Royal Mail
Royal Mail, the UK postal service, has made the wearing of cycle helmets compulsory for its 37,000 cycling delivery workers - the largest cycling fleet in Europe.
The move is not popular with many postal workers, who complain that they have not been given a balanced appraisal of the pros and cons of cycle helmets.
This case study examines the evidence behind this decision, and whether it is likely to improve the safety of Royal Mail employees.
Background
Following the deaths of five cycling postal workers in 3 years, the Communications Workers Union (CWU) called for mandatory cycle helmet use at its 2001 annual conference. Royal Mail commissioned the Transport Research Laboratory (TRL) to look at the benefits that might be obtained if its staff wore helmets. TRL concluded that the routine wearing of helmets by postal staff could reduce head injuries in low impact collisions.
In 2002 Royal Mail and the CWU reached agreement on a Code of Practice for the mandatory use of cycle helmets and high visibility garments. Helmets will be compulsory from October 2003.
Each year around 2,000 postal cyclists are injured, mostly as a result of slips and falls. Only a quarter of the injuries are sufficiently serious to require the workers to take time off work. Just 1% of casualties suffer head injury and Royal Mail acknowledges that wearing a helmet will not necessarily prevent injury or death.
Explaining the decision for compulsion, a Royal Mail spokesman said: "We are not giving our staff a choice about whether or not to wear helmets because we believe this move will enhance safety. As a responsible employer we must make sure that helmets are used and, just as we insist on high visibility clothing and other safety measures, it is our responsibility to ensure they are worn".
A Health & Safety perspective
The UK Health and Safety Executive (HSE) does not require employees to wear cycle helmets.
Cycle helmets used on the public highway are specifically excluded from the Personal Protective Equipment (PPE) at work regulations.
Although employers have general duties under section 2 of the Health and Safety at Work etc Act 1974 (HSWA) to ensure the health and safety of employees while cycling at work, where more specific laws, such as the Road Traffic Acts, provide the national safety rules for a particular situation (e.g. cycling on the roads), HSE considers that compliance with that law is, in general, sufficient to ensure compliance with the relevant requirements of the HWSA.
Since there is no requirement on cyclists generally to wear cycle helmets when on the road, HSE does not advise that employers insist that helmets be used under health and safety law.
This means that it would be very hard for an employer to force an employee to wear a cycle helmet on health and safety grounds. They are, however, free to require employees to wear cycle helmets as part of their uniform. HSE has no remit to dictate the uniform policy of a company unless it falls within the scope of PPE.
Ultimately the wearing of cycle helmets is a matter of individual choice, and any stance to the contrary could potentially be challenged on Human Rights grounds.
Above derived from communications with the Health and Safety Executive
The evidence for compulsion
The following arguments have been put forward by Royal Mail and The Communications Workers Union to justify the mandatory use of cycle helmets.
- Two-thirds of cyclists' deaths would be avoided by the protection of energy-absorbing cycle helmets.
- A report by the British Medical Association (Cycle Helmets June 1999) strongly recommended helmets and urged Government, health and cycling organisations to promote them.
- The BMA, although supportive of helmet promotion, has made clear its opposition to compulsion.
- The TRL research for Royal Mail concludes that the wearing of cycle helmets would have a beneficial effect, and have the potential for preventing fatal head injury.
- Neither Royal Mail nor CWU has responded to requests to release the TRL research, so it is not possible to assess the scope or validity of its findings. However, the quotations from the research on the CWU website suggest that it may have been limited in the evidence examined. As noted above, there is no real-world evidence that cycle helmets are effective in preventing fatal injuries.
- Cyclists are eighteen times more likely to be injured per kilometre travelled than car drivers.
- This is misleading, taking no account of the considerable difference in distance travelled by the two modes. A fairer comparison is on the basis of time at risk. From this perspective, adult cyclists face similar risks to motorists, but are less at risk than pedestrians. Cycling postal workers, like all people who cycle regularly, are more likely to live longer than those using sedentary forms of transport
- 49% of cyclists requiring hospital treatment in the UK sustained injuries to the head or face.
- Very few of these injuries are life-threatening or requiring further treatment. Helmets do not protect from most facial injuries.
- A Victoria, Australia study found that head injuries were significantly less frequent amongst cyclists wearing Australian approved cycle helmets than unhelmeted casualties.
- Other research has shown that helmeted cyclists are more likely to hit their heads in a crash. Long-term analysis of the Australian situation shows that the frequency of head injury increased relative to cycle use following the introductory of mandatory helmet wearing.
- A Seattle USA hospitals study indicated an 85% reduction in head injury risk due to wearing cycle helmets.
- This study, though widely cited, has been criticised for major methodological shortcomings. Its predictions have never been approached anywhere in the world. See: Commentary.
- A Cambridge UK Hospital study of over 1,000 injured cyclists attending emergency department found that the risk reduction effect from wearing cycle helmets was 60%.
