Personal Protective Equipment (PPE)
The British Motorcyclists Federation on the Personal Protective Equipment Issue
The British Motorcyclists Federation (BMF) is concerned at reports that motorcyclists are continuing to be sold clothing products in contravention of the PPE Regulations.
Quite simply, it is an offence to claim or imply that motorcycle clothing is protective unless the product in question has been independently tested and bears “CE” marking.
The BMF understands that there is confusion in the marketplace regarding the scope of the legislation, and many retailers are merely continuing, in good faith, to promote clothing products in the way they have for many years, but never-the-less in direct contravention of the new regulations.
This briefing is intended to informing consumers more fully on this complex subject. The BMF also believes retailers will find of interest.
Motorcycle clothing and standards - a buyer's guide
Good protective clothing for motorcyclists has been available for many years. However, how many riders are sufficiently experienced in materials science, clothing design and the mechanisms of injury in accidents to determine in a shop which jacket for example is truly protective and which jacket merely looks protective? The new European Standards set minimum levels for various characteristics of protective clothing that should ensure all clothing claiming to conform to the standards will provide a reasonable level of protection. Clothing, boots and gloves subjected to testing and bearing an independent and recognisable mark of fitness for purpose will be a less risky purchase than unmarked clothing.
The Personal Protective Equipment Directive neatly divides motorcycle clothing into that which is protective and that which is not. The Directive's stipulations are quite clear in this regard, and following lengthy meetings between the European Commission, industry and riders' groups, agreement on how to categorise motorcycle clothing has been reached.
In practical terms, motorcycle clothing can be divided into three groups:
Non-protective. Outer clothing constituting a barrier to the elements: heat, cold, wind and rain. Claims for any other form of protection breach the PPE Regulations, UK law, and industry and riders' groups' agreement with the European Commission.
Non-protective supplied with CE impact protectors. A non-protective outer garment, as above, fitted with for example accredited shoulder, elbow, knee and back protectors bearing CE marking.
Protective. Jackets, trousers, one-piece or two-piece suits, boots and gloves claimed by the manufacturer to be protective. Tested according to the European Standard (or the Cambridge or SATRA standards) and bearing CE marking. Garments must be fitted with CE marked protectors.
What defines which group a garment falls in to?
Quite simply, whatever the manufacturer claims it to be. As is often the case in such situations, however, there are a few mendacious companies who are taking advantage of the situation, and the consumer's lack of in-depth knowledge, to make capital.
For example, limb and back protectors can only be present for one purpose: to protect. There are some manufacturers, however, who are still fitting components made from plastic and foam into the limbs and back of garments. There are also boots and gloves with similar components. The likelihood is that the consumer will infer that these are impact protectors, but because the manufacturer does not claim them to be so, they take advantage of the loophole.
Where CE marked protectors are fitted to a non-protective garment (typically a textile jacket, but equally applicable to leather jackets, trousers and suits), some retailers are misinforming consumers, claiming that the whole garment is approved. It is not, and retailers who provide such information contravene, for example, the Sale and Supply of Goods Act and the Trade Descriptions Act.
Some such garments feature a “CE” label sewn to the lining, but in fact, this refers only to the status of the fitted protectors. This is misleading. Do not allow yourself to be misled.
Finally, how has the manufacturer or distributor described the garment in their advertising? What did the clothing salesperson at your local motorcycle shop say about the clothing as he tried to sell it to you? The European Commission's agreement with industry and riders' groups is quite clear in this regard, and the following advice has been issued:
“If a manufacturer explicitly claims, or implies in sale literature and /or advertisement, that a garment offers protection because of specific additional features, these additional features shall be qualified as “PPE”. As such, they must comply with the provisions of the PPE Directive.
“The specific features may materialise in e.g. impact protectors for limb and/or back, pads for elbow and /or shoulder and protection from cuts and abrasions (not exclusive listing of examples)”
Consequently, phraseology such as:
“absorbs shocks during falls”
“affordable protection against wind, rain and tarmac”
“for protection, quality and style”
“total commitment to safety”
can hardly be credibly be argued not to constitute a claim that the product so described is protective.
