The “Clear Vision” campaign has been launched to reverse the flawed decision taken by Roads Minister David Jamieson to sustain the Department for Transport (DfT) prohibition of dark visors, which have a minimum, light transmittance of 18%.

“Clear Vision” upholds the majority decision taken by MAG members at the groups’ annual conference in 2002 supporting the use of dark visors by motorcyclists.

The campaign will concentrate on writing a letter to your MP ensuring they are aware of motorcyclists’ views and the strength of feeling against the decision taken by the DfT.

Despite the overwhelming recommendations of MAG members, riders generally and the majority of rider bodies for a change in the legislation to permit the daytime use of Dark Visors the Government has capitulated to the illusions of the safety lobby.

The document contains all the information you require from background information to a sample letter to send to your MP, where to find him or her and how to become more active in motorcycling issues.

The response to the consultation and lobbying on Dark Visors was done by the book.

MAG influenced and implemented the full support of the National Motorcycle Council (NMC) but the DfT used the misguided conception that riders would misuse dark visors despite the major safety advantage for riders.”

MAG remains convinced that the wearing of dark visors especially in conditions of glare would not present a danger to other vulnerable road users especially with recommended promotion of rider awareness and safety on the use of dark visors.

Riders are being forced by the DfT despite the fear of prosecution to use dark visors not approved to a recognised standard in which impact resistance, optical qualities and colour filtering of an unknown quality which could adversely affect signal recognition etc, could be compromised.

MAG’s Position

Dark Visor use in daytime conditions can help to minimise the danger of disorientating glare, there are positive benefits in terms of rider behaviour to be had from dark visor usage, specifically that one aspect of venturesome behaviour (risk taking) may be reduced.

We would further contend that a scientifically arrived at standard for dark visors should be arrived at urgently and implemented by way of the necessary legislation, thereby removing the current source of confusion and putting an end to unnecessary prosecutions.

MAG will also continue to fight for a sensible solution to this problem through its positions on government task forces and standards bodies.

Our aim is to persuade the minister not only to listen, but also to turn around a flawed decision to a fearless support of Dark Visors.

“Clear Vision” is also available at www.mag-uk.org will be published in the members newspaper Streetbiker, the activists newsletter Network and Network Online at www.network.mag-uk.org

Background

Dark Visors Public Consultation - MAG Looking Ahead

The Motorcycle Action Group welcomed in March 2002 the promise kept by the government for public consultation on the future of *motorcyclists' visors.

The consultation followed the controversial findings of the published research completed in 2001 for the *DTLR (now the Department for Transport DfT) by the *Institute of Consumer Ergonomics (ICE Ergonomics Ltd) which looked at the benefits and disadvantages of darker visors.

MAG favoured Option 1 in the consultation to accept visor standards, which have a minimum light transmittance of 18%, the current “banned” Dark Visors used by motorcyclists.

MAG contended that in the real world, sudden and unexpected glare can give riders a problem. Dark Visors reduce eyestrain in this circumstance, enabling riders to look longer and more carefully for potential hazards.

The consultation document considered three options on Dark Visors.

Option 1 - Accept visor standards which have a minimum light transmittance of 18% (as proposed by most members of the BSI Committee). This would bring visors into line with the minimum permitted light transmittance for motorcyclists' goggles.

Option 2 - Accept visor standards which have a minimum light transmittance of around 34% (i.e. effectively the lowest level of the minimum range identified by ICE Ergonomics).

Option 3 - Retain the present minimum allowed light transmittance of 50% (which is just above the top of the minimum range identified by ICE Ergonomics). In principle, current standards could be readily modified to cater for *photochromic, and perhaps polarised, visors when the technology is ready.

MAG was led by the feelings expressed by our own members and riders generally, it was obvious that there was a substantial demand for a change in the law to permit the daytime usage of dark visors.

Details of the original consultation are at http://www.roads.dtlr.gov.uk/consult/visors/index.htm

It was noted that unlike previous consultations there was no electronic form to fill in requiring a need to print the documents out.

Summary of the consultation responses can be found at http://www.roads.dft.gov.uk/consult/visors/responses/index.htm

*Legislation requires that motorcyclists' visors comply with UN ECE Regulation 22.05 or British Standard BS4110:1979 (as amended). These standards currently allow visors to have a light tint with a light
transmission of no less that 50%. The light transmittance value relates to the percentage of visible light which the visor material allows to pass through.

