### CPSC Requirements Matrix

CPSC Paragrap h Title Requirement or Test Issues Possible Solutions

1512.1 Scope Requirements do not apply to "track bicycles" or "one-of-a-kind" bicycles. Track bicycle definition does not allow clincher tires. Should definition include all fixed gear bicycles and adopt new requirements specific to this niche? 1. Modify to include clincher tire 2. Consider new "fixed gear" definition per other comments

1512.2 Definitions Bicycle; Sidewalk Bicycle; Seat Height; Track Bicycle; One-of-a-kind Bicycle; Normal Riding Position. There are now many more types of bicycles than when this specification was written. Should we define the large categories and adopt regulations and tests that are more specific to each category? Suggest ASTM use classification. Definitions of the various bike types (like the CEN classifications) are too difficult to agree upon. Separate fixed gear bikes vs track bikes. Clearly define children's bikes.

1512.3 General Bicycles subject to the regulations shall meet the requirements. Bicycles sold that require assembly shall meet the requirements after assembly. 1. No clarity on bicycles sold without pedals 2. Bikes are now sold over the internet Options: 1. Leave in ambiguity regarding pedals (retailer issue) 2. Exclude "racing" bicycles 3. Adopt standard pedal dimensions for pedal-related tests 1512.4 Mechanical Requirements

1512.4a Assembly Normal intelligent adult shall be able to assemble.

1512.4b Sharp Edges No sharp edges or burrs. Add the following language: "accessible during normal handling or riding bicycle" (From TAG) This would exclude items such as chainrings.

1512.4c Integrity No visible fractures resulting from testing. 1512.18d, 1512.18e, 1512.18p

1512.4d Attachment Hardware Screws, bolts & nuts shall not loosen, fail or fracture. 1512.4e & f

Reserved N/A

1512.4g Excluded Area No protrusions except cables up to 6.4 mm (1/4 in) and cable clamps made of material not thicker than 4.8 mm (3/16 in) may be attached to the top tube. Cable stops on TT violate this requirement. Allow protrusions up to 12mm. 1512.4h Reserved N/A

1512.4i Control Cable Ends Protective caps or treated to prevent unraveling. 1512.18c. Accessible cable ends only

1512.4j Control Cable Abrasion Shall not abrade over fixed parts and shall enter and exit cable sheaths inline. Need diagram for example

1512.5 Requirements for Braking

Systems

1512.5a Braking system Shall be equipped with front and rear wheel brakes or rear wheel brakes only. Fixed gear bikes on the market with no hand brakes/one front hand brake/two hand brakes Option 1 Specify bike to be equipped with at least one independent braking system (CEN requires 2). This would also apply to rear-only coaster brakes. Option 2 Define fixed gear bike as any other type of bike (required to have at least one brake)

### CPSC Requirements Matrix

1512.5b Handbrakes Test 10 times by applying a force sufficient to cause the lever bar to contact the handlebar or 445 N (100 lbf.) and shall be rocked back and forth with 150 lbs on seat and there shall be no visible fractures, failures, movement of clamps, or misalignment of brake components. Test per 1512.18d2, 1512.18d2iii.

1512.5b1 Stopping Distance 150 lb rider, 15 mph, stop in 15 ft. Test per 1512.18d2v & vi.

1512.5b2 Hand Lever Access Readily accessible when in a normal riding position.

1512.5b3Grip Dimension Shall not exceed 89 mm (3 1/2 in) between the pivot point and lever midpoint and the handlebars - may increase toward open end (figure 5). Some current brake levers do not meet this std. Increase to 100 mm.

1512.5b4Attachment Securely attached with locking device, lock washer lock nut, etc. and shall not loosen during rocking test. Cable anchor bolt shall not cut cable strands. Test per 1512.18d2iii.

1512.5b5Operating Force Less than 44.5 N (10lbf) shall cause the brake pads to contact the braking surface applied to the hand lever at a point 25 mm (1.0 in) from the end of the lever.

