The Federal Consumer Product Safety Commission has a standard for the design of bicycles. This standard does little to make cycling safer, and in some ways it makes cycling more dangerous. The most dangerous error is its requirement of the all-reflector system for nighttime protective equipment, which cannot perform the known engineering task and encourages people to ride dangerously at night without lights.
The CPSC was staffed by safety zealots who thought that the design of bicycles caused many casualties. They thought that the Bicycle Manufacturers' sales standard was a safety standard and copied its requirements without understanding them, getting the engineering wrong. They put into law the dangerous all-reflector system that the manufacturers wanted to protect themselves.
The CPSC fulfilled the manufacturers' desire by putting the all-reflector system into law. It did so without either any testing of the performance of reflectors in potential collision situations or analysis of the known data on nighttime collisions, and despite having been clearly informed of why the all-reflector system cannot work. All it had was a demonstration in its driveway that reflectors shined when illuminated by car headlamp beams. When the CPSC was sued over this, it lied to the court about these matters. Then the Bicycle Manufacturers tried to get the all-reflector system made state law, but were repulsed. Subsequently, cyclists have been grievously injured in collisions caused by this system. The CPSC still defends its system, showing no realization of what are rather obvious engineering realities, and intends merely to improve the reflectors that cannot work.
The Bicycle Manufacturers Attempt to Invalidate the State Laws for Headlamps
Correspondence between the Bicycle Manufacturers Association and the CPSC regarding the conundrum posed by the conflict between state laws requiring headlamps and the CPSC's regulation that, by law, invalidates the state's laws. Both of the two attempts to resolve this conflict result in incredible absurdities, but legal rationalizations overcome reality.
In reaction to the legal imposition of the CPSC's dangerous all-reflector system, the League of American Wheelmen (now the League of American Bicyclists) adopted a policy on nighttime protective equipment that strongly criticized the all-reflector system and emphasized that cyclists need headlamps to be safe at night.
In 1994, the CPSC started to become concerned about the number of nighttime car-bike collisions, and held a hearing on the subject. This is Forester's report of that hearing.
This is the paper that I presented at the first CPSC meeting on nighttime equipment. It points out why front and side reflectors cannot perform the necessary task, and outlines how the CPSC could change its standard to facilitate and encourage the use of proper equipment (headlamp and bright rear reflector, plus optional rear lamp) when cycling at night.
The CPSC held a second meeting to announce how it planned to do research about countermeasures for nightime car-bike collisions. The research plan showed no recognition of the actual accident types and mechanisms, and therefore could not be directed at the real problems. There was a storm of protest from the better-informed attendees, but the CPSC shows little sign of understanding that the all-reflector system is a dangerous encouragement to cycling at night without necessary lights. This is Forester's account of that meeting and criticism of the research plan.
Various parties presented papers to the CPSC about nighttime conditions and equipment. These range from accurate analyses of how reflectors work to the most egregious, self-interested, promotion of foolish items such as reflective tires. This is Forester's review of these documents.
The CPSC's new reflector research justified its old regulation by failing to test reflectors under the conditions in which they fail. Was that caused by deceit or plain dumb luck? Therefore, the CPSC sees no need to revise its regulation and its system of nighttime protective equipment will be just as dangerous as always. The 3M Co. wants to petition for a regulation requiring large fluorescent and reflective panels for both daytime and nighttime safety.
Nighttime Equipment page last changed: 04-Feb-14