Wheel alignment

Wednesday, 27 April 2011

A bit perplexed....

This morning,  I saw some statistics on US motorcycle deaths which with the exception of a small reversal in 2009, shows a steady increase from the late 1990's.  I don't intend to debate all the reasons for the deaths as I suspect they're many and varied.  Also, if New Zealand motorcycle accidents statistics are anything to go by  (see this POST), they can be "interpreted" to prove whatever political point is currently in vogue.


US Motorcycle Fatality Statistics

However, the article which accompanied the graph revealed that statistics released from the Governers Highway Safety Association in America show that use of motorcycle helmets dropped 13% in 2010 compared to 2009.  Helmet use in the USA stood at 54% in 2010, compared to 67% in 2009.

According to the GHSA's figures, in 2008 42% of fatally-injured motorcyclists were not wearing helmets.

Only 20 states have a universal helmet law, requiring helmets for all riders.

If these statistics are anywhere indicative of the true picture, they leave me both puzzled and dismayed.  Although the article deals with fatalities, I suspect that they are merely the tip of the iceberg.  What about people who have suffered severe and on-going injuries as a result of not wearing a helmet?  I'll come back to that in a minute.

I could be completely cynical and say that folks choosing not to wear helmets is a great example of Darwin's theory of evolution at work, but that's not how I feel. America is among the most technologically-advanced countries on the planet, spends megadollars keeping people safe with advanced safety systems in other forms of transport such as cars and aircraft, yet all but 20 states fail to legislate for that most basic of motorcycle safety devices, the helmet.  What on earth is going on?  Is it cruiser riders of a certain persuasion or motorcycle posers of all kinds who have political influence?  If they don't wear helmets, I'm picking that their attitude to other protective gear is similarly casual.  Is it the motorcycle industry itself not supportive of helmet use?  Hard to imagine.

As an outsider, I'm wondering whether the logic which the rest of the developed world might use to support helmet use doesn't apply here and that freedom of personal choice (ummmm... like the right to smoke or drink yourself to death) is the over-riding consideration in these states which don't legislate.  Maybe people should have the right to decide not to wear a helmet but also lose their right to priority medical treatment?

Any motorcycle death is a tragedy in its own right to the family, friends and wider community.  When the cause is failure to wear a helmet, it must be almost impossible to bear.  Coming back to non-fatal but serious injuries caused by not wearing a helmet, the cost to the state/taxpayer must be enormous because of the long term medical care requirements.  You'd think that alone would be sufficient incentive to make wearing a helmet mandatory.  Because of the increased cost of medical care through motorcycle accidents in NZ, annual motorcycle licensing costs have jumped by a huge amount - almost double in some instances.  I now pay the equivalent of  US$418 for the Street Triple.  You could correctly argue that this isn't addressing the root cause of accidents but at least authorities are well aware of social and financial burdens to the community in the case of all forms of auto accidents.

So what am I missing in the case of US authorities not legislating for the use of helmets?


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28 comments:

  1. I'm with you on the helmet thing Geoff...I can understand people not wearing jackets, pants covering their legs, boots, gloves etc.....but I just can't imagine riding a motorcycle without a helmet, and cannot fathom why US authorities don't see helmet use as a manditory safety item......

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  2. Geoff:

    I can't speak for the 'States but when WA had no helmet laws we tried it, and didn't feel safe, so put our helmets back on. It doesn't make sense. BTW: Your insurance is so cheap.

    bob
    Riding the Wet Coast

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  3. Hi Bob!
    When I first started riding in the UK, there was no helmet legislation but I wore one anyway for the same reasons as you.

    That's not my insurance, that's just my annual road licence for the bike! The road licence income supposedly funds roading maintenance and development as well as auto accident costs. My fully comprehensive insurance is a further $US350 or thereabouts, even with 60% no claims discount. The road licence for the Striple is more expensive than either the Mazda MX5 Miata or the Toyota RAV 4!

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  4. Geoff, Geoff, Geoff.....when I read a post like this I hang my head in disbelief. I like America and its people but where the hell is that wise old man called..Mr Common Sense? When I was there last year I was horrified at what I saw bikers wearing. Having came off my Daytona and seeing the damage to my helmet I would hate to think what it would of done to my head had I not been wearing it.