1512.5b6 Pad & Pad Holders Pads replaceable and adjustable to engage breaking surface without contacting tire or spokes, pad holders securely attached. Brake pad retained during rocking test. Test per 1512.18d2iii. No disc brake standard 1512.5b7 Reserved N/A

1512.5b8 Hand Lever Location Rear brake right, front brake left. Does not account for only one hand brake such as on some fixed gear bikes, see 1512.5(a) Differentiate between track bikes and fixed gear bikes. When only one brake is installed, lever located on the right to make it consistent with most other nation's standards and track bikes (CEN defers to national standards for placement) 1512.5b9 Hand Lever Extensions Tested like levers. 1512.5c Footbrakes Tested per 1512.18e2

1512.5c1 Footbrake Stopping Distance 150 lb rider, 10 mph, stop in 15 ft. 1512.18e3. 1512.5c2 Footbrake Operating Force Opposite of drive force

1512.5c3 Crank Differential Not more than 60° at no less than 13.6N-m (10 ft-lb) both directions.

1512.5c4 Independent Operation Shall function independent of any drive gear positions or adjustments.

1512.5d Footbrakes and Handbrakes

in Combination Shall meet all requirements of each. 1512.18e3. 1512..5e1Sidewalk Bicycles Not handbrakes only.

1512..5e2Sidewalk Bicycles If seat height 22 in. or greater at lowest adjustment, must have footbrakes. 1512.18f.

1512..5e3Sidewalk Bicycles If seat height 22 in. or greater at lowest adjustment with no footbrake must not have freewheel. Label required - No Brakes. 1512.18f.

1512.6 Requirements for Steering

Systems

### CPSC Requirements Matrix

1512.6a Handlebar Stem Insertion

Mark Permanent mark indicating minimum insertion depth. Mark no affect structural integrity. Shall not be less than 2 1/2 times the stem diameter from the lowest point of the stem. Stem strength maintained for at least the a length of one shaft diameter below the mark. Applies only to quill stems Add threadless stem requirements. Adopt clamping requirements EN 14764:2005 (e) 4.7.4. Also, max steer tube exposure - no more than 40 mm in spacers (between top of hdset and bottom of stem).

1512.6b Handlebar Stem Strength Shall withstand a force of 2000 N (450 lbf) (1000N (225 lbf) for sidewalk bicycles). 1512.18g. 1. Not consistent (lower) than EN requirements 2. No differentiation for DH, road, ATB etc. Consider using EN requirements

1512.6c Handlebar Shall allow comfortable and safe control. Ends shall be symmetrically located in respect to the longitudinal axis. No more than 406 mm (16 in) above the seat in its lowest position. Recumbents do not meet the standard Exempt recumbents for the regs by definition. Some comfort bikes also have this issue. Suggest increase to 500mm.

1512.6d Handlebar Ends Ends shall be capped or covered. Handgrips, end plugs, control shifters shall be secure against removal by a force no less than 66.8 N (15 lbf). 1512.18c.

1512.6e Handlebar and Clamps Assembly instructions must include warning about the danger of damaging stem-to-fork assembly and the risk of injury from over tightening. 1512.18h Applies to quill stems only Include when creating new threadless stem standard 1512.7 Requirements for Pedals

1512.7a Construction Pedals shall have left-hand/right-hand symmetry. Tread surface on top and bottom except if one sided. Clipless pedals do not have treads No tread surface required. EN 14764:2005 (e) 4.13.1.3 1512.7b Toe clips Toe clips to be securely attached.

1512.7c Pedal Reflectors Shall have reflectors. 1512.16e Clipless pedals and most aftermarket BMX pedals do not have reflectors Create exception for clipless pedals (aftermarket pedals are not required to have reflectors). Adding reflector "platforms" to clipless pedals is not a solution. Continue reflector requirement for children's bikes and bikes sold with non-clipless pedals.

1512.8 Requirements for Chain DriveShall operate without catching or binding. Chain tensile strength no less than 8010 N (1800 lbf). (6230 N (1400 lbf) for sidewalk bicycles).

