The European Commission has recently launched a proposal for a Regulation on Personal Protective Equipment (PPE). FEMA insists that the use of personal protective equipment should always be optional for the rider.

Many motorcyclists regard personal protective equipment as essential in their riding activity. Although there is no legal requirement to use anything besides an approved helmet, studies show that almost all motorcyclists in the Nordic countries always use comprehensive personal protective equipment. The use of back and/or chest protection is also increasing.

Motorcycle riders are willing to take responsibility for their own safety and many prefer to increase their safety by using personal protective equipment of good quality, demonstrated by the number spending large sums on this every year.

Directive or Regulation?
The Commission has proposed a regulation which means that the Commission is empowered to adopt delegated acts.  FEMA represents consumers and our experience is that the users have very little influence in the drafting of delegated acts. Conversely, some states are liable to ‘goldplate’ a directive, thus over-reaching the objectives of the directive.

FEMA recommends that the revised proposal remains a directive which gives users better opportunity to influence the content.

Usage
Article 6 is the most important part for the European motorcyclists. It’s about how each Member State may impose requirements on the use of personal protective equipment. Many motorcyclists use protective equipment, even though it is not a statutory requirement and even if going on a trip of only a few kilometers. There is therefore no reason to make usage of PPE mandatory. Europe is a continent with varied climates. To require the use of the same type of equipment in northern Finland and south of Sicily is neither appropriate nor feasible. The high usage of personal protection in the Nordic countries might simply indicate that the equipment is best suited for the Nordic climate.

FEMA recommends that the use of personal protective equipment should always be optional for the rider. Guidelines on usage must be delegated to Member States.

Costs
The cost of personal protective equipment is an important issue. A motorcycle leather suit can cost between €500 to €2000. Protective equipment ages and the users change shape which is why equipment needs to be replaced with some regularity. FEMA and dealers point out the importance of a well-fitting protective equipment at all times. When FEMA became aware of the current proposal contact was made with representatives for CEN in different countries. There it emerged that work is in progress in CEN where certain requirements currently only required for professional motorcycle riders will be placed on all personal protective equipment for motorcyclists. This requires more testing which will mean increased prices. In future discussions FEMA will emphasize the importance of avoiding large increases in price, both within the PPE directive and within CEN work; for example by making the necessary testing reasonable for different levels of requirements depending on the application and user.

FEMA recommends that this too is a reason that the revised proposal in the future becomes a directive. A regulation with mandatory requirements where users have no influence could mean sharply higher costs for consumers.

Comfort
It is very important that the PPE fits well and feels comfortable. If it is loose the protective elements will not remain where they should be (shoulders, elbows, hips and knees). A back protector must be neither too big nor too small. It is of great importance that there is personal protection equipment for both men and women, for people of different sizes and for different uses.  Increased demands on postures and tests can lead to less choice in terms of size and fit.

FEMA recommends that different levels of requirements be recognised depengin on the application and the user; testing must be appropriate for the level of the requirements. This will allow the manufacturer to provide a range for all motorcyclists.

Quality
The quality is certainly important when buying safety equipment at high cost. As a consumer, it is assumed that the equipment complies with the requirements to obtain a CE marking, but this is not always the case. FEMA would like to see much more market surveillance of motorcycle equipment to ensure CE marking is not misapplied. Today, most consumer tests in Europe are made by motorcycle magazines and these tests do not correspond to tests for certification.

Sports
Marc Marquez, Dani Pedrosa, Valentino Rossi, Jorge Lorenzo and Cal Crutchlow are today’s top names in road racing. They have specially equipped clothing with embedded electronics, for example airbags that cost about € 40,000.  It is obvious that people who practice a sport at World Championships / Olympic level should have the best equipment. However, these standards cannot be required for all who train and compete in motorsport. Insisting on unreasonably high standards of protective equipment for road racing and other motorcycle sports will make it impossible for youngsters and others to train and compete at a lower level. This might lead to more accidents on roads since youngsters would be unable to afford to race on tracks.

FEMA therefore recommends that future standards take into account the young people and others who want to train and compete in motorcycle sport.