UNECE Regulation 22.

05
Motorcycle Helmets in
Australia
Guy Stanford a and Tom Gibson b
a Helmet Committee Australian Motor
Cycle Council bHuman Impact
Engineering
humanIMPACTengineering
injury prevention through analysis, testing and
design

Introduction
It is now possible to import, sell and
use on the roads in Australia
UN/ECE Regulation 22.05
Protective helmets and their
visors for drivers and passengers
of motor cycles and mopeds
AS/NZS 1698 Protective helmets
for vehicle users.

3 Questions
For the Australian consumer will the
change produce
Safer helmets?
Simpler, more understandable
regulation able to adapt to market
change?
Cheaper helmets?

The BEST Helmet Standard

Cochrane Collaboration - Lui et al. (2009)
Reviewed available helmet effectiveness studies
Found that motorcycle helmets were
45% effective in reducing fatality risk
69% effective in reducing the risk of serious injury.

But insufficient evidence to demonstrate whether

differences in helmet type confer more or less
advantage in injury reduction.
Hence, little value in comparing the technical
attributes of helmets defined by the test
requirements within the two standards.

AMC Review
Other areas of the standards setting
process Responsiveness, adaptability and
timeliness of the standard to changing
helmet developments in the market .
The quality assurance regimes
compared with ISO/IEC 17065 and
ISO/IEC 17067 Conformity Assessment.
Cost for the consumer

Helmet Recalls - May 2013

ACCC tested 6 helmets
Recalled helmets from 4 suppliers
All helmets Certified as compliant
with AS/NZS 1698:2006 by different
certifiers
The Australian Consumer Law 2011
requires substantiation of
compliance
ACL at Schedule 2 of the Consumer and
Competition Act 2010, applies nationally

Helmet standards contain

specified requirements
for a helmet

Conformity Assessment
Requires a Certification Scheme to prove the
specified requirements are met
No Certification Scheme, then no information
about the criteria with which the certified
product complies.
Certification Schemes define the METHOD of
assessing the specified requirements
Certification Scheme ensures conformity to
specified requirements is assessed before it is
placed on the market

Production Variability
A production process exhibits
variability
The question is always How Much?
Mean and Standard Deviation are
useful measures of variability when
the distribution is normal or
approximately normal
It allows a view of reliability or
consistency

Production Variability

Mean = 262.9 SD = 38.9

Only 83% of production is in compliance

Production Lowering the

Mean

Mean = 200 SD = 38.9

Reducing impact test Mean by altering helmet

design, but with same production variability, allows
99% of production to be compliant

Production Reducing Variability

Mean = 262.9 SD = 15
Improved production
process significantly
reduces variability.
99% of production now compliant without
changing helmet design

Statistical Sampling
Sampling can be statistically evaluated.
For a shipping container of say 1,000
helmets, and no knowledge of production
variability, ISO 2859-2 (AS 1199-2) defines
this as an ISOLATED LOT
AS 1199 specifies that for PROOF of 99.5%
conformity, 380 helmets of the 1,000 are to
be tested to ALL specified requirements
- with no failures

Certification
ISO/IEC 17065 - Conformity assessment
Requirements for bodies certifying
products, processes and services
Certification Bodies use their own Scheme
ISO/IEC 17065 does not contain detailed
requirements on certification schemes.
Schemes typically include additional
requirements above and beyond those
outlined in ISO/IEC 17065

ISO 17000 - Conformity assessment

Vocabulary and general principles
A.1.1 Conformity assessment is a
series of three functions that satisfy a
need or demand for demonstration that
specified requirements are fulfilled:

1. selection
2. determination
3. review and attestation.

1 Selection (ISO 17000)

Selection is identifying WHAT needs testing at
WHAT stage

1. Design stage (Type Test)

2. Production ready stage (Production Qualification)
3. On-going production surveillance (batch testing)
. Selection activities take place in both the initial
assessment and in surveillance.
. However, entirely different choices might be made in
surveillance.

2 & 3 Determination, Review,

Certification (ISO 17000)
Determination - testing
Review - verification of suitability,
adequacy and effectiveness of
selection and determination
that these activities fulfil requirements

Certification attesting to
conformity with a standard
demonstration that specified
requirements for a product are fulfilled

Certification
Initial certification comprises : Selection, Determination, Review,
Attestation
PRIOR to marketing of product
Maintaining Certification requires: Surveillance batch testing
Sampling from production and/or
marketplace

UNECE Regulation 22-05

Type Test (to prove the product design
meets the standard) [Paras 6 & 7]
Production Qualification(to prove
the production system is capable of
producing successive compliant
product)[Para 9.1]
Product Surveillance or batch
testing (to prove that the on-going
products are compliant) [Para 10.5.1]

AS/NZS 1698:2006
Sets out specified requirements
only
Does NOT deal with Conformity
Assessment
All processes of a Certification Scheme
are unique to each CAB, at their
discretion.

