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A biker guide
Personal Protective Equipment (PPE)
The Flash Gear (Biker Passion) literature on the Personal Protective Equipment Issue
The Flash Gear Company (Biker Passion) is concerned at reports that motorcyclists are enduring to be sold clothing products in flouting of the PPE Regulations.
Moderately, it is an offence to declare or imply that motorcycle clothing is protective unless the product in question has been independently tested and bears CE marking.
The Flash Gear Company (Biker Passion) understands that there is perplexity in the marketplace concerning the span of the legislation, and many retailers are merely continuing, in good faith, to endorse clothing products in the way they have for many years, but never-the-less in direct contravention of the new regulations.
This Flash Gear Company (Biker Passion) literature is intended to informing consumers more fully on this complex subject. The Company believes retailers will find of interest as well.
Motorcycle Clothing and Standards – A Buyer's Guide
High-quality protecting clothing for motorcyclists has been offered for many years. Nonetheless, how many riders are sufficiently knowledgeable in materials science, clothing design and the mechanisms of injury in accidents to decide in a shop which jacket for example is truly defensive and which jacket simply looks protective?
The innovative European Standards set least amount levels for various uniqueness of protective clothing that should make sure all clothing claiming to be conventional to the standards will provide a reasonable level of protection. Clothing, boots and gloves subjected to testing and posture an independent and recognizable mark of fitness for purpose will be a less dangerous purchase than unharmed clothing.
The Personal Protective Equipment Directive efficiently split motorcycle clothing into that which is protective and that which is not. The Directive's provisions are pretty obvious in this stare, and following extensive meetings between the European Commission, industry and riders' groups, agreement on how to categories motorcycle clothing has been reached.
In convenient requisites, motorcycle clothing can be separated into three groups:
Non-protective. Outer clothing constituting a barrier to the elements: heat, cold, wind and rain. Claims for any other form of protection breach the PPE Regulations, UK law, and industry and riders' groups' agreement with the European Commission.
Non-protective supplied with CE impact protectors. A non-protective outer garment, as above, fitted with for example accredited shoulder, elbow, knee and back protectors bearing CE marking.
Protective jackets, trousers, one-piece or two-piece suits, boots and gloves claimed by the manufacturer to be protective. Tested according to the European Standard (or the Cambridge or SATRA standards) and bearing CE marking. Garments must be fitted with CE marked protectors.
What defines which group a garment falls in to?
Relatively simply, whatever the company claims it to be. As is often the case in such situations, however, there are a few untruthful companies who are taking advantage of the situation and the consumer's lack of in detail knowledge, to make wealth.
For example, limb and back protectors are merely present for one purpose: to save from harm. Unfortunately there are some manufacturers, however, who are still planting components made from plastic and foam into the limbs and back of garments. There are also boots and gloves with similar components. The probability is that the consumer will suppose that these are impact protection, but because the producer does not claim them to be so, they take advantage of the loophole.
Where CE manifest protection are fixed to a non-protective garment (typically a textile jacket, but equally applicable to leather jackets, trousers and suits), some retailers are misleading consumers, claiming that the whole garment is approved. In fact it is not, and retailers who provide such information disobey, for example, the Sale and Supply of Goods Act and the Trade Descriptions Act.
On the other hand such garments feature a “CE†label sewn to the lining, but in fact, this refers only to the standing of the fitted protections. This is called misleading. Do not allow yourself to be misled.
As a final point, how has the manufacturer or distributor illustrated the garment in their advertising? What did the clothing salesperson at your local motorcycle superstore declare about the garments as he tried to sell it to you? The European Commission's agreement with industry and riders' groups is pretty apparent in this regard, and the following advice has been issued:
“If a manufacturer openly declare, or implies in sale literature and /or advertisement, that a garment offers protection because of specific additional features, these additional features shall be eligible as “PPEâ€. As such, they must fulfill with the provisions of the PPE Directive.
“The explicit features may materialize in e.g. crash protectors for limb and/or back, pads for elbow and /or shoulder and protection from cuts and abrasions (not exclusive listing of examples)â€
Consequently, phraseology such as:
(shock absorbing)
(impact resistant)
(absorbs shocks during falls)
(affordable protection against wind, rain and tarmac)
(abrasion resistant)
(for protection, quality and style)
(total commitment to safety)
can hardly be credibly be argued not to constitute a claim that the product so described is protective.
Question is how can the consumer tell which group a garment falls in to Personal Protective Equipments?