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  5. Hey Roger!
    Exactly the reaction I had first thing this morning! That's why I was looking for an informed opinion from our blogging mates up that way.

    Nicely put about Mr Common Sense! BTW, David Hough's book should be at your place about right now.

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  6. Hi Geoff,

    I guess the main issue is the 'making it mandatory', and hence reducing the 'freedom' of the American citizen.
    Besides no-helmet-law supporters might argue that peripheral vision and hearing might get obstructed.

    I rode an 80cc scooter once without protecting my marble while on vacation in Greece, and I wasn't feeling comfortable. Even if it weren't the law, I would still wear a helmet. Some laws simply do make sense if people don't apply common sense.

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  7. Call it freedom of choice but why should the medical bills be paid for treating someone who has chosen to taken the risk?
    I have only seen one turban wearing biker in UK!

    N

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  8. I don't understand riders not wearing a helmet or jacket or gloves or boots or pants/chaps. I took a relatively minor get off my first year riding at 20mph. I learned I don't like roadrash, jeans are no match for asphalt and loose gravel, and cotton work gloves aren't designed for protection. Since, I adopted AGATT.

    I've watched in amazement at the 20-somethings that pass me on crotch rockets flying like a bat from the gates of hell in thick traffic wearing a tshirt, gym shorts, and flip flops. But usually they are sporting and expensive fullface helmet. God bless them but one day its going to be an ugly skin graff.

    Georgia requires helmets but you can ride barefoot. Just because you CAN do something doesn't mean you SHOULD.

    Should each state require helmets? Maybe so to protect those not. Smart enough to protect themselves.

    -Peace

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  9. Am I really the first US citizen to comment on this post?

    Those who do not live in the US have no idea how strong the idea of "personal freedom" is in this country. It's rooted in the same fallacy that drives the vast majority of riders in the US to purchase outdated, poor handling motorcycles from a single particular brand.

    I hate to be glib, but you'd really need to spend a lifetime here to understand both sides of the issue.

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  10. First let me say that I wear a helmet. There have been times in the past when I did not but, I now always wear a helmet and my hope is that all riders will wear a helmet.

    Most Americans appreciate our freedoms. With freedom comes personal choice and personal responsibility. There are a lot of activities that are "dangerous" or "unhealthy" and individuals must make choices concerning their level of involvement. Motorcycling is one of those activities. I do not want the government deciding if I can rock climb, skydive, hunt, eat a double cheeseburger, or ride without a helmet. I believe the desire to have minimal governmental intrusion is the over-riding residence to mandatory helmet legislation.

    One thing I would like to know concerning the statistics is how many accidents are due to the motorcycle being hit by a car/truck and how many accidents had alcohol/drugs as a major influence. There are a lot of facts not known that could shed some light on the stats.

    Now, I must add this last comment – when you look at some of the people we elect to run this country it does not always speak highly of our ability to make good choices. :) Hopefully we will choose better in the future.

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  11. As an American raised in British Columbia I don't have the typical Freedom of this, Freedom of that attitude of typical Americans. And by typical I mean the flag waivers that think their rights and freedoms are being taken away when laws are made to protect the general public and people from themselves. Of course these are the same people who will not turn their headlights on in the rain or fog and can't figure out why they shouldn't text and drive.

    I usually think that it is natural selection when someone chooses not to wear their seatbelt or a helmet but at the same time I don't think my insurance rates should have to go up due to the fact people are making poor choices even though they may have the freedom to make those choices.

    We do not have universal healthcare in the USA. We all pay a ridiculous amount of premiums to an insurance company for little coverage. My health insurance coverage alone is $270 per month. Luckily Troubadour's employer pays for his. We still have to pay $30 for every doctor visit.

    Vehicle registration/licensing is about $40 per year per vehicle. As far as vehicle insurance we pay $228 per month combined for full coverage on 3 motorcycles, our 2011 Subaru and life insurance on the both of us. This also includes PIP (personal injury protection) on all vehicle policies so that State Farm will pay the first $15,000 of medical bills and ambulance on the motorcycles and $25,000 on the Subaru in the event of a crash. This is way more insurance that required by State and what most people pay.

