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Join Date: Jan 2006 Location: Cochin
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| Re: Non-ISI Helmets banned in India If you're against this dumb rule, then Copy-paste this letter into your email, right now and send it to js-tpt@gov.in Quote:
To,
Shri Abhay Damle
Joint Secretary (Transport),
Ministry of Road Transport and Highways,
Transport Bhawan,
Parliament Street,
New Delhi - 110001
Sir,
I write to you in regard to a recent notification, reported widely in the media (F. No. RT-11012/07/2012-MVL) bringing Protective Helmets for two-wheelers rider under compulsory certification under Bureau of Indian Standards Act, 2016. I welcome this initiative. It will compel manufacturers to adhere to quality standards for helmets, and riders to buy/demand higher standards for their own safety. However, in the process, I anticipate some problems and have concerns:
A vast majority of 'premium' imported helmets ranging in cost from Rs 5,000 to Rs 1,25,000 conform to international standards such as DOT, ECE, JIS, SNELL, SHARP etc. Our own IS 4151 is based on ECE 22.05, with some additions. These imported helmets do not conform to ISI 4151, and would, therefore, be ineligible for sale once this notification is in force, despite being made to the highest standard that far supersedes these certifications and used in the most demanding situations world-over. These standards have been developed over years of research and real-world experience in the spheres of motorsport as well as on the street. Such helmets are either imported privately or sold by importers. Our own national motorsport authority -- the FMSCI -- requires the use of SNELL or ECE-rated helmets for use on the racetrack for two wheelers racing and FIA approved helmets for four wheeler racing.
Requiring ISI certification for helmets already compliant with international standards will effectively reduce the choice of safe, high-quality helmets in the market. To this end, I would request you to make relevant exemptions for established international helmet safety standards (DOT, ECE, JIS, SNELL, SHARP etc), so that we in India may continue to choose helmets providing maximum safety. Such exemptions are already in place for fully-imported vehicles, which can be registered by furnishing homologation certificates from other countries. Certainly, this can be seen as a precedent.
Reports quoting the PTI indicate that there is a proposal to reduce the maximum weight of an IS 4151-compliant helmet from 1.5kg to 1.2kg, achieved by making relevant changes to the testing methodology. As in many types of manufacturing, achieving light weight is a demanding, expensive process. Worldwide, a standards-compliant helmet that weighs 1.2kg or less is typically made with exotic materials such as carbon fibre. These helmets are reserved for race use and are extremely expensive, putting them out of reach of the average rider. Also, if a manufacturer does need to comply with these weight restrictions during the manufacturing process, they in turn, would definitely have to compromise on safety provided by the helmet itself.
Most top-rated, proven international helmets conforming to SNELL, ECE, JIS etc will be above 1,300g. Putting an upper-limit of 1,200g for IS 4151 compliance seems infeasible. Certainly, modifying long-established and respected standards simply for a lighter helmet does not seem to be beneficial. I would request that due notice of established international standards, as well as compliant helmets and their weights be taken, before this weight limit is enforced. I believe that the current standard has it right - that lighter helmets are preferred but 1,500g is a good weight.
On-ground enforcement of this notification is also unclear. Thousands of safety-conscious riders in India have chosen to pay premium prices to ensure their helmets meet international standards of safety. Will these riders now be forced to buy ISI-marked helmets? Once again, reasonable exceptions for international standard helmets will achieve the greater goal of eliminating spurious helmets, as well as promoting safety among the two-wheeled population.
I appreciate your initiative in ensuring quality standards for helmets in India. We have been victims of spurious materials and poor enforcement for too long. Arguments against the wearing of helmets such as lack of visibility or greater injury due to low speeds/heavy weight are deflections and easily proved false.
What we gather from the information available, is that this regulatory change will change the business dynamics of the helmet marketplace, by requiring homologation of imported helmets. This is a tiny percentage of the market, and the requirement will likely make selling internationally-acclaimed helmets unfeasible or impossible. The greatest hit will be the customer -- who will now have less choice. As it stands today, one can buy an ISI-branded helmet for as little as Rs 300 from a local manufacturer. If this proposal passes, those helmets will be legal, while the best helmets in the world costing hundreds of times more, will be illegal. It is not unreasonable to ask who exactly is being benefited here.
I request you to take cognisance of these points in your final decision.
Sincerely, | Source |