Answer is here: By law all CE marked PPE must be supplied with detailed, printed information on selection, care and upholding of the product. Protective motorcycle clothing and crash protectors must be supplied to the consumer with such information and it must explain, for example: How the product was experienced, the test data generated, how to remove and reinstall protectors (as may be essential when clean-up the garment) and the predictable service life or how to recognize when the PPE requires substitution. Contact information for the European Notified Body responsible for the testing and certification will also be provided, from which you will be able to contact them to verify the genuineness or otherwise of the manufacturer's claims. If you are uncertain how to go about this, your local Trading Standards Department may be prepared to assist.
In short: treat no information as not approved.
The retailer told me that the European Standards do not apply to leisure riders, only ‘professional motorcyclists.
Riders' groups agreed to support the standards if leisure riders clothing was expressly excluded, to put off the standards being used to support obligation. The standards are for clothing not users; consequently, they can still be used to CE mark clothing for non-professional use. In addition, the Cambridge Standard and the SATRA alternative technical specification, which jointly form the basis of EN 13595, are still obtainable and do not distinguish between leisure, professional or competition users. Simply, there is no excuse for industry not to offer attributed products.
I have been told that the cost of testing and certification is so high, it would price CE marked clothing out of my reach
This is another red herring. It actually costs less to test and certify a motorcycle suit than it does the average pair of safety shoes - as proven by the fact that the first companies to achieve EC type sanction were the small, UK manufacturers of bespoke motorcyclists' clothing. Furthermore, the main clothing brands are buying CE approved impact protectors at considerably lower prices than they were five years ago. In fact, these foremost clothing brands, with promotion and advertising budgets in the hundreds of thousands of pounds, could cancel one publication advertisement and entirely cover their testing costs. They have the budget.
European Standards for motorcyclists' protective clothing!
Take a long, firm look at your motorcycle clothing. Do you know what it is? Not in the sense of is it leather or textile, one piece, two-piece or separates, and is it padded; but is it protective clothing or is it “fashion†clothing - because since 30th June 1995 those are the officially permitted distinctions.
The requirements and provisions of the Personal Protective Equipment (PPE) Directive (89/686/EEC), and their bearing on motorcyclists' protective clothing, seems necessary to review in this Flash Gear Biker’s Guide for batter understanding for riders.
The PPE Directive became an vigorous part of Motorcyclist Since that date, suppliers of protective clothing and equipment “designed to be worn or held by an entity for security against one or more health and safety exposure†(the Directive's definition of PPE) have been required to categories their goods as PPE, or non-protective; and to CE mark them by self-certification or through independent, third-party official approval by test facilities known as “European notified Bodiesâ€.
Motorbike clothing was not at first going to fall within the range of the legislation. Following the collapse of the ACU Standard for race wear (more on which later), however, a meeting took place between Dr Garth Willson and a Mr Petrovich, of the European Commission, in which the latter was persuaded that motorcyclists would advantage from the availability of products manufactured to a European Standard. The European Standards agency CEN (Comité Européen de Normalisation) convened a mechanical subcommittee with the long title of CEN/TC 162/WG9 - or “WG9†- in order to build up these standards.
In 1998, EN 1621-1 was published, and motorcyclists will be familiar with this, because limb protection fitted to garments are often claimed to meet this prerequisite (in fact no protector should be marketed if it does not conform to this standard, but that's a subject we'll be looking at in Part 3). Provisional standard prEN 1621-2, which covers back protectors, and which may be published as a full standard by the time you read this, is starting to be endorsed in the form of recently-accredited products (for example the T-Pro “Force field†back protector). In conclusion, there are the garment, glove and footwear standards: EN 13595 Parts 1 - 4, EN 13594 and EN 13634 in that order.
In this Flash Gear Biker’s Guide Article, we will be looking at the development and application of the CEN standards for motorcycle garments, their background and some of the controversy that destroyed and slowed their delivery.
The corridor to standards:
In February 1984, one of the monthlies carried an advertisement for motorcycle suits “ made to ACU Standard â€. An enquiry to the ACU on how other companies could gain this accreditation revealed the advertiser's claim was a lie; there was no ACU Standard and action was taken to prevent the claim appearing in publish again.
Certain officials within the ACU recognized, however, that the Standing Regulations for road-racers protective clothing - the ACU had merely adopted the FIM's instruction - could be usefully improved. The text is at best unclear and at worst completely meaningless. For example, it requires that: “ The following areas must be padded with at least a double layer of leather or enclosed plastic foam at least 8 mm thick:- shoulder, elbows, both sides of the torso and hip joint, the back of the torso, knees â€. The prerequisite for the shoulders, elbows and knees can be complied with simply enough. It is the requirement for the other parts of the body that raise a question mark over the efficiency of the requirements. Read one way, it could be argued that the regulations render back protectors compulsory. Read another, few mass-production manufacturers comply with the requirement for double leather between the armpit and the hip. Inconsistent, ambiguous, unenforceable and, of course, unenforced.