- This study also has significant shortcomings and its results are not confirmed by whole-population data for the Cambridge area. See: Commentary.
- It is likely that the routine wearing of a cycle helmet would reduce absences because cycle helmets have been shown to be effective in minor accidents.
- Unfortunately there is much evidence to suggest that helmeted cyclists crash more often. When they do crash, one study found that a helmeted cyclist is more than 7 times as likely to hit his or her head as a non-helmeted cyclist. This is probably not least because the surface area of a helmeted head is twice as large as one without a helmet.
- The routine wearing of cycle helmets by Postal staff would reduce injuries in most accidents involving head impacts. There is a likelihood for significant head injury without a helmet even in the more prevalent minor accidents. In more severe accidents, although less frequent, a helmet would provide significant protection to the wearer.
- It is possible that a helmet may provide some protection against minor knocks and abrasions, but this has to be set against the likelihood of a user hitting their head more often. As mentioned above, there is no real-world evidence that helmets reduce the number or severity of more serious injuries.
- A good cycle helmet would be expected to prevent fatal head injuries in accidents in which a cyclist, travelling at speed of up to 15 mph falls from his/her bicycle and impacts against a road surface or kerb.
- As previously stated, there is no evidence that helmets have ever brought about any reduction in fatalities. Helmet standards only relate to simple falls at up to 12 mph. Laboratory tests have found that most helmets do not provide this level of protection, even if accredited as doing so.
- Most research on the effectiveness of cycle helmets supports the view that they offer good head protection in the majority of cycling accidents and, in some circumstances, have the potential to significantly reduce fatal and serious head injuries.
- This is untrue. Only evidence from small-sample case-control studies has found helmets to be effective. Other types of research and impartial data collection mechanisms, usually based on larger populations, has not found evidence that helmets are effective, especially against more serious injuries.
- An independent review in 2002 for the Department for Transport has found helmets to be effective.
Other important considerations
The following issues do not seem to have been considered by Royal Mail or the CWU:
- There is much evidence that serious head injuries when cycling are often a result of rotational injuries to the brain. Cycle helmets are not designed to protect against rotational injuries and have not been shown to be effective in doing so. Indeed, some doctors believe that helmets can convert direct forces into rotational ones, increasing the likelihood of the most serious types of injury that lead to death and chronic intellectual disablement. See: Cycle helmets and rotational injuries.
- Although people can be required to wear a cycle helmet, it is much more difficult to ensure that one is worn correctly. Surveys have shown that most helmet wearers do not wear a helmet as intended, and this is particularly the case if helmet use is involuntary. Correct placement on the head and tight adjustment of the straps is essential if helmets are not to increase risk when cycling. This is likely to require ongoing and intrusive checks on employees.
- The most effective measure against head injury - or any kind of injury - when cycling, is good quality training. Royal Mail does not provide cycle training for its delivery workers, and has not expressed an intention to do so. The primary duty of both employers and unions is to secure a safe environment by working to minimise the dangers presented to employees, rather than relying on the uncertain chance that a helmet might provide sufficient protection after a crash that could have been avoided.
Summary
Royal Mail and the CWU seem to have considered only some of the evidence relating to the effectiveness of cycle helmets, and in so doing have not been able to give to postal workers a balanced view of the merits and drawbacks of cycle helmets.
Not taken into account are:
- The real-world evidence, from countries and towns where helmet use is significant, that helmets do not offer protection against serious or fatal injuries.
- Evidence that rising helmet use, particularly where use is mandatory, has often been associated with an increased risk of head injury to cyclists.
- The tendency of helmeted cyclists to crash more often than non-helmeted cyclists, and the much greater likelihood of hitting their heads if they do crash.
- The relative risks faced by cyclists. The risk of head injury for cyclists is less than that for pedestrians. The likelihood of a fatality involving head injury is almost the same for cyclists and motorists. It is illogical to require cycling delivery workers to wear helmets if the same requirement is not imposed on other postal employees.
Royal Mail is conducting an experiment with its cycling workers, and one in which the workers have no choice but to participate. Some fear for their livelihoods if they don't. There has been no preliminary trial to evaluate the effect of helmet wearing on casualty rates amongst delivery workers.
Royal Mail acknowledges that safety experts differ about the safety merits of helmets, and that some experts believe their use to be counterproductive. The evidence is favour of mandatory helmet use is far from convincing. This calls for a cautious approach from a responsible employer.
There is no requirement to wear helmets under Health and Safety legislation. Mandatory helmet use cannot therefore be required on health and safety grounds, and is open to challenge on grounds of infringement of Human Rights.
Whilst Royal Mail and the union are hopeful of achieving a safety benefit, the wider evidence suggests that at best it may have little effect on the safety of postmen and postwomen, whilst at worst it could result in increased risk of injury, with workers restricted in what they may do to protect themselves. It is not clear what impartial monitoring is in place to evaluate the outcomes.