1512.9 Requirements for Protective

Guards

1512.9a Chain Guard Bicycles with a single front sprocket and a single rear sprocket shall have a chain guard. Shall cover the top strand of the chain and at least 90° of the perimeter where the chain contacts the drive sprocket (figure 7). Rearward point at least 8 cm (3.2 in) forward of the centerline of the rear axle. Top shall be twice the width of the chain forward of the rear rim, rear part may be tapered to 1/2 the chain width. Chain guard shall prevent a rod of 9.4 mm (3/8 in) diameter and 76 mm (3.0 in) length from entrapment between the upper junction of the chain and the sprocket from chain side in any direction within 45° from line normal to the sprocket. 1. Does it apply to belt drives? 2. Consumers do not want chainguards except on children's bikes Option 1: Update to allow conventional chain guard OR chainwheel disc (bash guard) similar to EN 14764:2005 (e) 4.16 Option 2 (preferred) Limit full chainguard requirement to children's bikes, does not apply to bikes not intended for children (can use bash guard style)

### CPSC Requirements Matrix

1512.9b Derailleur Guard Shall be guarded to prevent the chain from interfering or stopping the rotation of the wheel through improper adjustments or damage. 1. Will not fit on modern wheel designs or 11-speed drivetrains 2. Often removed by consumer Create exception for "racing" bicycles.

1512.10 Requirements for Tires Inflation pressure molded into side of tire in letters no less than 3.2 mm (1/8 in) in height. English using Arabic numerals. Tire shall remain intact on rim while being tested under a load of 2000 N (450 lbf) per 1512.18j. Tubular exempt. 1512.18j. Tubular rolloff - should there be a requirement for tubular tire attachment? No recommendation 1512.11 Requirements for Wheels 1512.11aSpokes No missing spokes.

1512.11bAlignment Wheel assy shall be aligned such that no less than 1.6 mm (1/16 in) clearance exists between the tire an fork or any frame member when the wheel is rotated in any position.

1512.11c Rims Rims shall retain the spokes and tire when side-loaded with 2000 N (450 lbf) and tested per 1512.18j. Sidewalk bicycles exempt. 1512.18j.

1512.12 Requirements for Wheel

Hubs

1512.12a Locking Devices Wheels to frame with a positive locking device tightened to manufacturers specifications.

1512.12a1Rear Wheels No relative motion between the axle and the frame when a force of 1780 N (400lbf) is applied symmetrically to the axle for a period of 30 seconds in the direction of wheel removal.

1512.12a2Front wheels Locking devices, except QR, shall withstand torque in the direction of removal of 17 N-m (12.5 ft-lb). No disc brake QR standard

1512.12bQuick Release Devices Shall be adjustable for setting tightness. Locked and unlocked position visible to rider. QR clamp shall emboss the frame or fork when locked.Differs from EN requirements EN standard is confusing and hard to test. Need to exclude "emboss" for carbon dropouts as this can damage the dropout.

1512.12c Front Hubs Positive retention feature when not QR tested per 1512.18j3 so wheel will not separate from fork. 1512.18j3. No specific retention tab requirement even though industry standard Create retention tab requirement or adopt relevant EN standard

1512.13 Requirements for Front Fork Strength tested by 39.5 J (350 in-lb) of energy per 1512.18k1 without visible indication of fracture. Sidewalk bicycles exempt. 1512.18k1. How do we deal with nonductile materials, i.e. carbon fiber? Adopt CEN impact testing? Consider creating standard based on fork material and intended use. Need suspension fork test standards. CEN is a good starting point.