So how can the consumer tell which group a garment falls in to?
There is a simple answer: by law all CE marked PPE must be supplied with detailed, printed information on selection, care and maintenance of the product. Protective motorcycle clothing and impact protectors must be supplied to the consumer with such information and it must describe, for example: how the product was tested, the test data generated, how to remove and reinstall protectors (as may be necessary when cleaning the garment) and the anticipated service life or how to recognise when the PPE requires replacement. Contact details for the European Notified Body responsible for the testing and certification will also be provided, from which you will be able to contact them to determine the authenticity or otherwise of the manufacturer's claims. If you are unsure how to go about this, your local Trading Standards Department may be prepared to assist.
In brief: treat “no information” as “ not approved ”.
“The retailer told me that the European Standards do not apply to leisure riders, only ‘professional motorcyclists' ”.
Riders' groups agreed to support the standards if leisure riders' clothing was specifically excluded, to prevent the standards being used to support compulsion. The standards are for clothing not users; consequently, they can still be used to CE mark clothing for non-professional use. Furthermore, the Cambridge Standard and the SATRA alternative technical specification, which jointly form the basis of EN 13595, are still available and do not discriminate between leisure, professional or competition users. Simply, there is no excuse for industry not to offer accredited products.
“I have been told that the cost of testing and certification is so high, it would price CE marked clothing out of my reach”
This is another red herring. It actually costs less to test and certify a motorcycle suit than it does the average pair of safety shoes - as proven by the fact that the first companies to achieve EC type approval were the small, UK manufacturers of bespoke motorcyclists' clothing. Furthermore, the main clothing brands are buying CE approved impact protectors at substantially lower prices than they were five years ago. In fact, these major clothing brands, with marketing and advertising budgets in the hundreds of thousands of pounds, could cancel one magazine advertisement and entirely cover their testing costs. They have the budget.
European Standards for motorcyclists' protective clothing
Take a long, hard look at your motorcycle clothing. Do you know what it is? Not in the sense of is it leather or textile, one piece, two-piece or separates, and is it padded; but is it protective clothing or is it “fashion” clothing - because since 30th June 1995 those are the legal distinctions.
The requirements and provisions of the Personal Protective Equipment (PPE) Directive (89/686/EEC), and their bearing on motorcyclists' protective clothing, have been explained within BMF literature many times in the past, but a brief review seems appropriate.
The PPE Directive became an active part of UK law on 30th June 1995. Since that date, suppliers of protective clothing and equipment “designed to be worn or held by an individual for protection against one or more health and safety hazards” (the Directive's definition of PPE) have been required to categorise their products as PPE, or non-protective; and to CE mark them by self-certification or through independent, third-party accreditation by test facilities known as “European notified Bodies”.
Motorcycle clothing was not originally going to fall within the scope of the legislation. Following the collapse of the ACU Standard for racewear (more on which later), however, a meeting took place between Dr Garth Willson and a Mr Petrovich, of the European Commission, in which the latter was convinced that motorcyclists would benefit from the availability of products manufactured to a European Standard. The European Standards agency CEN (Comité Européen de Normalisation) convened a technical subcommittee with the long title of CEN/TC 162/WG9 - or “WG9” - in order to develop these standards.
In 1998, EN 1621-1 was published, and motorcyclists will be familiar with this, because limb protectors fitted to garments are often claimed to meet this requirement (in fact no protector should be marketed if it does not conform to this standard, but that's a subject we'll be looking at in Part 3). Provisional standard prEN 1621-2, which covers back protectors, and which may be published as a full standard by the time you read this, is starting to be promoted in the form of recently-accredited products (for example the T-Pro “Forcefield” back protector). Finally, there are the garment, glove and footwear standards: EN 13595 Parts 1 - 4, EN 13594 and EN 13634 respectively.
In this article, we will be looking at the development and application of the CEN standards for motorcycle clothing, their background and some of the controversy that blighted and slowed their delivery.
