Public comments skew toward eliminating coaster brake requirement for kids' bikes
Jun 23, 2023
WASHINGTON (BRAIN) — A 60-day comment period ended Monday, giving interested people an opportunity to weigh in on whether federal bicycle safety requirements – in particular a requirement that sidewalk bikes have coaster brakes — are outdated. The prevailing opinion of commenters is the coaster brake inhibits kids learning to transition to a hand-brake bike when they're older.
The Consumer Product and Safety Commission staff will look over the 246 opinions expressed online and through the mail before making a recommendation on whether to initiate any changes, a CPSC spokesperson said Tuesday. A deadline to initiate any changes has not been set, the spokesperson added.
In May, the commission voted to accept written and online discussion concerning the 16 CFR Section 1512 regulations and if they adequately address e-bikes. The decision came after woom Bikes petitioned the CPSC to eliminate the coaster brake requirement on certain kids' bikes. Currently, sidewalk bikes — defined as bikes with a seat height of no more than 25 inches — must have a coaster brake. Woom favors hand brakes, specifically its mini V-brakes, with levers that can be adjusted for the smallest of hands, according to the company.
While most Europeans learn to ride first on a balance bike before transitioning to a standard bike with hand brakes, in the U.S. many tiny cyclists learn on coaster brake bikes with training wheels. Europe does not require coaster brakes.
A woom spokesperson told BRAIN that the brand launched an engagement campaign in mid-June to rally support for its opinion that the requirement is a relic of the past and not the proper or safe way for kids to learn how to ride and control a bike.
Some commenters were adamant that the requirement be eliminated — with one saying his 3 1/2-year-old daughter was nearly hit by a car trying to use a coaster brake. That commenter, Rafael Jofre, echoed what many other petition supporters wrote. " ... With today's available technologies, there are better options than foot brakes. Manufacturers must be free to design bikes and provide best technologies available for the safety of our children."
Some want a choice
Others said parents should have a choice to choose coaster brake or hand brake models.
"My argument is not to completely reverse the regulation and require hand brakes," wrote Jonathan Walker. "I just believe the regulation should be removed, and the manufacturers and consumers (parents) should be able to make their own informed decisions. Because I believe the hand brakes were better for my children, I was forced into avoiding a U.S.-manufactured bike. I did have the option to increase my cost by buying a U.S. bike and then modifying it at home with additional parts. I have the skills to do such, but many parents may put their children at greater harm to ask them to modify the bike to avoid the coaster brake."
Justin Blea had a similar opinion.
"Bike safety and equipment has progressed to the point where this law has become cumbersome. We have newer and safer brakes for small children. Coaster brakes are reliable and safe but not always the best equipment in all applications. It would benefit the consumer and manufacturers to write this law differently or to do away with it entirely. Thank you for hearing my opinion, and I look forward to buying my child's first bike without coaster brakes."
Woom is an Austrian brand that entered the U.S. market in 2014 with its woom 2 sidewalk bike, with 14-inch wheels. The model has a coaster brake and the mini V-brakes with adjustable-reach levers. Woom chose brakes with power appropriate for kids, and specs Jagwire cables to reduce friction. Brake housing is color coordinated so kids learn which lever controls which wheel. The woom 2 is spec'd with a freewheel in Europe, and in the U.S. woom separately sells a rear wheel with freewheel for the model for $19.90 that allows woom 2 customers to swap out the coaster brake for a freewheel.
Caden Smith was one of the few who opposed eliminating the coaster brake mandate.
" ... The foot brake is easy to operate for all sizes and ages. It stops the movement of the wheels and gears rather than just slowing down the momentum of the bike through pads, which will be worn down over time, and if not checked will cease to slow the momentum of the moving bicycle. Furthermore, not all children have the reach, grip strength, or fine motor skills, to safely operate a hand brake. For these reasons, I foresee this petition would simply further the endangerment of our young children. ..."
Smith called for the CPSC to find a middle ground.
"... Therefore, I suggest that manufacturers be allowed to produce both options, and leave it to the discretion of the parents or legal guardians to decide if their child is in need of a foot brake or is able to safely operate a hand brake."
Coaster brakes offer 'security'
A commenter going by the "A H" wrote as a lifelong cyclist, "I can appreciate the security and safety of a child's first few bikes being coaster brake equipped."