    Having said that - there is an uproar right now in Oregon as legislation has been introduced to try and repeal the helmet law and only make them mandatory for riders under a certain age. I think from comments and letters to the editor that I have seen that a lot of people do not agree with the right to choose because if you become a vegetable and end up on Medicare (government run healthcare for the elderly and disabled) or on Social Security Disability it comes out of the tax payers pockets. Insurance rates also go up for unpaid hospital bills that do not get paid if those riders that crash and have no insurance and are hurt cannot pay their bills. The hospitals must write off those expenses, thereby raising their rates and/or charging more to compensate for their losses. Unfortunately just as many people seem to want the option to choose.

    I admit, many many years ago I did not wear a fully DOT compliant helmet. For the last 10 years I've always worn a full face helmet and full gear. Remembering back I don't know how I dealt with the wind let alone the bugs and the risk I was taking. Education is a big part of it. I am more educated now and want all the chances I can get at healthy survival in the event I crash.

    There are people that will tell you they have a right to choose if they wear a helmet. Funny I don't see that worded into the constitution. As society evolves they think so should the constitution. No way could our forefathers have imagined the technology that we have now when the constitution was drafted. But that doesn't stop people from trying to exercise their 'right'. As for the mentally in this rationale, I have no idea. Political? Mental disease? Anyone's guess.

    Given the choice some will always choose to wear a helmet and some will choose not too. For some reason the option is what matters to them.

    For me, I will never ride without a helmet, ever, period. Sorry for any typos and for rambling on, but you were looking for points of view.......

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  12. The U.S. does not have an extensive State or Federally funded health system.Health costs are paid by private insurance.
    The States still,largely, believe in freedom of choice and personal responsibility.

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  13. Take into consideration the price of gas in your graph, as gas prices rise so does motorcycle ridership and new riders at that, hence more accidents/fatalities. You'll most likely see another rise in motorcycle crashes here this year as the price of gas continues to rise.
    I too admit, I've ridden with skid lids and t-shirts in the past when I was young and stupid, but I consider myself extremely lucky and have changed my ways. I've tried to talk to other riders and now simply lead by example. I gave up on the argument regarding helmet laws and believe to let those who ride decide. I realized that what "they" don't understand is those that ride without helmets are going to be profiled by the police, their neighbors and their community whether on a cruiser or sport bike. They're going to get pulled over, harassed and arrested portraying that carefree lifestyle and what usually accompanies it. Fine with me, I'll ride ATGATT and wave as I ride by.
    I agree with others here that we don't want or need the government regulating everything we do but with freedom comes responsibility, it's the responsibility part that is highly disregarded and unfortunately laws are required to compensate for foolishness. I believe it is a select 'many' that feel it is their right and freedom to choose; it's when their freedoms infringe on my rights that I am bothered. (I thank the US for allowing me many of the same rights as those of a US citizen, plus getting out of jury duty).
    So, if one is going to ride lidless and pulls a Darwin award winning front flip over the handlebars they better have a minimum bond/insurance policy. Mandatory minimum insurance should be required for helmet less riders. This would encourage riders to wear a helmet in exchange for lower premiums, of course this goes against the rights and freedoms granted to them by their God and considered discrimination.

    The U.S. Constitution needs to be displayed at the DMV for everyone to read while standing in line to get their license renewed. The right to ride ain't in there.

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  14. As a teenager on a borrowed Honda 50 in the early 60's in Southern California the riding attire was jeans, t-shirt, and tennis shoes. There were fewer cars and motorcycles but as the population increased so did the laws regarding motorcycles.

    I low sided while on a downhill side of a canyon while trying to put distance between me and a big truck that was on my tail. I got road rash but by the grace of God no head injury. It only makes sense to wear protective gear as they do in the National Football League or any other dangerous sport. But to address your perplexity on this issue, Geoff, I think it has everything to do with a person's freedom. Take away the insurance issue of paying for injuries (because that's a mess in itself) some feel we head down a slippery slope when we start legislating how a person should dress or making them wear a seatbelt. It means the government is getting into our lives and that can just keep going.

    A couple of years ago while in Connecticut visiting relatives I saw many riders without helmets - even at highway speeds. I couldn't believe their logic. They're basically saying if they fall they don't care what happens. Of course some might think that those of us who ride with full gear think that way too.

