QB018-Farmsafe_Australia_Inc - Safe Work Australia Public

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QB018 — Farmsafe Australia Inc
Individual / Organisation name: Farmsafe Australia Inc
What state/territory are you from? National
Public Discussion Paper:
Review of Design and Engineering Controls for Improving Quad Bike Safety
Public Comment Response Form
Complete and submit this form by 5:00PM AEST 28 SEPTEMBER 2012 to
quadbikesafety@safeworkaustralia.gov.au
Response to questions identified in the Discussion Paper
Farmsafe Australia Inc. is the major stakeholder group representing a collaboration of 19 agencies
with an interest in health, wellbeing and safety within agriculture. Agencies represented include:
National Farmers’ Federation, Country Women’s Association of Australia, Australian Workers
Union, Department of Agriculture, Fisheries and Forestry, Safe Work Australia, Rural Industries
Research and Development Corporation, AgriFood Skills Australia, Tractor and Machinery
Association of Australia, Motor Traders Association of Australia, Monash University Accident
Research Centre, Australian Women in Agriculture, Australian Centre for Agricultural Health and
Safety - University of Sydney, FarmSafe New Zealand, Farmsafe Queensland Ltd, Farmsafe
Victoria, Farmsafe South Australia, Farmsafe New South Wales, Farmsafe Western Australia
Alliance and Farmsafe Tasmania - Pass Inc
While Safe Work Australia is a member of FarmSafe, it would not be appropriate for it to participate
in preparing FarmSafe’s comments, so these comments do not include the views of Safe Work
Australia.
Farmsafe Australia has a significant interest in this issue and welcomes the opportunity to
contribute. Our statements reflect the overall intent of our members, however as we are not a
group with specific engineering expertise, these comments are general in nature. We would
welcome significant input by suitably qualified independent engineers and others in related fields
that may be able to assist in resolving the long-term design problems associated with quad bikes.
1. What design solutions and/or engineering controls could improve quad bike stability
and safety?
Comment
The poor stability of quad bikes is best demonstrated by the words of Coroner Olle, who described
these vehicles as “... prone to rollover”.1 This propensity for rollover is reflected in the Australian
data where approximately 50% of fatal incidents over the 2001-2010 period involved such events.2
Furthermore, data from the US Consumer Product Safety Commission (CPSC), indicate that
around 65% of quad bike fatalities involve a rollover.3
It is unclear what, if any, design improvements the manufacturers’ have made to enhance quad
bike stability in the past 20+ years.
Historically, the legal action brought against manufacturers’ by the CPSC declaring quads as an
“imminently hazardous product” was settled by filing of a Consent Decree in 1988. As a component
of this Decree, a requirement for pitch stability was included but not for lateral stability. While it has
been reported that the manufacturers’ agreed to work towards a lateral stability requirement over
the next 18 months, this has never eventuated.4 Significantly, it is known that lateral stability has a
greater bearing on rollover than does pitch stability.
Despite several iterations building on this Consent Decree, some 24 years later there remains no
lateral stability requirement in what has now evolved into the American National Standard for Four
Wheel All-Terrain Vehicles ANSI/SVIA 1 - 2010.5 Furthermore, questions regarding the lack of a
lateral stability test and standard for quad bikes, continue to be raised at the highest levels within
the CPSC.6
Industry will insist that there are no data illustrating a “...a correlation between lateral stability and
ATV injuries”.7 However, this suggestion is simply nonsensical with such a significant prevalence of
fatal incidents involving rollover. Some within the industry also claim that the purported influence of
so-called “active-riding” and “variations in terrain” preclude assessment of lateral stability. Farmsafe
Australia would like to see the basis of any such claims fully detailed and investigated by
independent engineers with expertise in stability and rollover.
The importance of stability and prevention of rollovers is obvious in other aligned areas (e.g.
electronic stability control is a feature of the Australian New Care Assessment Program - ANCAP).
Indeed, manufacturers now use such features as a selling point to gain a competitive market
advantage. The development of similar requirements is likely to also significantly enhance quad
bike safety.
Farmsafe Australia requests the establishment of a quad bike lateral stability requirement within an
Australian Design Rule. Such a requirement should include both a static and dynamic assessment.
Vehicles not adhering to these criteria should be prohibited from importation into or manufacture in
Australia.
