwide, which shows any evidence
that their use would provide a net benefit to users. In fact the opposite is the case.
Physical and simulation research conducted by Dynamic Research Incorporated has
found that, for helmeted riders, the least harmful of the CPD’s tested caused
approximately as many injuries as it prevented and thus was of no net benefit.
Not only are the CPD’s themselves unproven but no ATV in current use has been
designed to accept fitment of any of the CPD’s on the market.
It is inconceivable that anywhere else in the automotive industry, an unproven
device (with no supporting research to demonstrate that it has any safety benefit, but
with research indicating the contrary1) would be allowed to be fitted to a vehicle
which was never designed to accept it, or that this would somehow be considered to
be a “safety” measure.
1
Zellner, J.W., Kebschull, S.A., Van Auken, R.M. UPDATED INJURY RISK/BENEFIT ANALYSIS OF
QUADBAR CRUSH PROTECTION DEVICE (CPD) FOR ALL-TERRAIN VEHICLES (ATVS) DRI-TR-06.
3 August 2012.
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With regard to “automated emergency alarms that are initiated in the event of roll
over” for those working alone or in isolated places, there may be value in the fitment
of an aftermarket EPIRB (or EPIRB-like) alarm device which triggers upon inversion
and is linked to a notification service. This would conceivably be of value to all
vehicle types used by those working alone and/or in isolated areas, not just ATVs.
What engineering options could minimise the capacity of children to start
and/or operate quad bikes?
Unless the vehicle has been tampered with, removal of the key from the ignition of
the vehicle will prevent the vehicle being operated by any unauthorised person, not
just a child.
Furthermore, isolating the key in a place where it is not accessible to children (e.g.,
key safe, gun safe, responsible adult’s pocket, etc.) will ensure that children do not
have the ability to start the vehicle and therefore will be unable to ride it. There
seems little need to look for a highly complex engineering solution when such a
simple solution is already available.
With regard to the inclusion of “seat weight sensors”, it has been rightly observed that
children are resourceful and would soon work out that the weight of two children
would also trigger a simple pressure switch in the same way as would a single adult.
Potentially encouraging one child to take a sibling or mate in order to trigger the seat
sensor, rather than riding the ATV alone, would likely be a counter-productive step.
Futuristic infrared or other sensing systems that detect the physical size of the rider
are under development in cars (for airbag sensing systems) but despite major efforts
are still beyond the state of technology. How or whether such systems, if ever
developed, might be adaptable to the dusty and exposed outdoor environment of an
ATV is unknown. In addition, they would discriminate against small adults who are
capable of safely operating an ATV.
With regard to the operator controls, much effort, over many years, has been
invested in refining their functionality to enhance the rider’s control of these vehicles.
To arbitrarily make them difficult for children, who have no place being on the adult
sized ATV’s, to us seems ill advised, and likely to be circumvented by children.
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What engineering controls could minimise the capacity of a quad bike to carry
passengers.
As they are rider active vehicles, the smooth seat normally fitted to an ATV is
designed quite specifically to make it possible for the rider to shift their body weight in
order to control the vehicle effectively. The seat normally continues smoothly both
fore and aft of the rider’s “neutral” seating position allowing them to “slide” their
weight forward and backward (and, to a lesser extent, side to side) to enable
appropriate body position to be achieved when ascending and descending slopes.
As most ATV (and off-road motorcycle) seats are non-adjustable, the seat is also
designed to allow the accommodation of riders of different heights and sizes.
Therefore “modifying the seats to limit space to a single operator” would necessarily
compromise the ability of the rider to operate the vehicle effectively and safely.
Regarding “redesigning carrying racks to restrict the ability to carry passengers
and/or make it uncomfortable to use carrying racks as seats.”, it should be
understood that the individual design of the carry racks on any particular vehicle is
based around the effective carrying of small loads, whilst ensuring that there are
smooth surfaces and minimal obstructions for the rider, particularly in the event of a
crash or at the time they choose to separate from the vehicle.
Making the racks uncomfortable to sit on may have unplanned negative
consequences. As long ago as the 1970’s, research by a Dr. Peter Bothwell found a
“strong indication that general smoothing of the outer contour all over the motorcycle
is a desirable feature.” and that “handlebars and motorcycle profile should be free of
trauma producing projections.” These findings have influenced motorcycle and ATV
design ever since and may provide a counterpoint to the argument of making
elements of the ATV deliberately rough or uncomfortable.
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CONCLUSION
Given that there is a highly integrated and synergistic relationship between the ATV
and its rider, it is unfortunate that this discussion paper deliberately excludes proven
safety interventions.
Whilst some additional engineering solutions (in addition to the 29 ANSI/SVIA-1
engineering requirements which are already mandated) may conceivably offer some
marginal improvement in safety outcomes, evidence from other countries show that it
is not until all stakeholders get serious about rider behaviour and, more importantly,
misbehaviour that improved safety outcomes can be expected.
Design changes, even if they could be shown to have effective safety outcomes
(which is currently not the case,) will take years to implement throughout the entire
ATV fleet. Changes in behaviour and compliance with proven safety measures can
be implemented widely and relatively quickly through a combination of education,
legislation and ultimately enforcement.
We know the major issues implicated in injuries and fatalities are a lack of helmet
use, children under 16 years riding full sized adult ATVs, passengers and
overloading of single operator vehicles and a lack of training/certification of users.
They can be addressed by:
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Making helmet use mandatory for all ATV riders.
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Not allowing children to access full sized ATVs.
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Ensuring all users are trained in the safe operation of ATVs through provision
of training and awareness and enforcement of existing workplace health and
safety legislation.
The industry remains committed to ATV safety and continues to be willing to be
involved in discussion on this issue.
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