Motivated by the number of low-quality suits that were supporting terrible failure during racing crashes - which at one point resulted in the ACU issuing an unprecedented ban on one leading European manufacturer's suits - in 1988, the ACU established a technical subcommittee to prepare its own standard for race wear. Members of this committee included ACU personnel, medical experts and garment manufacturers.
But no sooner had this committee delivered the final plan of their document than the ACU decided not to publish it. The reason afterward admitted was that the ACU had a fear that if a competitor sustained injury, they might be held responsible as the “official recognition body†for his suit. For the betterment of the ACU to required competitors to wear products accredited by another body.
Then European Commission becomes concerned.
It was at this point that Dr Willson, who had been a associate of the ACU standard committee, travelled to Brussels and convinced Mr Petrovich, whose son happened to be a motorcyclist, to take in motorcycle clothing within the scope of the standardization programmed initiated in response to the recently published Personal Protective Equipment Directive.
German standards agency DIN was appointed as the secretariat for Working Group 9, which held its first meeting within DIN's offices in the former East Berlin in August 1991. The committee's early efforts were first and foremost focused on developing a standard for limb protectors, but outside of the meetings, controversy was building.
The European motorcycling industry feared that the publication of PPE standards could lead to motorcyclists being obliged to wear approved clothing. Both the Commission and CEN were lobbied by industry and riders' groups to exclude motorcycle clothing both from the scope of the Directive and the standardization programmed.
At a crucial meeting with Commission officer Mr J-P Van Gheluwe, the industry demonstrated a textile jacket, which, it was claimed, merely represented a barrier to non-extreme ambient conditions of wind, rain and cold. Such products for personal use are specifically excluded from the scope of the Directive, and so the industry considered a block exemption for all motorcycle clothing to be warranted.
Sadly, someone had forgotten to remove the shoulder and elbow protectors from the jacket, and when one of the Commission delegation enquired “ what are these meant to be? â€, an industry representative answered truthfully and impulsively “ they are protectors †- which immediately resulted in the Commission delegation pronouncing them to therefore be PPE and consequently within the scope of the Directive!
Conciliation was reached whereby motorcycle clothing proposed for private use and providing protection only from non-extreme ambient weather conditions would not be considered as PPE. Any protectors fitted to, for example, the elbows and shoulders were considered to be PPE and therefore to be tested and approved. If, however, a manufacturer specifically claimed or implied in literature or advertising that in addition to fitted protectors, the garment also provided other forms of “special†protection (e.g.: abrasion and cut resistance), then the garment would also be considered to be PPE and subject to testing and certification.
Advancement is Made
Development after that point wasn't entirely controversy-free, but a standard for clothing which had been presented by the British Standards Institution (BSI), and which combined the requirements of the remarkably similar Cambridge Standard and test house and Notified Body SATRA's alternative technical requirement was used as the basis of the CEN standard for motorcycle clothing. Through a series of separate project groups operated under the control of WG9, a total of eight product standards started to take form.
In December 1997, the first WG9 standard to appear in print was EN 1621-1
Motorcyclists protective clothing against automatic impact – Part 1: Requirements and test methods for impact protectors.
The garment standard EN 13595 “ Protective clothing for professional motorcycle riders - Jackets, trousers and one-piece or divided suits †at last appeared during the late summer of 2002. This has been divided into four parts:
One part covering general requirements and one covering each of the three test methods. In response to a submission by riders' groups - embraced by industry and accepted by the Commission and CEN - the scope of these documents was amended from earlier versions to include garments for use by professional riders only.
This step was taken to provide a blockade to the CEN standards being used as the basis of further legislation making the wearing of approved PPE by leisure motorcyclists compulsory.
Footwear standard EN 13634 and glove standard EN 13594 also feature a scope amended to encompass professional use only. These were published at the same time as EN 13595, which is significant since the standards share many ordinary test methods.
At last, prEN 1621-2 “Motorcyclists protective clothing against mechanical impact - Part 2: Motorcyclists' back protectors - Requirements and test methods†has just completed its Formal Vote stage and it is predictable this document will appear in print early in 2003 - maybe even by the time you read this.
After a decade, finally a series of authoritative standards is available that will deliver to the marketplace, and thence the consumer, fit for purpose motorcycle clothing bearing an independent, recognizable mark.
Appendix:
Remember when buying motorcycle clothing; if claims for special features, CE armour etc. are mentioned in the advertising then the protectors - and, if the claims extend to it, the clothing - must by law be CE marked. It has been possible to purchase type-approved and CE marked motorcycle clothing since the Cambridge Standard's publication in 1994.