Compliance Comparison
Compliance Folder

ECE 22-05

AS/NZS
1698

Type Test Report

Qualification of Production

Certificate of Conformity

Production Surveillance Tests

X
[Para
10.5.1.4]

X
[varies by
CAB]

Yearly Tests

X
[varies by
CAB]

Factory Audit Certificate

Conformity Audit Certificate

Component Quality Control

Batch Testing
Certification Schemes includes how the
certified product can maintain its
certification after initial certification is
granted
Batch testing does not substitute for
initial assessment of compliance
Batch Test sampling rates are low
Batch testing alone cannot determine
compliance

AMC Impact Testing

Job-lot of discontinued AS/NZS
Certified helmets
Type Test of Clause 6.1 of AS/NZS
1698:2006
6 helmets tested
Test to Clause 7.4 of AS/NZS
1698:2006
40 helmets tested
Results analysed by Clause 9 of
ECE 22-05

Testing Results
AS/NZS 1698 Clause 6.1 6 helmets passed
BUT, when extras added (to test 10), one failed

Clause 9 of ECE 22-05 requires 40 helmets

to be tested. We tested 50
Limits on Standard Deviation and Mean at
Clause 9.2.2.3 of ECE 22-05 were exceeded
5 helmets failed Clause 7.4 of AS/NZS 1698

AMC Testing Results part 2

This batch of helmets failed Production
Qualification
Under ECE 22-05 certification criteria,
this helmet would NEVER have reached
the market
Certification requirements for AS/NZS
1698:2006 are comparatively weak.
Batch test sample rate by itself
inadequate to detect failures

The 40 helmets when tested

had:

1st Impact:
Mean (X) of 203.15
Standard Deviation
2nd Impact:Mean (X) of 262.90
Standard Deviation

g
(S) of 26.29 g
g
(S) of 38.90 g

No test result exceeded 330 g (1.1xL)

for the first impact
3 test results exceeded 330 g for the
second impact.


Under these conditions, the 40
helmets failed the ECE Reg 22.05
Clause 9.2.2 Shock Absorption
production qualification test for the
second impact.

1st impact
X + 2.4S = 266.25
does not exceed L
2nd impact
X + 2.4S = 356.26
exceeds L.

FAILED

1st Impact (AS/NZS 1698 Clause 7.4)

Mean = 203.15 SD =
29.29

2nd Impact (AS/NZS 1698 Clause 7.4)

Mean = 262.9 SD = 38.9

17% of production non-compliant

AUS Helmet Pricing

Pricing affected by: Currency Fluctuation against US, EU
When ordered (18 month lead times)

Deals such as
Bulk purchase
Superseded models
Alterations to meet AS/NZS

PRICES 2012 to 2016

2012
Average premium over
US retailer pricing
around 65%

2016
Average premium over
US retailer pricing
around 37%

AS/NZS helmets
essentially re-certified
FMVSS-218

Average premium over

European retailer
pricing around 20%

EU
US$

Summary - 2
For the Australian consumer,
the addition of UNECE Regulation 22.05
motorcycle helmets for sale and use on
the road to AS/NZS 1698 helmets
Will produce simpler more
understandable regulation
Cheaper and safer helmets.

Summary - 2
Successful implementation will
require
a means of proof of substantiation
of helmet conformance with the
provisions of Australian Consumer
Law (ACL).
Need for surveillance testing of
market helmets

THANK YOU

In Memoriam Tony Ellis

ISO 17065 Normative Refs

ISO/IEC 17000 - Conformity assessment
Vocabulary and general principles
ISO/IEC 17020 - Conformity assessment
Requirements for the operation of various types
of bodies performing inspection
ISO/IEC 17021 - Conformity assessment
Requirements for bodies providing audit and
certification of management systems
ISO/IEC 17025 - General requirements for the
competence of testing and calibration
laboratories

Scheme Development
References
ISO/IEC 17067 (Fundamentals for product
certification schemes)
ISO/IEC Guide 23 (methods of indicating conformity)
ISO/IEC Guide 27 (corrective action for misuse of
mark)
ISO/IEC Guide 28 (model for third party product
certification systems)
ISO/IEC Guide 53 (use of quality systems)
ISO/IEC 17007 (drafting normative documents)
ISO/IEC 17030 (use of marks)
ISO/IEC 19011 (auditing Management Systems)

Table 1: ISO 17065

Building a product certification scheme
Conformity
assessment
functions

Conformity
assessment
activities

Scheme types

Type 1
to
Type 5
for
product
s