The path to standards
In February 1984, one of the monthlies carried an advertisement for motorcycle suits “ made to ACU Standard ”. An enquiry to the ACU on how other companies could gain this accreditation revealed the advertiser's claim was a lie; there was no ACU Standard and action was taken to prevent the claim appearing in print again.
Certain personnel within the ACU recognised, however, that the Standing Regulations for road-racers protective clothing - the ACU had merely adopted the FIM's prescriptions - could be usefully improved. The text is at best ambiguous and at worst entirely meaningless. For example, it requires that: “ The following areas must be padded with at least a double layer of leather or enclosed plastic foam at least 8 mm thick:- shoulder, elbows, both sides of the torso and hipjoint, the back of the torso, knees ”. The requirement for the shoulders, elbows and knees can be complied with simply enough. It is the requirement for the other parts of the body that raise a question mark over the effectiveness of the requirements. Read one way, it could be argued that the regulations render back protectors mandatory. Read another, few mass-production manufacturers comply with the requirement for double leather between the armpit and the hip. Anomalous, ambiguous, unenforceable and, of course, unenforced.
Motivated by the number of low-quality suits that were sustaining catastrophic failure during racing crashes - which at one point resulted in the ACU issuing an unprecedented ban on one leading European manufacturer's suits - in 1988, the ACU established a technical subcommittee to prepare its own standard for racewear. Members of this committee included ACU personnel, scrutineers, medical experts and garment manufacturers.
But no sooner had this group delivered the final draft of their document than the ACU decided not to publish it. The reason subsequently admitted was that the ACU had a fear that if a competitor sustained injury, they might be held responsible as the “accreditation body” for his suit. Far better for the ACU to require competitors to wear products accredited by another body - BSI-approved helmets for example.
The European Commission becomes involved
It was at this point that Dr Willson, who had been a member of the ACU standard committee, travelled to Brussels and convinced Mr Petrovich, whose son happened to be a motorcyclist, to encompass motorcycle clothing within the scope of the standardisation programme instigated in response to the recently published Personal Protective Equipment Directive.
German standards agency DIN were appointed as the secretariat for Working Group 9, which held its first meeting within DIN's offices in the former East Berlin in August 1991. The committee's early efforts were primarily focused on developing a standard for limb protectors, but outside of the meetings, controversy was building.
The European motorcycling industry feared that the publication of PPE standards could lead to motorcyclists being compelled to wear approved clothing. Both the Commission and CEN were lobbied by industry and riders' groups to exclude motorcycle clothing both from the scope of the Directive and the standardisation programme.
At a pivotal meeting with Commission officer Mr J-P Van Gheluwe, the industry demonstrated a textile jacket, which, it was claimed, merely represented a barrier to non-extreme ambient conditions of wind, rain and cold. Such products for private use are specifically excluded from the scope of the Directive, and so the industry considered a block exemption for all motorcycle clothing to be justified.
Unfortunately, someone had forgotten to remove the shoulder and elbow protectors from the jacket, and when one of the Commission delegation enquired “ what are these meant to be? ”, an industry representative answered honestly and instinctively “ they are protectors ” - which immediately resulted in the Commission delegation pronouncing them to therefore be PPE and consequently within the scope of the Directive!
A compromise was reached whereby motorcycle clothing intended for private use and providing protection only from non-extreme ambient weather conditions would not be considered as PPE. Any protectors fitted to, for example, the elbows and shoulders were considered to be PPE and therefore to be tested and approved. If, however, a manufacturer specifically claimed or implied in literature or advertising that in addition to fitted protectors, the garment also provided other forms of “special” protection (e.g.: abrasion and cut resistance), then the garment would also be considered to be PPE and subject to testing and certification.
Progress is made
Progress after that point wasn't entirely controversy-free, but a standard for clothing which had been submitted by the British Standards Institution (BSI), and which combined the requirements of the remarkably similar Cambridge Standard and test house and Notified Body SATRA's alternative technical specification was used as the basis of the CEN standard for motorcycle clothing. Through a series of separate project groups operated under the control of WG9, a total of eight product standards started to take shape.