The European motorcycle clothing standards enlighten:
Introduction
High-quality protecting clothing for motorcyclists has been offered for many years. Nonetheless, how many riders are sufficiently knowledgeable in materials science, clothing design and the mechanisms of injury in accidents to decide in a shop which jacket for example is truly defensive and which jacket simply looks protective?
The innovative European Standards set least amount levels for various uniqueness of protective clothing that should make sure all clothing claiming to be conventional to the standards will provide a reasonable level of protection. Clothing, boots and gloves subjected to testing and posture an independent and recognizable mark of fitness for purpose will be a less dangerous purchase than unharmed clothing.
Impact Protection Standards:
EN 1621-1 - Motorcyclists' protective clothing against mechanical impact –
Part 1: Requirements and test methods for impact protectors;
Many motorcyclists will be well-known with EN 1621-1, ever since its publication in 1997, shoulder, elbow, knee and, to a lesser degree, hip protectors marked as meeting the requirements of this standard have appeared in increasing numbers across the whole range of motorcycling garments.
Protectors are experienced on the similar equipment used to evaluate many other shapes of impact protection, including horse riders' body protectors, martial arts protectors, cricket equipment and riot protection for the police.
Purely, the apparatus is a overlook mounted on a one metric tons block of steel or concrete, to which is bolted a load cell. The product for testing is mounted the relevant one of a series of anvils, on behalf of the various parts of the human body, which is bolted above the load cell. Impactors broadly replicating the “hazard†(a flat road surface, a fist, a cricket ball or a brick, for example) are dropped onto the sample and the transmitted force expected by the load cell is recorded.
prEN 1621-2 - Motorcyclists' protective clothing against mechanical impact –
Part 2: Motorcyclists' back protectors - Requirements and test methods
Draft customary prEN 1621-2 covers back protectors. This may well have been published as a full standard by the time you read this article. The crash energy is the same as for limb protectors, at 50 Joules, but the transmitted force is lower than for limb protectors at 18 kN for “Level 1†products and 9 kN for the higher performance “Level 2†products. There has been disparagement of the standard from medical experts who consider the transmitted force levels too severe; citing decades of automotive investigation which indicates 4 kN is the maximum force the brittle bones which form the human ribcage can withstand before they fracture. Four kilo Newton is the requirement adopted in standards covering, for example, horse riders' body protectors and martial arts equipment.
Attempts to reduce the broadcasted force requirement to 4 kN and to correspondingly reduce the 50 Joule impact energy requirement were strongly resisted by industry, who claimed consumers would be “confused†by different impact energy requirements between EN 1621-1 and EN 1621-2.
By fact, it was in industry's commercial benefit to test both types of protector at 50J, since they could then extol the efficacy of back protectors which, when struck with the same impact energy as limb protectors, transmitted only 9 or 18 kN compared to 35 kN. The consumer would be unconscious that subtle differences in the impactor and anvil were accountable, still less aware that 9 kN was still more than double the safe edge supported by medical experts. Moreover, during the late 1990s, some companies had used the wholly unsuitable EN 1621-1 to CE mark their back protectors. Commercial objectives were given priority over consumer safety.
In spite of these concerns, EN 1621-2 characterize a initial point from wholly unsafe products should be render obsolete and unsalable. It will be important, however, for consumers to ensure back protectors are manifest with the accurate standard number, if they are not to mistakenly purchase an old stock Finally, there are a small number of back protectors on the market which have been dual-tested against the requirements of EN 1621-2 and also against a 4 kN transmitted force requirement. Reading the manufacturer's technical information will reveal which are the superior products. item marked to EN 1621-1.
Clothing standards
EN 13595 Parts 1 - 4 - Protective clothing for professional motorcyclists - Jackets, trousers and one-piece or divided suits
As the title says, and as has been enlightened somewhere else in this series of articles, the scope of EN 13595 includes garments for use by “professional motorcyclists†only.
Whilst it became evident that their political lobbying of the European Commission and European Standards agency CEN had failed both to have motorcycle clothing specifically disqualified from the scope of the PPE Directive and for the programmed to be dissolved, industry looked to other ways to slow development of the standards.
Claimed to be to present yet another blockade to legislators to use the clothing standards as the basis for compulsion, the suggestion was tabled that the document should be divided into as many parts as possible. It was rational to follow the format of other product standards, with a general requirements document supported by documents relating each of the test methods. This slowed progress down slightly, but not significantly given the eight years it had taken to get to the point where advanced clothing drafts were even in movement!
The four parts of EN 13595 are as follows:
