QB037 - Suzuki Australia Pty Limited

QB037 — Suzuki Australia Pty Limited

Individual / Organisation name:          Suzuki Australia Pty Limited
What state/territory are you from? Victoria (operating nationally)

                                 Public Discussion Paper:
          Review of Design and Engineering Controls for Improving Quad Bike Safety
                                    Public Comment Response Form
                Complete and submit this form by 5:00PM AEST 28 SEPTEMBER 2012 to

Suzuki Australia Pty Limited (Suzuki) is an importer of motor vehicles, motorcycles and All Terrain Vehicles
(ATVs) in all States and Territories in Australia (except Queensland).
Suzuki is also an active member of the Federal Chamber of Automotive Industries (FCAI) and supports the
submissions made by the FCAI in response to the Public Discussion Paper.
Since the introduction of the ATV to Australia Suzuki has been involved in a number of ATV safety
initiatives including, but not limited to:
    1. ensuring that all ATVs sold by it comply with the voluntary and "world's best" ANSI/SVIA design
       standard (2007 and 2010);
    2. participating in a number of workshops, discussions and consultation with industry and expert bodies
       with a view to investigating and considering practical strategies and effective controls to improve the
       safety of ATVs.
    3. the preparation and presentation of detailed submissions and recommendations for the lengthy
       Coroner's Inquiry in Victoria and Tasmania; and
    4. the preparation of detailed submissions and recommendations for the Parliamentary Inquiry into the
       Cause of Fatality and Injury on Victorian Farms.
Through these initiatives Suzuki has consistently supported and promoted proven safety measures including
the mandatory wearing of helmets, comprehensive training and appropriate use of ATVs, particularly the
banning of children under the age of 16 from using adult-sized ATVs and the carrying of pillion passengers on
single operator ATVs. Suzuki has also made recommendations that the relevant state workplace legislation be
amended by, amongst other things, inclusion of express references to ATVs in the definition of plant and
equipment’ and by the introduction of ATV “operator safety standards” which would include a requirement
that accredited ATV safety training be an integral part of farm safety management.
In addition, Suzuki's customers are provided with the most reliable and up to date information in relation to
the safe operation of all of its vehicles. Suzuki promotes the safe and responsible use of ATVs through its
involvement in the activities of the FCAI and by reference to information in its warning decals, owner
manuals, websites and training, and by providing a free of charge ATV safety video to its customers.
Suzuki remains committed to developing and implementing practical strategies to ensure and improve the
safety of ATVs and welcomes the opportunity to provide its comments in relation to the Public Discussion
Paper on the review of design and engineering controls for improving ATV safety.
Based on the research conducted for and on behalf of the FCAI and SVIA to date, Suzuki does not support the
fitment of ROPS or CPDs and believes that information, training, compliance and enforcement of proven
safety measures (including mandatory wearing of helmets, appropriate use of ATVs and a ban for children
under the age of 16 from operating adult-sized ATVs and the carrying of pillion passengers on single operator
ATVs) is critical to improving the safety of ATVs riders. Suzuki will however continue to review and
investigate engineering improvements where they can be proven to be safe an effective for its customers.
Suzuki also stresses the importance of analysing real injury and fatality data to understand the true causes of
death and injury on ATVs. The data relied on in the Public Discussion Paper ought to be treated cautiously.
As we understand it the data was derived by Media Monitors Australia by scanning daily, weekly and monthly
media publications Australia wide utilising specific ATV and Quad Bike search terms. No criticism is made
of Media Monitors in this regard however, this data ought to be treated more cautiously than the data
produced by the National Coroners’ Information System (NCIS) (which only deals with fatalities and not
injuries). It is only by properly understanding and analysing the real data that you can identify the true causes
of deaths and injuries on ATVs and in turn continue to make them safer.

Response to questions identified in the Discussion Paper
  1. What design solutions and/or engineering controls could improve quad bike stability and
There is no credible or proven research which supports any current design solution and/or engineering
controls options that can improve ATVs stability and safety at this time. Suzuki supports the position that
further research is required into any engineering improvements to ATVs to prove that such options can be
safe and effective for ATVs.

It is important that the inherent design and intended use of ATVs is considered in carrying out the research
required to determine appropriate design solutions or engineering controls which may assist in the stability
and safety of ATVs. It is important to consider how changing the design or engineering components may
affect its intended use and operating features.

ATVs are more akin to motorcycles in design and engineering controls. ATVs are used in off-road
conditions, with uneven and unpredictable terrains (commonly used in the agricultural industry), where the
ability to quickly change direction is vital. Rider control is critical to the intended use of the ATV with the
position of the rider's body on the ATV critical to the effective operation, stability and safe use of the ATV.
The focus is on the rider's ability to manoeuvre the ATV, with seats, handlebars, wheelbase and hand
operated accelerator/brake/gears/clutch designed to ensure that the ATV rider movement is crucial to the
operation of the ATV (known in the industry as "rider-active"). Therefore, commonly used designs and
engineering controls which have been introduced to other types of vehicles which are not rider/driver-active
(where manoeuvring of the body has not direct connection with the operation of the vehicle) in the
automotive industry would not be suitable for use on ATVs based purely on the intended use of an ATV and
its rider-active nature.

In relation to the suggested engineering controls in the Discussion Paper, we set out our position below:

    •   lateral stability specification - There is no evidence that supports the proposition that lateral
        stability is a correct measure of ATV safety or any connection between roll overs in ATVs and lateral
        stability measures. In the US, it has been reported that the vast majority of ATV related deaths and
        injuries were due to rider/operator behaviour as the primary contributory factor whilst lateral stability
        was states to be a contributing factor in only a small minority of cases.
    •   active stability controls - There is currently no active stability controls systems that are available for
        off-road vehicles. There is sensor technology, such as electronic stability controls (ESC), currently
        used in vehicles used on public road (i.e. "on-road" as opposed to "off-road" vehicles) which work on
        a traction control and/or anti-lock braking system. However, ATVs and similar off-road vehicles do
        not and cannot implement these types of controls/system required to enable ESC to be implemented.
        The two main reasons for this is that such systems increase tyre traction and reduce wheel spin
        leading to an decrease in the required mobility for use of an ATV and in roll stability for ATV.
    •   passive stability control systems - There may be some limited safety enhancement in the use of
        ATVs. It is likely that any warning device would be triggered at a point where it is too late to alert
        ATV riders to potential roll over incidents (e.g. the ATV would already be on the incline of the slope
        when the warning device is triggered). ATV use in uneven and off-road terrain together with the
        speed at which ATVs are inherently built to achieve in these environments for effective operation,
        means that warning sounds may go off at incorrect times (i.e. bumpy terrain, increased vibrations),
        may not be heard (i.e. operating in noisy environments) and would be triggered too late for the rider
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to have enough time to react. A visual warning would only increase safety if it didn’t distract the
        rider from correctly operating the ATV.
    •   increasing wheel track width and/or wheel base length - ATVs needs to be, by their nature,
        mobile and easy to manoeuvre with the rider's body weight. Increasing length and width on vehicles
        will make the vehicle more stable and heavier which are not features that are compatible with ATVs.
        It would transform an ATV into a different type of vehicle entirely, and other additions/changes in
        the current design and engineering controls on ATVs would need to be implemented (e.g. a steering
    •   lowering the centre of gravity - The less ground clearance affects the mobility and utility of an
        ATV (which are its essential features). There are already ATVs available in the market with lower
        centres of gravity. However these types of ATVs would not be suitable for use by farmers
        /agricultural industry, primary use of ATVs, which requires vehicles that have higher ground
        clearance to deal with the environmental conditions.

A further issue with the implementation of design and engineering controls to enhance safety measures, is the
ability for riders to modify, disable or remove these devices in the event that it detracts from the intended use
and purpose of the purchased ATV.

The rider-active feature of ATVs makes it imperative that riders are aware of, trained and take control of their
own safety measures. The simplest way to do this is to inform and enforce proven safety measures such as
the mandatory wearing of helmets, comprehensive training on the appropriate use and operation of ATVs
(which is currently offered by a number of companies within the industry) and promotion of the requirements
and obligations of ATV riders set out in owner manuals. In addition to the promotion of the existing work
place safety legislation and regulations.

There needs to be further work performed in relation to the enhancement, research and implementation and
enforcement of these proven safety measures, in conjunction with further research in relation to options of
effective design/engineering controls that could be utilised for ATV stability and safety.

    2. What engineering controls could improve operator protection in the event of a roll over?
If a rollover occurs, it is crucial that the ATV rider is not restricted in the ATV by additional
hardware/equipment on the ATV. This is so the rider can separate from the ATV in a controlled way. ATVs
are built and intended to be used for off-road and uneven terrain with an ability to quickly change direction to
deal with this type of volatile environment. Any introduced or fitted engineering controls to ATVs need to
have consideration of the inherent design of the ATVs, how and where the ATV is intended to be used. In
addition to, being applicable to "rider-active" feature of the operation of an ATV.