2. What engineering controls could improve operator protection in the event of a roll
over?
Comment
As previously defined rollover events are responsible for approximately 50% of fatalities in
Australia.2 Furthermore, analysis of quad bike fatality data from 2003-2006 suggests that around
40% of all on-farm quad bike deaths have the potential to be averted if a Crush Protection Device
(CPD) is used.8
Data supporting the potential benefits of CPDs have been consistently identified by independent
sources9-12 Such propositions have been uniformly rejected by the manufacturers’ funded research,
even though several of their own analyses have identified a statistically significant benefit for some
devices. Notwithstanding this, the credibility and validity of the manufacturers research has been
demonstrated to be highly questionable.13
Even the most recent manufacturer supported research which claims to have identified
“unacceptably high injury risks in comparison to injury benefits” for the Quadbar (the CPD under
examination), however the research continues to use a methodology that was developed for
motorcycles and has never been validated as being appropriate for quad bikes.14 Significantly, the
principal author of this new analysis was part of the HWSA technical engineers group that agreed
in 2011 that “,,,the existing ISO method needed improvement because it was a tool for motorcycle
analysis and was not considered an appropriate evaluation tool for Quad Bikes”.15 While the
newest study has attempted to address some (but not all of the limitations defined), it remains an
unvalidated tool and hence, it is not a relevant piece of information on which to base future
intervention actions.
Farmsafe Australia is already on the public record as supporting the development of a technical
standard for fitment of suitably tested CPD’s on quad bikes. This position is based on existing
engineering evidence as previously cited and the anecdotal experience of users, particularly in
Australia and New Zealand.16 This remains our position.
Given the significant R&D budgets of these corporations, it is highly likely that there are indeed
alternate options that manufacturers’ may have tested or are in the process of assessing e.g. air
bag technology. Manufacturers’ should be encouraged to fast-track any such new approaches.
Page 2 of 5
The proposal for some form of emergency alarm that sends an automated message via a wireless
network is also worthy of further investigation. Notwithstanding telecommunication reception
limitations in a farming environment, such proposals may have utility in reducing harms subsequent
to a rollover event (though it will not avert the rollover itself).
3. What engineering options could minimise the capacity of children to start and/or
operate quad bikes?
Comment
It is simply too easy for young children to operate an adult sized quad bike. This year there is
already a well documented case in the media of a child under three years of age who was able to
start a quad bike, ride off and roll the vehicle.17 The child was resuscitated and survived but the
ease with which such an event can happen is testament to the problem faced.
Children under 16 years are involved in 21.8%% of all quad bike fatalities in Australia.2 Recently,
US CPSC Commissioner Adler stated “All ATVs pose an unnecessary and avoidable risk of injury
or death to children” and “ATVs remain the most dangerous discretionary use product for children
within CPSC’s jurisdiction.”6
Farmsafe Australia has an existing position that children under 16 years of age should not ride or
be carried as a passenger on a quad bike of any size.18 This is also supported by several other
national and international agencies.19-21
Farmsafe Australia strongly endorses the development of any technologies such as seat sensors
and more multi-task inputs to start the vehicle (noting this will not preclude operation once the
vehicle is started).
4. What engineering controls could minimise the capacity of a quad bike to carry
passengers.
Comment
The Australian data indicate that passengers were implicated in 10.9% of all fatal incidents over the
2001-2010 period. 2 The existing seat design is virtually an invitation to carry passengers, which
unfortunately has tragic consequences. While the industry may decry such approaches as it would
limit “active riding”, we are unaware of the factual basis for such an argument and would welcome
evidence in this regard from the manufacturers’.
Farmsafe Australia endorses the investigation and adoption of modifications that would restrict the
carrying of passengers. Similarly, steps that limit the carrying of passengers on racks are worthy of
investigation.
Please note legal requirements, such as those imposed by the Freedom of Information Act 1982,
may affect the confidentiality of your submission.
Page 3 of 5
REFEENCES
1. Olle J. Investigation into deaths of Vince Tobin, Joseph Jarvis Shepherd, Jye Kaden Jones, Peter
Vaughn Crole, Thomas James Scutchings, John Neville Nash, Patricia Murray Simpson,
Elijah Simpson with inquest. Melbourne: State Coroner Victoria., 2009.
