Viewable With Any browser

DfT Letter


 CV   Cycling   Recumbents   Unicycling   Juggling   Other Links 


This is a letter that I wrote to the Department for Transport regarding a report that they commissioned into the effectiveness of cycle helmets. The report is linked to in the references at the end of the letter:





Department for Transport (Road Safety Division)
Great Minster House
76 Marsham Street
London SW1P 4DR

27 May 2003



Dear Sir/Madam

I was disappointed to read the Department for Transport’s report “Bicycle helmets – review of effectiveness” [1], published on 16 April 2003.

The body of the report largely seems well researched and presented, with one notable exception. The authors refer several times to the “anti-helmet group”. Having followed the helmet debate for many years, I have never encountered anyone who could reasonably be described as “anti-helmet”. However, I have observed that those who favour mandatory helmet legislation (usually, it has to be said, non-cyclists) often like to portray their opponents as “anti-helmet”. In reality, of course, there is a world of difference between being anti-helmet and anti-compulsion. This reference is an early indication of the bias of the authors.

Even with this indication of bias, the conclusion is surprising after reading the body of the document. In particular, the authors conclude that: “There is now a considerable amount of scientific evidence that bicycle helmets have been found to be effective at reducing head, brain and upper facial injury in bicyclists.”

In their conclusion, they choose to ignore the considerable body of scientific evidence (mentioned earlier in the report) that bicycle helmets can increase the risk and severity of certain types of brain and spinal injury, as well as increasing the risk of a crash that may result in serious injury to parts of the body not protected by a helmet.

At university I was trained always to analyse benefits vs risk. It seems that the authors of this report have chosen to focus on the benefits of wearing a helmet while ignoring the risks involved. It is neither reasonable nor scientific for the conclusion of such a report to ignore research which does not agree with the authors’ preconceptions. The authors also readily admit to flaws in many of the studies that found helmets to be beneficial, yet choose to ignore these flaws when reaching their conclusion.

The tone of the report and of its conclusions suggests that the report was not actually intended to review the effectiveness of cycle helmets, as stated, but was intended rather to make a case for future introduction of mandatory helmet legislation (contrary to the advice of the British Medical Association [3][4] [5]), where no real case exists.

It has been reported that the Department for Transport has used this report as the basis for a new policy, that when images of cyclists appear in DfT documents they must always be wearing helmets. Although such a policy may at first seem harmless, it sends out three subtle but important negative messages:

(i) “Cycling is dangerous.” It is foolish to send a message like this when not only is it patently untrue, but the Government wishes to encourage cycling. Cycling offers significant health benefits, with regular cyclists living on average longer, healthier lives than non-cyclists. As pedestrians and motorists are more likely to suffer head injuries than cyclists [5], can I expect DfT documents to also picture those classes of road user wearing helmets?

(ii) “Cyclists who do not wear helmets are irresponsible.” It seems common sense that a helmet protects against head injury and therefore it is best always to wear one. But common sense is not always right. When the benefits and risks of wearing a helmet are analysed it becomes clear that, though there are times when it makes sense to wear a helmet, there are other times when it is best not to. Cyclists should be encouraged to make an informed choice based on both benefits and risks, rather than simply encouraged to wear a helmet regardless.

(iii) “It is better to patch a problem than to treat its cause.” The problem is that motorists occasionally collide with cyclists. The causes are insufficient training of both motorists and cyclists, inadequate policing of the behaviour of both classes of road user, and inadequate punishment for those who transcend the law. The patch is to advise cyclists to wear helmets – of little use in most car-bike collisions and clearly no substitute for driver education or for developing the cycling skills described in the Stationery Office publication “Cyclecraft” [6].

For the record, I tend to wear a helmet in winter and not to wear one in summer. When my head needs insulating from the cold I find that a well designed cycling helmet is a comfortable and practical solution, with the added benefit that it may offer some protection if I should happen to slip on a wet or icy road. In warm weather, on the other hand, the discomfort of wearing a helmet is likely to cause lapses of concentration. A helmet will also cause sweat to run into my eyes, having a significant adverse effect on vision. The result is that I would be more likely to crash while wearing a helmet, so for my own safety I choose not to wear one.