There are simple proven safety measures and techniques which ATV riders should be informed of and forced
to undertake which are proven to protect riders against injury from roll-overs. These include:
    1. The rider must place himself/herself in the correct riding position on the ATV for example, being
        "uphill" on slopes/hills or to the "inside" in corners/turns.
    2. Riders/operators/purchasers of ATVs should be required to undertake comprehensive training in
        relation to the design/use and requirements of operating a ATV. This should include that ATV riders
        are not to use ATV on terrain or in applications for which its is not suited.
    3. A helmet must be worn at all times operating a ATV.
    4. Read the owner's manual and watch the safety video provided with the ATV.

In relation to the engineering controls referred to in the Discussion Paper, Suzuki's position is as follows:
     • crush protection devices (CPD) - There has been much debate, particularly recently, on the utility
         of CPD/Roll Over Protective Structures (ROPS) being fitted to ATVs in an attempt to improve
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safety. There is no credible evidence or research that Suzuki is aware of globally that proves that
        ROPS will improve safety or avoid ATVs related injuries/fatalities. However, there is
        comprehensive reliable research that indicates that the fitment of ROPS/CPD to ATVs may increase
        the risk of injury to ATV riders (especially in the event of riders not wearing helmets). In
        particular, if a ATV rider is obstructed by the ROPS/CPD in the event of a roll over, it may create an
        environment whereby the rider/passenger is thrown up against the ROPS/CPD device. This is of
        considerable concern in relation to the safety of ATV riders, in particular, when it is currently not
        mandatory to wear helmets when operating ATV. It should be highlighted also that in carrying out
        this research it was shown that the least harmful of the ROPS/CPDs tested caused the same amount
        of injuries (approximately) as it prevented when tested with helmeted riders.

        Internationally, there have been no ATVs designed to accept fitment of ROPS/CPDs, thus
        ROPS/CPDs are not acceptable safety mechanisms for ATVs.

        Suzuki does not support the fitment of ROPS/CPDs to ATVs as an effective safety mechanism at this
        time. The fitment of these devices to ATVs may lead to more injuries than they will prevent.
        Suzuki is opposed to the use of ROPS/CPDs on ATVs because of international research which found
        that all ROPS/CPDs examined at the time posed an unacceptably high risk of creating new injuries
        (research conducted by Dynamic Research Inc in 2007). The research modelled several types of
        ATV overturns based on 113 real ATV accidents from the UK and USA, and compared unmodified
        and modified ATVs across a range of use and misuse conditions. The analysis used the relevant
        portions of international standard ISO 13232 (2005) for Motorcycles – Test and analysis procedures
        for research evaluation of rider crash protective devices fitted to motorcycles.

        Without credible evidence to support the theory that ROPS/CPDs when fitted to ATVs will
        protect/improve safety for ATVs riders, such theories should be dismissed. Any further research
        should include comprehensive consideration into the potential unintended consequences of these
        devices being fitted to ATVs. Any further research should also be undertaken by reference to the
        current voluntary and mandatory standards and codes which have been implemented world wide.

    •   foot well design - Suzuki (as with all FCAI members) voluntarily complies with the ANSI/SVIA 1 -
        2010 standard (which is a mandatory federal standard in the US) in relation to its ATVs in Australia.
        In particular, its ATVs have a standardised "foot well" design for protection. This was introduced in
        an attempt to improve safety measures for ATVs rider and passenger (if operating an ATV designed
        for passengers), to support riders/passengers feet when operating an ATV to lower the chances of, in
        the event of a roll-over, their feet getting unintentionally caught between the body/wheels of the
        ATV and the foot pegs. This is an effective solution to minimise the risk of crush injury to the ATVs
        lower limbs. Further, mandatory comprehensive training and personal protective measures (such as
        wearing the right protective clothing) should be introduced in conjunction with the use of the foot
        well design for increased safety for ATV riders.

    •   automated emergency alarms - Suzuki repeats its comments in relation to question 1 "passive
        stability controls systems". Further, any alarm type system implemented on an ATV must be
        designed so as not to interfere with the rider-active nature of the ATV (i.e. should not be an
        obstruction to the use of the ATV). An alarm type system would be useful as a safety measure in
        relation to ATV riders who are alone/work in isolated places when operating ATVs (such as farmers)
        being able to potentially notify other people of the roll over occurring so that help can be provided as
        soon as possible.

Further, Suzuki is particularly concerned that any engineering controls/design solutions that are introduced to
ATVs will cause ATV riders to become less concerned with implementing other proven and practical safety
measures. It may also induce ATV riders to be more careless with ensuring that they are informed and obtain
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training in relation to the ATV capabilities and purposes. Accordingly, it is imperative that with any
introduction of engineering controls/design changes that the focus is also on improving the awareness and
knowledge of the benefits of proven safety measures being followed and implemented as well.