1512.14 Requirements for Fork and

Frame Assembly Strength tested by applying a load of 890 N (200 lbf) or at least 39.5 J (350 in-lb) of energy, whichever results in the greater force per 1512.18k2 without visible evidence of fracture or frame deformation that significantly limits the steering angle over which the wheel can be turned. Sidewalk bicycles exempt. 1512.18k2. Much lower then EN requirements, no impact test, no carbon fork standard Allow EN requirements as alternative 1512.15 Requirements for Seat

1512.15aSeat Limitation No part of the seat shall be more than 125 mm (5.0 in) above the top of the seat surface at the point where the seat surface is intersected by the seat post axis. Recumbents do not meet the standard Exempt recumbents for the regs by definition

### CPSC Requirements Matrix

1512.15bSeat Post Permanent mark indicating minimum insertion depth. Mark no affect structural integrity. Shall not be less than 2 times the stem diameter from the lowest point of the stem. Stem strength maintained for at least the a length of one shaft diameter below the mark. Seat mast diameter clarification required for "racing bikes" and aero designs, no "insertion" with seat mast design, variety of designs Add requirements for bicycles with seat masts and define based on cross section and minimum "overlap" versus insertion mark.

1512.15cAdjustment Clamps Shall be capable so securing the seat in any position preventing movement in normal use. Following the road test, the seat clamps shall be tested per 1512.181. Follow CEN standard

1512.16 Requirements for

Reflectors Shall be equipped with reflective devices to permit recognition and identification under illumination from motor vehicle headlights. Off center reflectors acceptable if they meet this and 1512.18m & n. The combination of reflectors has a clear field of view of +/- 10° vertically and +/- 50° horizontally. Sidewalk bicycles exempt. 1512.18m2, 1512.18m & n.

1512.16a Front, Rear, and Pedal

Reflectors Colorless front-facing. Colorless or amber pedal. Red rear-facing.

1512.16bSide Reflectors Retroreflective tires or reflectors mounted on spokes of each wheel, 76 mm (3.0 in) from inside of rim visible on each side of the wheel

1512.16c Front Reflector The reflector shall not contact the ground when bike is on the ground. The optical axis of the reflector shall bedirected forward within 5° of horizontalvertical alignment when wheels tracking straight. Must meet 1512.18m test. Look at the requirements for 1512.18(m) - reflector mount and alignment test. Does not address band-style clamps.

1512.16d Rear Reflector The reflector shall not contact the ground when bike is on the ground. Mounted to the rear of the seat mast with the top of the reflector 76 mm (3.0 in) below the top of the seat post. The optical axis of the reflector shall be directed rearward within 5° of horizontal-vertical alignment when wheels tracking straight. Must meet 1512.18m test. Look at the requirements for 1512.18(m) - reflector mount and alignment test. Does not address band-style clamps.

1512.16e Pedal Reflectors Shall be located on front and rear. Shall be recessed. Clipless pedals and most aftermarket BMX pedals do not have reflectors Create exception for clipless pedals and aftermarket pedals.

1512.16f Side Reflectors Within the spoke cage not to exceed the angle of the spokes. Colorless or amber front; colorless or red rear. Wheels without conventional spokes Revise description of attachment methods

1512.16g Reflector Tests The pedal, front-mount, rear-mount, and side mount reflectors must meet 1512.18n tests. 1512.18n.

1512.16h Retroreflective Tires When used instead of reflectors, must meet the requirements of 1512.16h 1-4 and 1512.18o2i.

1512.16i Retroreflective Rims When used instead of reflectors, must meet the requirements of 1512.16h 1- 3, 1512.18r and 1512.18o. 1512.17 Other Requirements 1512.17a Road tests Must meet 1512.18p 1512.17bSidewalk Bicycle Proof Test Must meet 1512.18q

### CPSC Requirements Matrix

1512.17c Ground Clearance Tilt 25° vertical without pedals or any other part except tires touching ground.How far does pedal stick out from crank arm? Does not account for suspension system impact on ground clearance Define standard pedal - EN standard is also 25°but accounts for suspension sag EN14764:2005 (e) 4.13.2.1

1512.17dToe Clearance If not equipped with positive footretaining devices shall have at least 89 mm (3 1/2 in) between centerline of pedal and front tire or fender (figure 6). Does not account for very small frame sizes Adopt EN14764:2005 (e) 4.13.2.2 - standard is 100mm. Instruction/warning label for bike if intended for use with clipless pedals.

1512.18 Tests and Test Procedures If tests are different from CEN tests, double testing may be required. Follow applicable CEN tests or accept specified CEN tests in lieu of CPSC tests to avoid duplicative testing.