sapperadam wrote:meic wrote: and pedestrians wearing helmets. it is NOT "reasonably practical" for them to do so
I dont see how it is any more difficult for a pedestrian to wear a helmet than it is for a cyclist to wear one.
Let alone putting the not in capitals. In fact many cyclists dont bother taking their helmets off when they are walking their bikes.
I said it was not
reasonably practical. It is a generic term used in H&S and we cyclists actually use it to justify many things as well. Is it
reasonably practical to force all cyclists to register bikes or have insurance for example? The same reason we are not [i]forced[/] (yet, hopefully never) to wear a helemt is because it not, in my view, reasonably practical to do so. However, that doesn't mean that it is not a reasonably practical measure for a cyclist to make.
Also we could declare any thing (crucifixes as an example) to be a safety aid and insist that they be worn on the grounds that it is "reasonably practical" to wear one while cycling.
You're quite right, you could declare anything at all to be a safety aid, whether or not it would be seen as reasonably practical is another matter.
It is all very well tossing H&S terms about, but please keep in context. I am Professional Head for safety and quality for a company working in a safety-critical industry and previously worked as a Regulator in the same, so I think I can claim to have a smattering of experience in all levels of risk assessment/control.
Reasonably practicable is a test of gross disregard. If you work to achieve ALARP for catastrophic events, there are specific numerical (probability) criteria for levels of incident you need to demonstrate.
However, this is not catastrophic risk but usual day to day risk, so lets take the risk assessment approach to decide what risk controls measures are "reasonably practicable." A cycling helmet is PPE and to talk about whether PPE is "reasonably practicable" or not is doing the usual "I know a bit about H&S but not a lot" thing. Well before then, the Principles of Prevention should be applied.
The Principles of Prevention is Reg 4 of the Management of Health and Safety at Work regs, and following them is an "absolute duty"- you SHALL follow the Principles of Prevention when carrying out a risk assessment and deciding what risk controls to put in place.
So, let's take the Principles of Prevention approach to the risk to cyclists from cycling. To do the assessment properly, we need to define a few more things- place, activity, persons effected (as per the HSE 5-steps model). So, let's take an experienced commuter on well-maintained a touring bike using a mix of town roads, a bit of off-road but decent cycle path and a couple of roundabouts- usual sort of commute. I will take the Principles of Prevention approach to assessing the risk here, but heavily summarized:
The main hazards are being struck by a car/motor vehicle and falling off. We then consider risk (i.e. consequence and likelihood) for each. For a commuter, falling off is generally low likelihood, and the outcome is generally low to medium. Just as not every papercut leads to an infection causing death (that suggestion is how you spot an inexperienced risk-assessor
), not every fall off a bike leads to catastrophic brain damage or death. That's where understanding the details of stats of accident types for your context is important. Biggest risk is being struck by a motor vehicle.
(1) Can we remove the hazard totally?
We need to get to work, telecommuting is not viable so we need to travel. The stats indicate that walking or driving is just as high a risk, so in this case, removing the risk cannot be done.
(2) Collective measures.
Can we put in some collective measures to control the risk?
The risk is significant, and if using H&S regulations, collective measures always take priority over individual measures. So, we would require some segregation in place, motor vehicle speed limits (possibly speed limiters) and site rules enforced. Chances are, we'd ban use of mobile phones too; and we would need competent staff with proper supervision. In the same context, proper enforcement of speed limits, highway code and phone use whilst driving would be required, as would a decent standard of driving, probably with re-tests every couple of years. Things like making bikes and motor vehicles were properly maintained would also come into play.
(3) Personal protective equipment.
At this point, the main risk is controlled. We may consider hi-vis; but cycle helmets would be unlikely as the protective effect in this context is low and they are uncomfortable for a long period. Also, the research indicates that in some circumstances they can increase the risk, plus if we introduce them as mandatory for cycling we also should introduce them for drivers of motor vehicle and pedestrians. Either a blanket introduction or not at all.
So, there's a risk assessment for cycle commuting. Obviously if you are charging downhill on a rocky trail and the main hazard is high-speed collision head-first with a tree, the whole profile of risk controls changes; probably why downhillers wear full-face helmets and body-armour.
Of course, in H&S land as with other things, there is a tendency for those in power to move immediately to "PPE" and indulge in victim-blaming. "Dress em all in PPE and they will be OK" rather than investing in proper collective measures like edge-protection to prevent falls when working on a flat roof.
It doesn't mean that folks cannot wear additional stuff if it makes them feel better inside (so long as it doesn't increase the risk), but in a workplace I wouldn't be able to justify mandating it. I am not a fan of blanket PPE unless it really does control a risk for the majority or wearers. That's not to say some workplaces don't fall on the bandwagons and push cycle helmets for in-work cycling, but equally, lots of workplaces get the whole risk assessment thing wrong too. To properly use the approach requires not only experience but also the willingness to make a decision NOT to put in place a specific available control and so open up potential for criticism or blame in event of an incident, even when using that additional measure would have made no difference to incident happening or outcome!. If I see a risk control system based around lots of PPE and personal measures, then unless it's in a valid context (e.g. firefighters), then it's a clear symptom of someone who doesn't fully understand risk assessment.
Just my view though; ultimately, most (neurotypical) people make decisions with a lot of emotional and symbolic input, so no doubt many will disagree with my analysis!
(No, I don't wear a helmet any more when commuting, because I did the risk assessment, studied the research and made a decision).
TPO