Comment from Michael Dunn

As an avid cyclist, I was interested to learn that regulations regarding bicycle requirements were being reviewed to better address current advancements in bicycle technology. Because my safety depends on bicycles meeting standards, I appreciate efforts to ensure that products do not cause harm due to failures in design. I believe all changes currently listed in this proposed rule are beneficial and support continued safety. However, to make requirements more realistic for the bicycle manufacturer I feel that certain areas could be addressed, as found in the Bicycle Product Suppliers Association’s (BPSA) letter dated 4 June 2010. Requirements for pedals, and the derailleur guard should be adjusted to accommodate designs common in racing and high performance bicycles. The requirements for pedal construction do not allow for the “clipless” pedals that have been in use for several years. The pedals are designed to be lightweight, and have lower profiles. This design makes it near impossible to attach any sort of reflector while maintaining the intent of the design. The attachment to the 4 June letter from BPSA also points out that it is “difficult to design [a] light weight competition pedal with retention mechanism and space for reflectors.” It is important to increase the visibility of the cyclist at night, but the potential added benefit of reflectors on these types of pedals does not outweigh the cost and burden on the bicycle manufacturer. Also, it is not feasible to place treads on the pedals, as there is very little space on the pedal. In accordance with the issues pointed out in the 4 June letter from BPSA to the CPSC, the rules should be amended to allow an exception for “clipless” pedals to the requirement for treads and reflectors. The derailleur guard requirement should also be revised. The letter points out issues that affect competitive bicycles, specifically the guards “do not fit on modern wheel designs or 11 speed drive trains.” The requirement should be adjusted to accommodate non-traditional wheel designs found in time trial, triathlon and road racing bikes. I support maintaining the proposed changes, and recommend further consideration of the issues above to support the bicycle manufacturer.