As a taxpayer, I am concerned that public money is being spent on flawed reports such as this. As a cyclist, I am concerned at the implication that the DfT would like, in future, to remove my right to make an informed choice as to when it is appropriate to wear a helmet. I hope you can assure me that my fears are unfounded and I urge the DfT to reverse any policy that it has implemented requiring cyclists pictured in its publications to be wearing helmets.

Finally, I would draw your attention to the excellent critique of the report written by John Franklin, the UK’s foremost expert on cycle safety [2].

Yours faithfully


Danny Colyer BSc(Hons)

References

[1] “Bicycle helmets – review of effectiveness” –Elizabeth Towner et. al., November 2002, published April 2003
http://www.roads.dft.gov.uk/roadsafety/roadresearch/bicyclehelmets/index.htm

[2] “Bicycle Helmet Effectiveness – a broader perspective: A Critique of Department for Transport Road Safety Research Report No 30, 2002” - John Franklin, 2003
http://www.cyclenetwork.org.uk/papers/broader.pdf

[3] “Cycle Helmets” – British Medical Association, 1999

[4] “Cycle helmets should not be compulsory” – Douglas Carnall, British Medical Journal 1999;318:1505
http://bmj.com/cgi/content/full/318/7197/1505/a

[5] “Three lessons for a better cycling future” – Malcolm J Wardlaw, British Medical Journal 2000;321:1582-1585
http://bmj.com/cgi/content/full/321/7276/1582

[6] “Cyclecraft” – John Franklin, 1997
ISBN 0-11-702051-6




I received a reply on 25/06/03. This was clearly a standard letter (my letter happened to coincide with a CTC campaign against the DfT's helmet promotion campaign), evidenced by the fact that it started by attempting to justify the DfT's 'Cycle Sense' campaign, which my initial letter had not mentioned. The letter was 4 pages long, so I won't reproduce it here, but my response is below:





Mr J Richardson
Road Safety Division 3
Department for Transport
Zone 2/13
Great Minster House
76 Marsham Street
London SW1P 4DR

28 June 2003



Dear Mr Richardson

Cycle Helmets

Thank you for your letter of 23 June responding to my concerns about the DfT’s cycle helmet campaign. There are 3 points to which I should like to respond.

First, you claim that those outside your target audience are unlikely to see your “Cycle Sense” posters. I can accept this, although I am slightly concerned about the posters being seen by head teachers and governors of the type who already ban pupils from cycling to school because of the perceived danger. I have not seen the posters myself, but I have seen the corresponding website and I think it highly likely that it will be found by others outside of your target audience. Imagine a grandmother posting to an internet newsgroup or mailing list for cycle safety information and being directed to http://www.cyclesense.net. Or the same grandmother entering “cycle safety” into a search engine – if this search is entered into Google UK then the Cycle Sense site is the seventh hit at time of writing.

While I do not personally find the pictures on the site macabre or discouraging, I am well aware that many others do. My wife’s first 3 thoughts upon seeing the site were: “Dead bodies"; "This will kill you"; "Roadkill". The grandmother in my example might start putting pressure on her son or daughter to discourage her grandchildren from taking part in such a dangerous activity. I can certainly picture this scenario with my own grandmother, or my daughter’s grandmother.

Second, you write: “The point has been raised of the possibility of increased injury risk to bicyclists wearing helmets as a result of a rotational rather than a linear impact to the head. We are not aware of any research on the specific injury mechanisms. We would be grateful if correspondents referring to this could provide details of the evidence.”

I notice that you make no mention of the increased risk of spinal injuries (the DfT report into the effectiveness of helmets [14] mentions increased risks of spinal injury being reported in two of the papers reviewed [7][16]). In any case I find it difficult to accept that the DfT is unaware of the risks of rotational injury, given that these risks have been well known for many years and that John Franklin’s response to your report [5] mentions the risk and gives 2 relevant references [3][9].

It took very little time to find a few more references for the mechanics of rotational head injury, some of which I regret that I have not had the chance to read myself: [2][4][6][8][11][13][15].