In December 1997, the first WG9 standard to appear in print was EN 1621-1 “ Motorcyclists protective clothing against mechanical impact - Part 1: Requirements and test methods for impact protectors ”.
The garment standard EN 13595 “ Protective clothing for professional motorcycle riders - Jackets, trousers and one-piece or divided suits ” finally appeared during the late summer of 2002. This has been divided into four parts: one part covering general requirements and one covering each of the three test methods. In response to a suggestion by riders' groups - embraced by industry and accepted by the Commission and CEN - the scope of these documents was amended from earlier versions to encompass clothing for use by professional riders only. This step was taken to provide a barrier to the CEN standards being used as the basis of further legislation making the wearing of approved PPE by leisure motorcyclists compulsory.
Footwear standard EN 13634 and glove standard EN 13594 also feature a scope amended to encompass professional use only. These were published at the same time as EN 13595, which is important since the standards share many common test methods.
Finally, prEN 1621-2 “ Motorcyclists protective clothing against mechanical impact - Part 2: Motorcyclists' back protectors - Requirements and test methods ” has just completed its Formal Vote stage and it is anticipated this document will appear in print early in 2003 - perhaps even by the time you read this.
After eleven-and-a-half years, finally a series of authoritative standards is available that will deliver to the marketplace, and thence the consumer, fit for purpose motorcycle clothing bearing an independent, recognisable mark.
Remember when buying motorcycle clothing; if claims for special features, CE armour etc. are mentioned in the advertising then the protectors - and, if the claims extend to it, the clothing - must by law be CE marked. It has been possible to purchase type-approved and CE marked motorcycle clothing since the Cambridge Standard's publication in 1994. Motorcycle clothing manufacturers who have accredited their protective clothing include:
ASP (leather clothing)
BKS (leather clothing)
BMW (certain models of boots)
Carrerra (leather clothing)
Crowtree (leather clothing)
Crusader (leather clothing)
Fowlers of Bristol Limited (textile clothing)
Hein Gericke (Hiprotec ® limb protectors; boots)
Jofama (leather and textile clothing; limb and back protectors)
Mir Yousaf Leatherware (Pvt) Limited (leather clothing)
MJK (leather clothing)
MW (leather clothing)
Odell T-Pro (back and limb protectors, including components fitted into undergarments)
Planet Knox (back and limb protectors, including components fitted into undergarments)
RS Performance Protection (leather clothing and gloves)
Scott Leathers International Limited (textile jackets)
Zak (leather clothing)
Many other companies market limb and back protectors which are claimed to have been tested and approved against the requirements of EN 1621 Part 1 or Part 2 respectively. Check the manufacturer's information which is required to be supplied with protectors for further details. If the information is not present, treat the protectors as not approved and the manufacturer's claims as false.
The European motorcycle clothing standards explained
Good protective clothing for motorcyclists has been available for many years. However, how many riders are sufficiently experienced in materials science, clothing design and the mechanisms of injury in accidents to determine in a shop which jacket for example is truly protective and which jacket merely looks protective? The new European Standards set minimum levels for various characteristics of protective clothing that should ensure all clothing claiming to conform to the standards will give a reasonable level of protection. Clothing, boots and gloves subjected to testing and bearing an independent and recognisable mark of fitness for purpose will be a less risky purchase than unmarked clothing.
Whilst this has yet to be recognised as the important landmark in motorcycling's history it represents, it means nothing if the requirements of the standards themselves are set so low or so high as to be meaningless or unachievable. Whilst criticisms have been levelled that certain aspects of the standards could have been more stringent, in the main the standards represent a useful starting point for further development - both in the documents themselves and in the products they will deliver.
Impact protector standards
EN 1621-1 - Motorcyclists' protective clothing against mechanical impact - Part 1: Requirements and test methods for impact protectors
Many motorcyclists will be familiar with EN 1621-1, because since its publication in 1997, shoulder, elbow, knee and, to a lesser degree, hip protectors marked as meeting the requirements of this standard have appeared in increasing numbers across the whole range of motorcycling garments.
Protectors are tested on the same apparatus used to evaluate many other forms of impact protection, including horse riders' body protectors, martial arts protectors, cricket equipment and riot protection for the police.
