On Wed, 27 Aug 2003 07:00:14 +0900, James Annan <
[email protected]> may have said:
>This is not actually the 'official' signed letter which is in the post, but I received the
>following via email recently:
>
>"Based upon the information currently available, the staff does not believe the problem identified
>necessitates further action by the Commission under Section 15 of the CPSA. However, the Commission
>has recommended that the ASTM Bicycle Committee, which meets in October 2003, take this matter
>under advisement for further discussion, additional testing and problem examination."
>
>Section 15 of the CPSA can be found at
https://www.cpsc.gov/businfo/cpsa15b.html
I'll just toss in an observation or two.
The CPSC tends to view products differently based in part on who they are sold to. If a product is
mass-marketed to the public in large quantities, and the "average" user may be either an untrained
and unskilled juvenile or someone who is unlikely to be familiar with routine safe usage, mantenance
and repair issues and their implications, then they apply a less forgiving standard of what creates
an unacceptable hazard. If the product's principal market is to skilled enthusiasts or technically
qualified persons and particularly if it is customarily sold for use by persons engaged in an
actvity that has some inherent hazards already, then the application of the standard is somewhat
different; if the hazard is recognized as being generally avoidable by proper maintenance and
inspection, they are unlikely to find that there is a fundamental hazard involved for skilled users.
I believe the bike disk brakes are being judged as properly belinging in the latter category.
As an example of the difference: I seem to recall that quite a few years ago, a brand of rock
climbing rope was recalled because it was subject to internal fiber breakage which would not be
revealed by normal inspection techniques. Thus, even a skilled user would be at risk of serious
injury from the defect, and a recall was merited. Conversely, however, the CPSC has not demanded the
recall of the non-climbing-quality imitation carabiners which are presently being marketed as
keychains (and such) because the perception is that even though they are often not marked "do not
use for climbing", no real rock climber would make the mistake of using one.
It is important to note that at present, largely due to their cost, bike front disc brakes are
primarily marketed to cycling enthusiasts; these buyers are probably regarded as being persons
likely to be familiar with the safety and maintenance issues associated with their equipment, and
therefore are probably being judged able to evaluate the risks and take the actions needed to
control them in the use of the brakes in question. As such, restricting the sale or use of such
units would not seem warranted. If, however, some manufacturer were to begin marketing a front disk
brake mounted to a QR wheel on bikes at the under-$200 price level, the attitude might change.
If my impression is correct, and this is indeed the rationale that is being applied, then I don't
have a problem with that policy. YMMV.
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