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  15. I’m with you – wearing a helmet increases your chances of surviving a motorcycle crash … but look at the stats in Canada (and we have a helmet law). In Canada there has been an increase in the total number of fatalities. There are simply more bikes on the road. When you look at the actual rate, that is the number of deaths per 10,000 registered riders, you see a decrease. You might want to note as well that most of the fatalities were the result of excessive speed and loss of control in road bends and many of them were alcohol related. In Canada only 15% of the fatalities were riders not wearing helmets (of course half of them might have survived if they had been wearing). In the end – it’s really what’s under the helmet that will save your life.

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  16. I have to add one more thing – you can’t legislate common sense!

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  17. Jeff, there was an American Blogger Wendy Moon who I followed until she died, who was rasing these points both with rider training and helmet use. Her Blog site Moonrider Redux is still up and this was raised over the winter 2009/10, into March 2010, though her health deteriorated before we got to the final piece. I think the arguement was being developed that we all have a level of risk that we are willing to accept in an activity, possibly one which feeds our enjoyment of it and as the kit or training improves so we 'showboat to move the risk back to 11. Risk Compensation

    Also aspects American Culture highlighted in the Hurt report don't help, for example DUI seems more common and socially acceptable than in the UK as and the driving and riding tests are very much simpler than in UK or NZ.

    I say this not to through stones as UK has enough glass houses of its own, just that it a very complex social model you are looking into here

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  18. Hello Everyone,

    Please take this as a very personal thank-you to you all for such erudite replies. You've all answered the question I posed with a great deal of thought and detail. Having worked in the southern US for a short time in the 1990's, the issue of personal freedom came through quite strongly in everyday conversation so I guess it's really not a surprise.

    I am surprised however, that there are calls to repeal helmet law in some states which already have it in place as there must be irrefutable evidence of its positive impact. I guess that it comes back to the "personal freedom" issue, particularly if you don't trust the state/national government to do the right thing by its citizens. In NZ, the previous Labour government were basically thrown out of office for becoming too intrusive in our everyday lives so it's not hard to understand that it could be the thin end of the wedge.

    Trobairtz' comments about insurances was an eye-opener as I'd assumed that overall costs would be low compared with NZ but apparently not. The reason I support the use of protective gear is because in NZ, we have a system of no-fault accident compensation which essentially means that that if you injure yourself, you get treated; irrespective of fault. People who injure themselves on motorcycles (or anything else) through either their own fault or someone else's hike the compensation component of my annual registration fee as there's no discount for being claim-free. Seems hardly fair.

    A few of you commented on motorcycle accident statistics in general and their root causes. From what I've read about data collection in the world, the confidence levels in attributing true fault are extremely low. I'd treat any claims of root cause with a great deal of suspicion. Motorcyclists everywhere seem to attract more blame than rigorous analysis would suggest.

    The only thing we can have direct impact on is our personal safety, through ATGATT and making sure that our riding skills, particularly situational awareness; are of a high standard. And that brings us back full circle does it not? With personal freedom comes personal responsibility. If that doesn't happen, we all pay for it one way or another.

    It's a complicated old world with no black and white, just shades of grey isn't it?

    Sincere thanks again for all the fantastic responses!

    Geoff

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  19. I am late to this, but I would still like to offer comment.

    “So what am I missing in the case of US authorities not legislating for the use of helmets?”

    US authorities have legislated helmet use. At one time, most all states had strict helmet laws. The reversal came about when motorcyclists and support group lobbied to reverse the laws. They have been very successful.

    http://www.npr.org/templates/story/story.php?storyId=7761667

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  20. Hi Bryon!

    Thanks very much indeed for that link, it was really insightful. I don't know whether I'm reading something into the article which isn't really there but one paragraph seems to infer that it's the ZZ Toplookalike Harley riders who really object to being told what to do. I guess they stick out because the voice of the moderate motorcyclist isn't quite so loud. Not sure what power they hold over state legislature though.

    Interesting that they talk about their "rights", but never the responsibilities which go with being a true citizen. Same all over the world.

    There's a "Biker's Rights" group in NZ who have similar leanings. A lot of us don't want anything to do with them because of the connotations of rights having to be earned, but they're not interested in responsibilities to themselves,loved ones or the wider community. There was a recent NZ forum post where a bunch of them were talking about organising protest rides against increased road user charges arising from motorcycle accidents. I asked how many of them had attended rider training in the last 2-3 years to at least do something to help themselves..... deafening silence. I despair sometimes...

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  21. "...it's the ZZ Toplookalike Harley riders who really object to being told what to do."