Simply, the apparatus is a tower mounted on a one metric tonne block of steel or concrete, to which is bolted a load cell. The product for testing is mounted the relevant one of a series of anvils, representing the various parts of the human body, which is bolted above the load cell. Impactors broadly replicating the “threat” (a flat road surface, a fist, a cricket ball or a brick, for example) are dropped onto the sample and the transmitted force received by the load cell is recorded. Picture 1 shows a protector under test. The standard specifies the impact energy of the impactor and the maximum permitted transmitted force. For motorcyclists' impact protectors, the impact energy is 50 Joules (roughly the equivalent of being struck by an average 2.5 kilogram house brick dropped from 2 metres) and the mean transmitted force should not exceed 35 kiloNewtons (kN).
prEN 1621-2 - Motorcyclists' protective clothing against mechanical impact - Part 2: Motorcyclists' back protectors - Requirements and test methods
Draft standard prEN 1621-2 covers back protectors. This may well have been published as a full standard by the time you read this article. The impact energy is the same as for limb protectors, at 50 Joules, but the transmitted force is lower than for limb protectors at 18 kN for “Level 1” products and 9 kN for the higher performance “Level 2” products. There has been criticism of the standard from medical experts who consider the transmitted force levels too severe; citing decades of automotive research which indicates 4 kN is the maximum force the brittle bones which form the human ribcage can withstand before they fracture. Four kiloNewtons is the requirement adopted in standards covering, for example, horse riders' body protectors and martial arts equipment.
Attempts to reduce the transmitted force requirement to 4 kN and to correspondingly reduce the 50 Joule impact energy requirement were strongly resisted by industry, who claimed consumers would be “confused” by different impact energy requirements between EN 1621-1 and EN 1621-2.
In truth, it was in industry's commercial interests to test both types of protector at 50J, since they could then extol the efficacy of back protectors which, when struck with the same impact energy as limb protectors, transmitted only 9 or 18 kN compared to 35 kN. The consumer would be unaware that subtle differences in the impactor and anvil were responsible, still less aware that 9 kN was still more than double the safe limit supported by medical experts. Furthermore, during the late 1990s, some companies had used the wholly inappropriate EN 1621-1 to CE mark their back protectors. Commercial objectives were given priority over consumer safety.
Despite these concerns, EN 1621-2 represents a starting point from wholly unsafe products should be rendered obsolete and unsaleable. It will be important, however, for consumers to ensure back protectors are marked with the correct standard number, if they are not to mistakenly purchase an old stockFinally, there are a small number of back protectors on the market which have been dual-tested against the requirements of EN 1621-2 and also against a 4 kN transmitted force requirement. Reading the manufacturer's technical information will disclose which are the superior products. item marked to EN 1621-1.
EN 13595 Parts 1 - 4 - Protective clothing for professional motorcyclists - Jackets, trousers and one-piece or divided suits
As the title says, and as has been explained elsewhere in this series of articles, the scope of EN 13595 encompasses garments for use by “professional motorcyclists” only.
When it became apparent that their political lobbying of the European Commission and European Standards agency CEN had failed both to have motorcycle clothing specifically excluded from the scope of the PPE Directive and for the programme to be dissolved, industry looked to other ways to slow development of the standards.
Claimed to be to provide yet another barrier to legislators to use the clothing standards as the basis for compulsion, the suggestion was tabled that the document should be divided into as many parts as possible. It was logical to follow the format of other product standards, with a general requirements document supported by documents describing each of the test methods. This slowed progress down slightly, but not significantly given the eight years it had taken to get to the point where advanced clothing drafts were even in circulation!
The four parts of EN 13595 are as follows:
Part 1: General requirements
This “umbrella” document establishes broad technical requirements for materials and the performance criteria for materials and assemblies. For example, the materials and components which make up the garment are not permitted to contain chemicals which are known to be hazardous to the health of the wearer, and which may leech into the skin when the garment becomes wet or when the wearer perspires.
