Comment from Melanie Stevens

These amendments will effectively update 16 CFR 1512. The increased clarity provided in the proposed amendments is a necessary step on the path to ensuring bicycles receive focused testing prior to entering the consumer market. The amendments will also relieve an economic burden on manufacturers by eliminating unnecessary testing on specific types of bicycles. However, as the CPSC points out, with the rate that technologies, designs, and features of bicycles change, an entire review of 16 CFR 1512 is necessary. In reviewing the charts provided by the Bicycle Products Suppliers Association (BPSA), it seems that there are many areas of concern for bicycle manufacturers that are not addressed in this proposed rule. While a comprehensive review seems impossible in the timeframe provided, simply changing definitions to provide clarity will not do enough to ensure that products are adequately tested prior to entering the market place. I fully support the changes included in the proposed amendments however, I urge the CPSC to go further in its efforts to fully reform 16 CFR 1512 so that the regulations adequately address the needs of today’s bicycles.