2. Lower T, Herde E, Fragar L. Quad bike deaths in Australia 2001 to 2010. Journal of Health,
Safety & Environment 2012;28:7-24.
3. Garland S. All-terrain vehicle deaths database. US Consumer Product Safety Commission, 2011.
4. The Oregonian. Feds let ATVs off with a warning. May 13,
http://blog.oregonlive.com/oregonianatv/2007/05/feds_let_atvs_off_with_a_warni.html,
2007.
5. ANSI/SVIA-1-2010. American National Standard for Four-Wheel All-Terrain Vehicles Equipment
Configuration and Performance Requirements, 2010.
6. Adler R. Statement of Commissioner Robert S. Adler regarding the final rule amending the
mandatory all-terrain vehicle standard. http://www.cpsc.gov/pr/adler02142012.pdf: US
Consumer Product Safety Commission, 2012.
7. Canadian Off-Highway Vehicle Distributors Council. COHV ATV Rider Safety,
2009:http://www.catv.ca/cohv%20cvhr%20media%20and%20ongoing%20issues/General%2
0COHV/COHV%20Industry%20statement%20Oct%202009.pdf.
8. Lower T, Fragar L, Herde E. Potential for preventing farm injury fatalities in Australia. Journal
of Health, Safety & Environment 2011;27(2):125-37.
9. Grzebieta R, Achilles T. Report on the Quad-bar in relation to ATV rollover crashworthiness:
Monash University, Department of Civil Engineering, 2007.
10. Rechnitzer G, Day L, Grzebieta R, Zou R, Richardson S. All Terrain Vehicle injuries and deaths.
Melbourne: Monash University Accident Research Centre, 2003.
11. Snook C. An assessment of passive roll over protection for quad bikes. Brisbane: University of
Southern Queensland Faculty of Engineering and Surveying. 2009.
12. Thompson J, McDonald R, Macbeth A. All Terrain Vehicle (ATV) stability testing. Sydney:
Insurance Australia Group Research Centre.2009.
13. Worley G. Promoting the use of equestrian helmets: Another opportunity for injury prevention.
Journal of Emergency Nursing Online 2010;36(3):263-64.
14. Zellner J, Kebschull S, Van Auken R. Updated injury risk/benefit analysis of Quadbar crush
protection Device (CPD) for all-terrain vehicles (ATVs) - DRI-TR-12-06. http://dri-atv-ropsresearch.com/download/Updated%20injury%20riskbenefit%20analysis%20of%20Quadbar%20crush%20protection%20device%20(CPD)%20fo
r%20allterrain%20vehicles%20(ATVs),%20Zellner,%20et%20al,%20First%20Rev,%202012-0806.pdf: Dynamic Research Incorporated, 2012.
15. Heads of Workplace Safety Authorities. Quad bike Industry Solutions Program Trans-Tasman
Working Group: Industry strategy for the reduction of fatalities and serious incidents
resulting from on-farm use of quad bikes.
http://www.hwsa.org.au/files/documents/Activities%20%20Current%20Campaigns/6eec848e-c9d7-41a4-a9d5-fe243eef93f2.pdf, 2011.
16. Kinsey B. http://www.youtube.com/watch?v=pDjARaO1RO4, 2011.
17. Anon. Toddler survives quad bike crash. Cobden Timboon Coast Times, 23 May 2012.
18. Knight S, Franklin R, T L. Mount Isa Statement on quad bike safety.
http://nrha.org.au/Mount_Isa%20Statement_on_Quad_Bike_Safety.pdf, 2012.
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19. American Academy of Pediatrics. Policy Statement: All-Terrain Vehicle Injury Prevention: Two-,
Three-, and Four-Wheeled Unlicensed Motor Vehicles.
http://pediatrics.aappublications.org/content/105/6/1352.full, 2007.
20. Royal Australasian College of Surgeons. Position Paper - All terrain Vehicles (ATV's) (reviewed
2010). http://www.surgeons.org/media/348313/pos_2011-08-26_quad_bikes.pdf, 2010.
21. Yanchar N. Position Statement: Preventing injuries from all-terrain vehicles. Canadian
Pedeatric Society. http://www.cps.ca/documents/position/preventing-injury-from-atvs, 2012.
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