Part 1 also covers design principles and explains the controversial “zoning” principle for motorcycle clothing where the protective performances of different parts of the garment are proportionate to the severity of the forces they will be expected to withstand in an impact with and slide along a hard, abrasive road surface. For example, the various limb joints and the buttocks are expected to provide a significantly higher level of impact abrasion, impact cut and burst resistance because these are the areas of a garment which are most at risk of heavy and prolonged contact with the road.
The ergonomic performance of the test clothing is also evaluated via a brief series of standardised tests. A further important test is for “restraint”. Many otherwise satisfactory garments in the marketplace exhibit sleeve and ankle cuffs that are significantly oversized, so an assessment is made of the resistance of the sleeves and legs of the garment to ride up the limb and expose the wearer to injury, or the join between the two halves of a two piece suit separating and allowing the wearer's midriff to become exposed to the road.
Part 1 also specifies two levels of protective performance: Level 1 and Level 2. Clothing meeting the Level 1 requirements is defined as “ Clothing designed to give some protection whilst having the lowest possible weight and ergonomic penalties associated with its use ” whereas Level 2 clothing is said to be “ Clothing providing a moderate level of protection, higher than that provided by level 1. There are, however, weight and restriction penalties in providing this level of protection ”.
In practical layman's terms, Level 1 clothing should provide adequate protection in accidents at urban speeds, not higher than 30 mph/48 kph. Level 2 clothing should provide adequate protection in higher speed accidents but may not subsequently be reusable or repairable. If even higher levels of protection are required, clothing should further meet the Level 3 requirements of the Cambridge standard or the SATRA alternative technical specification.
Part 2: Test method for determination of impact abrasion resistance
During the development of this standard, a number of existing test methods were proposed and discussed. Some were found not to be suitable for testing certain of the textile materials increasingly in use in motorcyclists' clothing, and the final choice came between the “Darmstadt” machine (which is used by several textile weavers and motorcycle clothing manufacturers; notably Schoeller, BMW and Alpinestars) and the “Cambridge” machine conceived and built by Dr Roderick Woods of the Protective Clothing Research Facility (PCRF) at Cambridge University.
Both machines were uniquely developed for the testing of motorcycle clothing, but employ distinctly different criteria to assess clothing materials. The Darmstadt machine consists of a “doughnut” of concrete, with a rotary system emerging from the centre from which one or more sample holders are suspended. An electric motor spins the sample holders to a specific number of revolutions per minute and then the sample holders unlock from the central shaft, fall onto the concrete and continue to spin whilst gradually coming to rest. The test sample is judged on the basis of the difference between its mass prior to and subsequent to testing.
Supporters of the method claim that it more accurately mimics the action of clothing in a real accident; a reduction in speed from initial velocity to a halt. Critics claim that the constitution and abrasiveness of the concrete cannot be adequately controlled, that the surface condition changes as debris from the previous “sweep” of the sample holders, further affecting results, but most seriously that this method approves materials which are known to be wholly unsuited to use in motorcyclists' protective clothing; for example sheep nappa.
Despite these criticisms, the Darmstadt machine initially found favour within the standards committee - possibly because the machine was already in use in industry and there was reluctance to invest in another device! Darmstadt University were given every opportunity to address the areas of technical concern that had been levelled at their device, but failed to respond. Consequently it was decided to write the standard around the Cambridge machine.
The Cambridge machine has been used to develop, test and certify every leather and textile product to be subject of EC Type-Examination and bearing CE marking. At least three have been built: at PCRF, SATRA Safety Product Centre and the device used for many years by RiDE magazine for its clothing tests.
A heavy duty abrasive belt of known grit value and manufactured to a standard, spins at a constant speed of eight metres per second or just under 18 miles per hour. The test specimen of garment material is mounted on a hinged arm that is released and falls onto the moving belt. A fine copper wire fixed across the surface of the specimen is cut and starts an electronic timer. The test continues until the sample is abraded through, whereupon a second copper wire is cut and stops the timer and the time taken from contact to perforation is recorded. The minimum times for each of the zones are stipulated in Part 1. Picture 3 shows an impact abrasion test in progress and Picture 4 shows an abraded test specimen.
