Dennis Stalter - Comments

I've spent quite a bit of time studying the issue of mandatory helmet laws and helmet effectivness and one thing that I've never found in any of NHTSAs statistics is the Death to Accident Ratio. If riders wearing helmets were 37% more likely to survive an accident then that should be easily visible in a statistic which measured the number of deaths per accident between states which have mandatory helmet laws and those which don't. I took the statistics for California from 1984 (the earliest I could get from the California Highway Patrol) through 2006 and calculated the number of deaths per 100 accidents both before and after a mandatory helmet law went into effect in 1992 and found that the average Death to Accident Ratio was 3.22 before the helmet law and 3.45 post helmet law to date. If riders wearing FMVSS 218 compliant helmets were 37% more likely to survive an accident it sure doesn't show up in these numbers. Pennsylvania recently removed their mandatory helmet law and has seen virtually no change in their Death to Accident Ratio. So now I look at this proposal and what it suggests the benefit of better labeling for FMVSS 218 compliant helmets would be and I can't see much of a cost benefit. Actually I can't see that at all because there is no estimate of how much this would cost or even what the cost of making the proposal is. What I can see is that, using NHTSAs own estimates on helmet effectiveness and riders using helmets which may not meet the FMVSS 218 standard, if the claimed 5% of the claimed 15% of these riders in the 20 states that require mandatory helmet use used new helmets then maybe an additional 17 to 32 would survive a crash. That's great, but what I also found when reviewing the California statistics was that, after implementation of the CMSP, there was an enormous drop in the number of accidents. This correlated with an enormous drop in the number of injuries and fatalities. This is why the motorcycling community has been stressing that programs which will reduce the number of accidents will go much further than changing helmet labeling requirements. If NHTSA is really interested in saving lives then rather than spending precious resources trying to force people to wear helmets maybe they should look at what's really effective. I'm also troubled by the unsubstantiated statement that "Wearing a helmet does not increase the risk of other types of injury." on page 9. There has been a lot of debate over this issue over the years but for a government agency to come out and declare there is no risk is irresponsible at best. That's even worse than saying airbags don't cause injury - at least you're aware that they do and even measure this factor in some of your automobile statistics. No one even looks at whether a helmet contributed to an injury or fatality so how can you say, uneqivocally, that they don't? People could die from misinformation such as this. May I suggest that this proposal be shelved until you can clearly demonstrate that the Death to Accident Ratio will be improved by forcing people to wear compliant helmets and can, without hesitation, say that helmets won't cause injuries in some crashes. Meanwhile, try focusing on accident prevention, especially through motorist awareness programs, and see what effect that has. You may be surprised. I read an article recently about such a program in Ohio that resulted in fewer fatalities even with the increased ridership over the past year. I'd be happy to provide additional documentation to support what I've said if anyone is interested. It's time to take the focus off helmets and put it on training and motorist awareness programs. That's where you'll find real gains in accident reduction and the corresponding injury and fatality numbers you're looking for.