Thirdly, you write: “The Department does not agree with the theory that cycle helmet wearing increases the risk of accidents. This theory, known as ‘risk compensation’, has never been proved.”

Proof is not a scientific concept. No theory or hypothesis can ever be proved, except in mathematics. We can only draw conclusions based on the evidence available. Although controversial, I believe there is sufficient evidence to take risk compensation seriously [12]. It certainly seems a reasonable explanation for the often mentioned increase in pedestrian and cyclist fatalities following the introduction of mandatory seatbelt legislation and for the extra risks taken by motorists when roads are made “safer” [10]. The Health & Safety Executive appears to take risk compensation seriously [1].

You make no mention of the mechanisms by which a helmet may increase risk without invoking risk compensation, as described in my letter of 27 May. I repeat: “In warm weather … the discomfort of wearing a helmet is likely to cause lapses of concentration. A helmet will also cause sweat to run into my eyes, having a significant adverse effect on vision. The result is that I would be more likely to crash while wearing a helmet, so for my own safety I choose not to wear one.”

Yours sincerely


Danny Colyer BSc(Hons)

References

[1] Adams, J & Thompson, M - “Taking account of societal concerns about risk; Framing the problem” HSE RR35 (2002)
http://www.hse.gov.uk/research/rrpdf/rr035.pdf

[2] Brain Association of British Columbia - “Concussion in Sports Handbook”
http://www.brainassociation.com/docs/handbook.pdf

[3] Corner, J P et. al. - “Motorcycle and bicycle protective helmets: requirements resulting from a post crash study and experimental research” Federal Office or Road Safety report No CR 55, Canberra, p5 (1987)

[4] Ellerton, A L - “The (ASTM/SEI) Helmet: Setting a Legal Standard” Equine Law
http://www.equinelaw.com/Articles/ellint03.pdf

[5] Franklin, J - “Bicycle Helmet Effectiveness – a broader perspective: A Critique of Department for Transport Road Safety Research Report No 30, 2002” (2003)
http://www.cyclenetwork.org.uk/papers/broader.pdf

[6] Holbourn, A H S - “Mechanics of head injuries” The Lancet, 2, 338-441 (1943)

[7] McDermott et. al. - “The Effectiveness of Bicyclist Helmets: A study of 1720 Casualties” J Trauma 34,834-44 (1993)

[8] Mendoza, I D - “U S Patent Application 20020023291” (2002)

[9] National Health and Medical Research Council - “Football injuries of the head and neck” AGPS, Canberra (1994)

[10] Noland, R B - “Traffic fatalities and injuries: The effect of changes in infrastructure and other trends” Centre for Transport Studies (2002)
http://www.cts.cv.ic.ac.uk/staff/wp22-noland.pdf

[11] Ommaya, A K & Gennarelli, T A - “Cerebral concussion and traumatic unconsciousness: correlations of experimental and clinical observations on blunt head injuries” Brain, 97, 633-654 (1974)

[12] Peltzman, S - “The Effects of Automobile Safety Regulation” Journal of Political Economy, vol 83, issue 4, pp677-725 (1975)

[13] Standards Association of Australia - “Australian Standard 2063.2” (1990)

[14] Towner, E et. al. - “Bicycle helmets – review of effectiveness” (November 2002, published April 2003)
http://www.roads.dft.gov.uk/roadsafety/roadresearch/bicyclehelmets/index.htm

[15] United States Department of Transportation - “Trauma Systems and Mechanism of Injury”
http://www.nhtsa.dot.gov/people/injury/ems/ EMT-I/DISK2/trauma%20system.pdf

[16] Wasserman, R & Buccini, R - “Helmet Protection from Head Injuries among Recreational Bicyclists” Am J Sports Med, 18 (1), 96-97 (1990)





Registered Voter

Danny
 CV   Cycling   Recumbents   Unicycling   Juggling   Other Links 

e-mail address

Note on browser compatibility - I hope that this site will be easily accessible in all browsers. If you experience any problems viewing this site, please let me know what the problem is, what browser you're using and, if possible, where I can obtain a copy for testing.