Brushes and a vacuum debris removal system ensure the surface of the abrasive belt is continually cleaned. The method tiers materials according to a hierarchy supported by anecdotal evidence. Leather, textiles (wovens and knitteds, including aramids) and plastics can all be evaluated. The device has also been adopted for use in other standards where there is a requirement for products to be tested for their abrasion resistance against road surfaces, such as roller skating protectors.
Part 3: Test method for determination of burst strength
An adaptation of a long-established international test method. A circular test specimen is cut from a garment and securely mounted in a cylinder. Below the specimen is a flexible membrane behind which water is pumped. The membrane distends, placing increasing pressure on the test specimen until, eventually, it fails. The water pressure at the point of failure is recorded. This method can be used to test samples of whole materials, seams or zip insertions and lining fabrics. The minimum burst pressures across the zones are specified in Part 1. Picture 4 shows a leather test specimen at the point of failure.
Certain materials can exhibit adequate abrasion resistance, but poor cut resistance. Once cut, their structural integrity may be severely compromised and catastrophic failure inevitable. For example, in countries where the roads are covered in snow for many months, and where use of snow chains is prevalent, the snow chains can hone the aggregate in the road surface to a sharp profile. These sharp edges can slice through inadequate motorcycle clothing - and the rider underneath! - with alarming ease.
This test method provides a “double-check” on the suitability of materials. A standardised blade, mounted on a holder which runs vertically on guide rods, is dropped from a specified height onto the test specimen and the depth of penetration of the blade is measured. The maximum permitted depth of the cut is specified in Part 1.
EN 13594 - Protective gloves for professional motorcycle riders - Requirements and test methods
Glove materials are also required to meet international requirements for their innocuousness. Any metal studs or components of other materials which are intended to improve the abrasion resistance of certain parts of the glove must be fitted to a separate external layer and may not protrude to the inside of the glove. Gloves must extend not less than 50 mm above the wrist joint, and are restraint tested to ensure that in use they cannot be pulled off the hand.
There are requirements for tear strength of materials, with the impact abrasion resistance (minimum requirement of 2.5 seconds) sharing the same apparatus described in EN 13595. The tests for strength of seams and impact cut resistance adopt methods from the industrial glove standard. Optional impact protection is tested with an impact energy of 5 Joules and a transmitted force requirement of 4 kilo Newtons.
EN 13634: Protective footwear for professional motorcycle riders - Requirements and test methods
Based on the wealth of available industrial footwear standards to draw from, EN 13634 provides an adaptation suitable to the demands motorcyclists place on their footwear. There is a minimum height requirement of 160 mm, measured inside the boot from the footbed up the rear of the boot to its topmost edge.
The strength of the bond between the sole and the upper is tested, the thickness and cleat height (depth of “tread”) of the sole must both be above prescribed mimima and its resistance to abrasion is tested. The sole is also required to demonstrate a minimum specifoied level of inherent rigidity - too soft a sole could collapse in an accident and increase the risk of severe foot injuries, which a more rigid sole might help to prevent.
The uppers of the footwear are subjected to the impact abrasion test described in EN 13595 Part 2, although the impact cut test follows a different method to that used for garments. The water absorption and desorption characteristics of the material worn closest to the wearer is also assessed.
Optional requirements include testing of impact protection which may be fitted to the ankle and shin, water resistance and fuel oil resistance of the outsole.
Each of these standards features requirements based on several years of independent laboratory testing products from the marketplace; determining where the dividing lines lay between products that protect and those which do not. The standards do not seek to replace conventional wisdom with new concepts of academic origin, but are founded on a level of best practice established over several decades by leading garment manufacturers. The result is a series of documents that - even taking into account concerns in respect of the back protectors standard - will provide exceptional benefits to motorcyclists seeking dedicated safety clothing and those who wish to make their purchase against a recognisable, independent mark of fitness for purpose.
