Quad Bike Safety: Issues Paper

Response 959647961

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What is your organisation?

Kids Health

Questions 1-6

1) Can you provide additional data or information on costings of injuries and fatalities caused by quad bikes?

2) Would design changes to quad bikes be likely to reduce the number of injuries and fatalities caused by quad bikes in Australia?

The available evidence shows that rollovers are a significant cause of fatalities and injury to riders of quad bikes, so clearly design changes are required to minimise this risk.

3) If you answered ‘yes’ to question 2, what design changes do you consider would have this effect? Which design features, if any, should a safety standard mandate or prohibit? In particular the ACCC is interested in understanding design changes that are likely to reduce:

Design changes that minimise the risk of fatality and injury resulting from a quad bike rollover should be the priority along with better evidence that smaller sized quad bikes intended for children up to sixteen years of age actually do reduce their risk of injury and death.
Design changes that address these risks should be included in any mandated safety standard.

4) If your view is that design features should be mandated or prohibited to increase quad bike safety, could the regulation be designed to encourage innovation rather than prescribing particular products or technical solutions (for example by ensuring fitting points or attachment mechanisms to allow the development of improved CPDs or ROPSs or by prescribing performance-based outcomes rather than technical designs)?

Innovative approaches to minimising the identified risks should be allowed for in any mandated regulation. The desired outcome is improved protection for riders and passengers of quad bikes. While ROPS and CPDs are the current systems, allowing for innovation may produce a redesign that manages the risks in a better way.
Examples of innovative approaches to a known injury risk can be found in other products, for example nets on domestic trampolines.

5) If any or all of these design changes were implemented in Australia, are you able to estimate the additional cost that would be imposed on Australian suppliers?

6) To what extent does the US Standard satisfactorily address design features that ensure quad bikes are safe for use? Do you consider that Australia should adopt a mandatory safety standard similar to the US Standard? To what extent would this option impose additional costs on Australian suppliers or create barriers to trade?

Unknown, however it may be a starting point.
Australia has led the development of new Standards in other areas, which have subsequently been adopted internationally. While there are costs associated with developing a new standard instead of adopting an existing standard, if the existing product does not meet the need or is inadequate then that cost should be accepted.

Questions 7-12

7) Are consumers currently getting adequate information at the purchase point about quad bike use and limitations or safety information and equipment? Should there be additional warnings or instructions displayed at the point of purchase or provided with the sale of quad bikes?

Consumer information is available at the point of sale as well as from other locations however experience from other sectors suggests that point of sale information can be overlooked or undermined by inadequately trained or informed sales staff and vested interests.
Providing warnings and information is essential but it is only part of what is needed. Consumer beliefs based on their own ‘source of truth’ and their own abilities often discount or override point of sale information and warning labels, while instructions are often ignored. Many full sized quad bikes already carry warnings about usage by children less than 16 years of age, yet some consumers still permit children to ride quad bikes and do not supervise the activity.

8) In relation to the option of a consumer safety rating system:

Over time, ratings programs for cars and for child car restraints have demonstrated improvements in safety features so a suitable safety ratings system for quad bikes is likely to have a similar impact provided it is appropriately endorsed and promoted.

The quad bike supply industry is a multi-million dollar industry in Australia so investment in improved safety to save lives, minimise hospital costs and prevent permanent disabilities is a small proportion of the value of the market

9) If your view is that regulation is needed to reduce the number of injuries and fatalities caused by quad bikes in Australia, how should these be implemented? One proposed option is to prohibit or mandate particular design features; another is to increase consumer information, including through a consumer safety rating system; a third option is a combination of both:

Approaches that combine a number of different strategies at different levels of prevention are often the most successful.
The common hierarchy of injury prevention is to consider
a) engineering strategies that will eliminate the risk completely;
b) environmental strategies that minimise exposure to the hazard;
c) legislative and enforcement strategies
d) education strategies
e) personal protective equipment

10) If the ACCC recommends a mandatory safety standard for quad bikes:

A standard should apply equally to all usage purposes of quad bikes
There needs to be more evidence that smaller sized quad bikes intended for children do actually minimise the risk of injury or fatality.
Both SSVs and quad bikes should be covered
A standard should commence as soon as possible
Yes there will need to be a transitional provision – but not too long a period
A standard should have a review date, not necessarily an expiry date
A standard should apply to both new and second hand vehicles. Some evidence indicates that up to 50% of quad bikes are purchased via the second hand market. It is acknowledged that there would need to be effective simple solutions for the second hand market.

11) What is the life cycle of quad bikes in Australia? For example, on average how long do consumers use quad bikes before the vehicle is retired? How long might it take before the current stock of 380,000 quad bikes is replaced by new stock that satisfies requirements of a safety standard, if imposed?

Anecdotal evidence suggests that quad bikes have a long life cycle and can pass through several owners with only major breakdown or irreparable damage leading to retirement.
Waiting for natural attrition could mean a ten year transition period, in which time more people, particularly children and young people remain exposed to the risk.