PeopleForBikes, which told BRAIN in June it would provide the CPSC with a comment on behalf of the industry, does not support woom's petition, with Policy Counsel Matt Moore writing in an attached letter dated Monday:
"... A review of the petition and supportive public comments submitted to date fails to reveal any scientific data or study that concludes that children younger than age 6, considered as a group, generally have the capability to use hand brakes safely and effectively. Rather, the commenters uniformly make conclusory statements about the relative safety or convenience of coaster brakes, or anecdotally cite the ability of their children to learn the use of hand-actuated brakes. The petition only notes that there is no study showing that foot brakes are safer, and that hand brakes 'may be safer.'
Moore went on to write about the danger of a "pitch-over" accident when more force is applied to the front brake and the rider is thrown over the handlebars. in contrast, when a coaster brake is applied forcefully, the bike will only skid.
"Additionally, the regulations already permit a manufacturer to equip a sidewalk bicycle with both a coaster brake and one or more handbrakes," Moore wrote. "This would enable parents of children perceived to have more advanced abilities to teach them the use of hand brakes. ..."
Other regs attract less scrutiny
Fewer comments directly addressed the overall 16 CFR Section 1512 regulations, especially how they relate to e-bikes. When the CPSC voted in May, Commissioner Mary T. Boyle also requested the agency's technical staff conduct a study of e-bike "hazard patterns."
16 CFR Section 1512 defines a bicycle as:
Vince Amodeo worked 17 years for the CPSC before retiring in 2019. He was the point man in the last effort to update the regulations and says they still need to be revisited. He also worked with ASTM and ISO regulation agencies in developing their standards.
"I can attest that it is extremely difficult to change federal regulations, even if they are outdated," he wrote. "I've been a bicycle rider for over 55 years. The entire bicycle regulation needs a thorough review and update. Most of the test requirements were originally written to apply to steel bicycles built for children and adults in the early '70s. These bikes did not use advanced materials such as aluminum and carbon fiber. They did not have disc brakes. There were no electric bicycles. They were primarily used on pavement. Modern bicycles now include a vast array of manufacturing materials, such as aluminum, carbon fiber, and titanium. They also can have disc brakes and electronic shifting.
"In addition, there are now a multitude of use classes that are not addressed in the current regulations. This includes mountain bikes, gravel bikes, dirt jump bikes, BMX bikes, downhill bikes, hybrid bikes, in addition to road bikes. The existing test requirements are not rigorous enough to apply to some of these bicycle types and are too rigorous for others. The regulations need to apply to all bicycle types and uses, which they currently do not. Instead, CPSC should eliminate many of the existing test requirements and refer to existing ASTM and ISO standards."
Amodeo also wrote that he favors removing the coaster brake requirement.
E-bike safety addressed
Charles DiMaggio, professor of surgery and director of injury research for the New York University School of Medicine, wrote an in-depth response about e-bike safety. He said in a peer-reviewed analysis of CPSC data, e-bike and e-scooter riders were three times more likely to be injured seriously enough to require hospitalization than traditional pedal bike riders.
"Persons injured using e-bikes skew considerably older than those using powered scooters or pedal cycles, which may account for some of the comparative increased injury severity," he wrote. "A younger person might walk away from a crash that would put an older person in the hospital. We also surmise that e-bikes are more likely to be used for commercial and food deliveries, putting drivers in direct contact with motor vehicle traffic. And in fact in our study, e-bike injuries were three times more likely to involve a collision with a motor vehicle than powered scooter injuries. ..."
"E-bikes differ sufficiently from pedal-cycles that they require separate treatment by the CPSC, including rules and regulations to increase safety. Some of those rules should include requiring helmet use, strongly encouraging training for new riders, options for speed restriction engineered into the vehicles, and police reporting requirements for crashes involving e-bikes that result in injury requiring hospital transport. From a research perspective, there also is a need for exposure-based studies, e.g. number of injuries per vehicle-mile driven, to really get at whether the actual risk is increasing or whether the increasing number of injury reports is more a function of their increasing popularity and use. Finally, we encourage the CPSC to give particular attention to vulnerable groups using e-bikes like commercial delivery persons, a group which our team at Bellevue (Hospital) has looked at in the past. These individuals provide an important service in many urban areas and were essential in helping folks weather the pandemic. Their safety deserves increased attention."
Some in the industry have said with battery safety also a consideration, the CPSC could consider adopting ISO 4210 and melding UL standards. ISO 4210 is a standard created by the International Organization for Standardization and created after the CPSC rules. ISO 4210-10 is a technical specification, not a standard, that covers e-bikes.
Moore said PeopleForBikes supports the creation of new e-bike-specific regulations based on ISO 4210 and relevant parts of UL 2849.Some want a choiceCoaster brakes offer 'security'Other regs attract less scrutinyE-bike safety addressed