European Standards for motorcyclists' protective clothing - Compliance and controversy
The regulations concerning PPE for motorcyclists are quite plain: if the manufacturer claims in their literature or advertising that the product, or some component of it is intended to provide protection, then the product or component shall be considered PPE and must be brought into compliance with the PPE regulations. Motorcycle clothing is a category of PPE that is required to be independently tested. Approved clothing is required to bear CE marking.
Given that the motorcycling industry was an integral part of the lobby which negotiated an understanding with the European Commission, we should expect compliance.
Well, that simply isn't happening.
There are manufacturers - who had elected to CE mark their garments against the requirements of the Cambridge Standard or SATRA alternative specification. This was because the European Standards were still under development. It is now possible to purchase leather or textile garments meeting the Level 1, Level 2 or Level 3 requirements of these documents.
Looking through magazine advertisements and the web sites of some manufacturers, it does not take too long to find companies who market their clothing in a manner that is misleading. Where phraseology appears in print such as “affordable protection against wind, rain and tarmac”, “offer extreme protection”, “for protection, quality and style” and “total commitment to safety”, how can this credibly be argued not to constitute a claim that the product so described is protective?
Some garment suppliers have been fitting their products with protectors discovered to be fraudulently CE marked. In 2002, one UK-based distributor was caught out when Trading Standards purchased one of its garments and arranged for the fitted protectors to be independently tested. The protectors failed to meet the requirements of EN 1621-1 and the distributor's stock of garments was reportedly impounded until the non-conforming protectors were replaced with the genuine item.
Industry can to some extent argue that since the clothing, footwear and glove standards were only published fairly late in 2002; with the lead times involved in the development, sampling, selection and catalogue photography for the major distributors' ranges - often a year or more before they hit the shops - they cannot reasonably be expected to have a “European Standard” range available until the 2004 model year at the earliest. Against this, however, industry knew from 1991 that the standards were under development, was aware when they were completed and knew the EU Member States had approved them for publication. Moreover, if industry can market back protectors conforming to EN 1621-2 long before the standard is officially published (the author's Gore-Tex suit being a case in point), why not a range of clothing?
Manufacturers appear to be treading a thin line, with retribution only a visit from Trading Standards or a product liability case away. If the consumer purchases a motorcycle garment based on the manufacturer's advertising that it is protective, and the product is not CE marked, the manufacturer may have broken the law and the consumer should contact a local Trading Standards Department.
If this discovery is made after what the consumer thought was a protective garment has disintegrated around them during an accident, then previous litigation indicates the courts may be on their side. For example, in Maxwell v Custom Lids (Milton Keynes County Court, case number MK708466), a suit suffered catastrophic seam failure when the wearer fell from his motorcycle at 40 mph. The judge stated that the motorcycle suit Mr Maxwell was wearing was not fit for purpose as motorcycle clothing. It is understood the brand distributor at the time removed all stocks of the model concerned from retailer's shelves.
This brings us full circle to the opening paragraph of Part 1 of this series of articles. Clothing declared by the manufacturer not to be PPE may provide a level of protection that is satisfactory, adequate, barely adequate or completely unsatisfactory. Clear identification of the various types of clothing will enable consumers to differentiate between competing products in the marketplace and this will safeguard the interests of both the consumer and the supplier. It is hoped that in addition to alerting consumers to the situation, and the issues involved, these articles will also have resonance with manufacturers and distributors of motorcycle clothing and impress on them the need to be open and honest in describing the status of the products they market.
With acknowledgement and thanks to:
Paul Varnsverry (Originator of this briefing)
Roy Jackson (Facilitator)
Richard Olliffe (Briefing Editor)
This document cannot be reproduced without the prior permission of P.D. Varnsverry and/or the British Motorcyclists Federation. Copyright © All rights reserved May 2003
PERSONAL PROTECTIVE EQUIPMENT (PPE) A BRIEFING FROM THE BRITISH MOTORCYCLISTS FEDERATION
BMF, Jack Wiley House, 25 Warren Park Way, Enderby, Leicester, LE19 4SA
Tel: 0116 284 5380 Fax 0116 284 5381 Email: firstname.lastname@example.org Website: www.bmf.co.uk
Last reviewed/updated 23/9/04