    You nailed it, but they are only one segment.

    "...the voice of the moderate motorcyclist isn't quite so loud. Not sure what power they hold over state legislature though."

    Here’s a big one for the states and the voice of the moderate motorcyclist and their position.

    americanmotorcyclist.com/Rights/PositionStatements/VoluntaryHelmetUse.aspx

    *The AMA believes that adults should have the right to voluntarily decide when to wear a helmet.
    *Mandatory helmet laws do nothing to prevent crashes.

    I cannot believe they actually came up with that line about helmets doing nothing to prevent crashes. Helmets help YOU SURVIVE A CRASH. No one has ever claimed helmets prevent crashes.

    "...I asked how many of them had attended rider training in the last 2-3 years to at least do something to help themselves..."

    Since you got me out of the corner swinging...

    While I believe vehicle drivers do share fault, I risk being tarred and feathered by my fellow US motorcyclists with what I am about to further write. The Northwest of the US is clouded over a majority of the year. On a crowded workday commute, those who wear dark colors blend away in a sea of buses, cars and trucks. I also find some motorcyclists in the US will also...

    *Not take a training class
    *Proudly ride without a license endorsement
    *Won’t carry medical insurance
    *Ride reckless on highways
    *And choose to not wear a helmet

    While this may make me appear harsh, my first close call ever on a motorcycle was caused by a reckless rider on a high powered super bike riding crazy on the highway. Grrr

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  22. Bryon:
    THE AMA SAID THAT???? I'm at a loss for words!

    Yep, in NZ, auto drivers do share a pretty high percentage of accidents involving motorcyclists. The point another contributor made about risk/excitement etc being part of the attraction of riding a bike is perfectly true. The point is though that because bikes are inherently less stable than 4 wheels, it's prudent to mitigate controllable risk (helmet, ATGATT, skill training etc). It doesn't mean that you have less fun. In fact, since I started my journey towards becoming an advanced instructor, it's added significantly to the enjoyment factor.

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  23. I do understand the “don’t interfere with my freedom of choice” issue and why people use it, but when it comes to helmet laws, that is a load of nonsense really. Unlike Geoff, when I started to ride motorbikes in the UK, the wearing of a helmet has always been compulsory, so everybody does it and (almost) nobody complains about it having to do so. Like many non-Americans, I find it difficult to understand why somebody who does have the choice would want to risk increase the chances of death or more serious injury by not wearing one. Sure, it is a good feeling to take off your helmet and feel the wind in your hair and I did try it once, but is that increase in risk worth it? Surely not. The way I look at it is this – how would my friends and family feel if I was killed in an accident just because I wasn’t wearing a helmet? No matter what the argument against it, wearing a helmet has got to make sense. Fighting your battles about freedom of choice and avoiding the increasing influence of the nanny state is definitely worthwhile, but not when it comes to wearing a helmet.
    BTW – The comment I liked most here? Easy. “ it’s really what’s under the helmet that will save your life”.

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  24. Geoff,

    I don't understand the logic of not wearing a helmet either, but I can see the politicians' point of view. When faced with a bunch of irate single-issue voters that don't want to wear helmets it is easier to just go along instead of argue. If you do argue you risk being labeled a liberal, nanny-government proponent. They have already made up their minds and you would have an easier time teaching a cat geometry.

    One helmet story: I used to live in New Hampshire where the state motto is "Live free or Die" - naturally helmets are only required for minors. Next door is Massachusetts which has a helmet law. A friend would windsurf along the coast and watch bikers riding north over a bridge just after the border - scooping off their helmets as they rode over the bridge. You can't legislate common sense.

    One comment on accidents - as much as we want to blame the idiot in a Volvo turning across traffic, often the enemy is us. Everyone knows that bikes lose vs cars, but conveniently forget that a large fraction of bike accidents are single vehicle accidents (somewhere I've seen a figure of 60%/40% multi/single vehicles). Pilot error in other words - with the 2 most common causes being alcohol & excessive speed. Alcohol is just stupid, but speed is often ignorance, inexperience, or lack of skill. Or as one racer said, "Well, we ran out of road and talent at about the same time."

    Tom

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  25. Gary:
    When I was young and bulletproof, I did the odd short ride without a helmet but even to a hormonal teenager, it didn't make sense. Like you, I'm a staunch opponent of nanny state laws but defending freedom to decide on this particular issue doesn't make sense. I'd be picking that there are rather more intrusive and shadowy laws which quietly impinge on a citizen's rights to crusade on!