  3. What engineering options could minimise the capacity of children to start and/or operate quad
Suzuki do not endorse children under the age of 16 operating adult-sized ATVs. It was never intended that
adult-sized ATVs should be operated by children. There should be legislation/regulations introduced to ban
the use of adult-sized ATVs by children under the age of 16.

Suzuki manufactures and distributes youth ATVs specifically designed for age-appropriate operators.

The key areas to controlling access of adult-sized ATVs from use by children is the:
   • removal and control of the keys;
   • monitoring ATVs usage; and
   • the ATVs owners/adults properly instructing children not to operate the ATVs; and
   • introduction and enforcement of a ban.

There are problems with the introduction of engineering controls such as start up systems and seat weight
sensors for ATVs. This includes, issues regarding:
    • dealing with a variance in children's cognitive developments from a toddler age to teenagers and
        determining a start up system which will cover this width of cognitive "intellect".
    • children are resourceful and will easily "find a way" to start or operate a adult-sized ATV if so
    • determining the correct measurements of the weight sensors for children, without restricting adult use
        (e.g. how would it distinguish small adults).
    • even if engineering options are implemented to adult-sized ATVs in order to "child-proof" the ATV,
        the inherent issue in relation to children's use of adult-sized ATVs is that it is the ATV owners
        (adults/parents) that are willing to allow their children to operate adult-sized ATVs. This may
        include the removal/modification/disable of any "child-proof" device and/or simply the adult starting
        the adult-sized ATV for the child. This can only be overcome by knowledge and comprehensive
        training in relation to or enforcement of a ban of children operating adult-sized ATVs.
    • any system should not interfere with the normal operation of a ATV/affect its ability to function in
        the off road environments.

Currently, similar sensoring systems to detect the physical size of drivers in cars for airbag systems are only
in development stage.
Further, Suzuki reiterates its comments in relation to section 2, regarding the implementation of ROPS/CDP
or other engineering controls and the role it may take in reducing ATV riders implementing practical proven
safety measures and in particular, the false belief that children will be safer operating an adult ATV when
such devices are installed on ATV. This is not the case. It is crucial that parents and adults are informed and
trained and requirements are put in place that ban the use of adult ATVs by children under the age of 16.
  4. What engineering controls could minimise the capacity of a quad bike to carry passengers.
There should be mandatory training for ATV riders in relation to the use of the ATV. This should include the
importance of ATVs which are designed to carry no passengers (i.e. single-rider ATVs) being utilised in the
correct manner and the potential effects of non-compliance with this requirement. Suzuki promotes the
correct use of ATVs and ensures that single-rider ATVs are fitted with passenger warning labels on the seat.

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ATVs do have a greater load carrying capacity than motorcycles but less than a side by side or 4x4 vehicles.
The ATVs are quite distinct in this regard. The intended purpose and use of ATVs requires that any
modification or engineering controls which minimise the capacity of a ATV to carry passengers doesn’t
compromise or restrict the "rider-active" feature of the ATV. The ATV rider must be able to shift their body
weight in order to operate and control the ATV safely.

ATV’s have seats which are non-adjustable to ensure that it is possible for the rider to manoeuvre his/her
body weight to effectively control and operate the ATV safely (for example, a rider can quickly and smoothly
move their body forward when riding up a hill). The length of the seats are generally not large enough to
allow an adult rider passenger in single-rider ATVs.

The ATV rider must have enough space to be able to control and operate the ATV efficiently and safely, as
well as not having any restrictions or obstructions fitted to the ATV which will, in the event that the ATV
needs to quickly remove himself/herself from the ATV, he/she can do so safely. Any proposed modification
to the seats to limit the space to a single rider needs to take these factors into account.

This also applies to any proposed modification of the carrying racks. By making the carry racks rough or
uncomfortable may have the opposite effect to ensuring safety, as it may in fact lead to increased injuries in
the event of an accident. As previously stated minimal obstructions or restrictions are an essential feature of
ATVs safety minimising any potential injuries which may result from ATV accidents.

The major issues in ATV related injuries and fatalities are non-helmet use, children under 16 operating adult-
sized ATVs, pillion passengers on single operator ATVs, overloading a single operator ATV and a lack of
training/certification of ATV riders. These can be practically addressed by non-engineering and design
changes (which will take time to research, develop and implement) such as:

    1.   Helmet use being mandatory for all ATV riders.
    2.   A ban on children under the age of 16 using adult-sized ATVs.
    3.   A ban on carrying pillion passengers on single operator ATVs.
    4.   Promoting and ensuring that all ATV riders are trained in the safe operation of ATVs, through
         training, awareness and enforcement of legislation and regulations.

Please note legal requirements, such as those imposed by the Freedom of Information Act 1982, may affect
the confidentiality of your submission.

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