    Tom:
    Yes indeed! Politics pretty much the world over isn't about principles and as you correctly say, principles and common sense go out of the window if it's going to cost votes. Also as Stacy said, you do have to spend some time in the USA to understand that the fight for freedom is etched in more recent times than many countries.

    Completely agree about single bike accidents and the same causes also apply in bike/auto collisions - failure to ride defensively. Which is why I'm a big advocate of periodic re-skilling or upskilling to get an independent assessment of your skills. I guess the people who won't wear helmets simply don't think that way though as it would infringe on their rights to die or maim themselves through incompetence.

    BTW, our cats are lousy at geometry too, but one of them isn't to bad at calculus :-)

    Thanks so much for dropping by!

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  26. I've just had an email from fellow rider Carl Minkel from Maryland and he's given me permission to publish the part on helmet law and other pertinent comments. Another superb response!

    Geoff,
    I just got around to checking your blog again and I understand your perplexity at the USA helmet laws. As several of your commenters noted, it's about the notion of "freedom". Here in Maryland, we have had mandatory helmet use since the early 1990's. Still, every year repeal or modification of the helmet law is debated in the legislature (as if our legislators have nothing better to worry about). Clearly there is a very vocal group clamoring for the politician's ear.

    One of my former martial arts students had a near fatal accident while participating in an organized ride to repeal the helmet law. He nearly died but was airlifted to a shock/trauma facility and underwent a long painful reconstruction process. When he had more or less recovered, he promptly went on another ride to protest the helmet law. On the same stretch of road as his previous accident, he experienced a "flashback" and again low sided into a guardrail. Like the first "accident", he was not wearing a helmet in protest. This time the recovery was not complete and now he is permanently disabled. However, he still believes the helmet law should be repealed. He jokes about how the doctors call him "The 7 Million Dollar Man" because that's how much his surgeries and physical therapy have cost the Maryland taxpayers. I have more luck reasoning with my cat than I have with this fellow.

    People speak of their rights, but rarely of their responsibilities. Perhaps another USA example would help. I am a self defense instructor and have taught courses for police, corporations, universities and the general public. Although Maryland is one of the strictest states when it comes to gun control, I can still purchase more or less any firearm I wish (with some exceptions) as long as it's not full auto (e.g. a machine gun). When I first came to Maryland in the 1960's, you had to take a written test and a road test in order to get a license to drive a car. You could, however, buy a firearm as long as you did not have a criminal record - there was no requirement that you demonstrate any competency with firearms. It is not much different today. There are waiting periods and you have to watch a mandatory video but if you have the funds that Dirty Harry 44 Magnum is yours.

    Similarly, if you learned to ride on a Bridgestone 175 Hurricane Scrambler (as I did) there is absolutely nothing to stop you from hopping on a 200hp Superbike (or a Street Triple :-) ). It may be your right, but is it a responsible thing to do?

    Many of your commenters talked about going without a helmet when they were younger but wearing one now. I am in the same category. In my early riding years, helmets were not mandatory. I wore a helmet when at highway speeds and promptly took it off when I motored at lower speeds. Now, even when practicing on my own property I wear a helmet. Curiously, Maryland only requires helmets for bicycle riders under age 16 and it was a major effort to get that law passed.

    Anyway, I thought you might be interested.
    I have not investigated how to post on your blog but feel free to use any/all of my email if you wish.
    Best. -- Carl Minkel

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  27. That is a very interesting email from Carl, the rights vs responsabilties is an interesting argument and certainly hits the nail on the head. Yet after reading all this and the comments from those that live in the states it still does not make one ounce of sense to me. A lawyer once said to me.."it is not about right or wrong, but about the law". If the law says it is okay , even if it is stupid then that is fine. When I owned my yacht, I spent a great deal of money on a life jacket that was not cumberson, and regardless of weather I very rarly would not wear it.

    You cannot legislate common sense.

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  28. Roger,
    Yes indeed! I've also had some emails too from people who didn't want to publicly postwhat they wanted to say. As Stacy from Bolty.net said, you need to have lived in the USA to understand the varying concepts of freedom as it's somewhat different from a "European" notion because of the way it's evolved.

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