*Department for Transport, Local Government and the Regions, Great Minster House, 76 Marsham Street, London, SW1P 4DR. www.roads.dft.gov.uk

* Institute of Consumer Ergonomics (ICE Ergonomics Ltd) http://www.ice.co.uk. Copies are also available from: Jayshree Lakha, Transport Technology Ergonomics Centre, Research School in Ergonomics and Human Factors, Holywell Building, Holywell Way, LOUGHBOROUGH, Leicestershire, LE11 3UZ
(Tel: 01509 283310
email: j.lakha@lboro.ac.uk

*photochromic light-sensitive visor materials requiring long term technical solutions for designs to lend themselves equally to both day and night time use.

The Motorcycle Lobby on Dark Visors

The main UK motorcycling organisations meet under the umbrella grouping of the National Motorcycle Council (NMC).

The NMC was set up to provide a forum for the different interests within the motorcycle and powered two-wheeler community in order to promote the use of powered two wheelers (PTWs) and establish them as a mode which is recognised to be an integral part of transport strategy.

MAG along with the BMF and MRA implemented the full support of the NMC outlining in a joint document to the DfT the safety benefits, promotion of risk awareness, safety issues and enforcement regarding any changes in the legislation for visors.

Organisations involved include:

Motorcycle Action Group (MAG)
British Motorcyclists Federation (BMF)
Motorcycle Retailers Association (MRA)
Motorcycle Rider Training Association (MRTA)
Dispatch Association
Auto Cycle Union (ACU)
Motor Cycle Industry (MCI)
Automobile Association (AA)
RAC Foundation
Local Authority Road Safety Officers' Association (LARSO)
Driving Standards Agency (DSA)
Institute of Advanced Motorcyclists (IAM)

Solution for Dark Visors

SAFETY BENEFITS
The NMC considers that there will be net benefits and risk improvement to safer rider behaviour by legalising visors with a light transmittance of 18% for daytime use only.

Riders will be protected from the effects of sun glare but to be effective, a nominal light transmittance of 25% is necessary. Hence the NMC is unwilling to accept anything greater. A rider who is not suffering glare discomfort is more inclined to look longer and more carefully for potential hazards than one that is dazzled. This is perhaps difficult to express in scientific terms. In layman's terms however, it is the difference between taking a quick squint into bright sunlight and thereafter taking a chance on perceived hazards, compared to taking a longer and more careful look with the benefit of a dark visor.

Riders at present are using tinted visors not approved to a recognised standard and hence are of unknown quality in which impact resistance, optical qualities and colour filtering - which could adversely affect signal recognition etc, could be compromised.

Regulation to BSI with markings to indicate that a visor is approved to that standard would significantly reduce sale of these unapproved visors within the market place. This would be beneficial not only initially to the motorcycle accessory trade with increased sales but also to UK industry since manufacturers/distributors are currently restrained from marketing visors which do not comply with BS 4110 or UN ECE 22.05. These visors would satisfy demand in place of unapproved visor imports obtained through non-UK based sources or the Internet.

With visors indelibly marked with the appropriate standard and “DAYTIME USE ONLY” for those with less than 50% light transmittance, enforcement of both approved visors and tinted visors used within official lighting up times can then be readily achieved without the need for enforcement agencies to purchase equipment that measures light transmittance.

Visors with a minimum light transmittance of 80% will be mandated for night time use, compared with the current minimum of 50%, thus improving rider safety.

SAFETY RISK EVALUATION
There are some concerns that riders would be caught out in bad weather conditions of failing light and be tempted to ride with a dark visor in these conditions or at night. Unlike unapproved dark sunglasses, a visor can readily be "flipped" open if these circumstances are encountered. Alternatively, a "clear" replacement visor, if carried by the rider, can easily be fitted at the side of the road.

Motorcycles and scooters have various methods of storage, lockable space underneath seats or tail sections, top boxes soft luggage including panniers, tail packs and tank bags. In addition, purposely-designed visor pouches, similar to a “bum bag”, are readily available.

Many helmets are fitted with quick release mechanisms. Other release mechanisms do not require sophisticated tools, for example, a few twists of a coin may be all that is required to replace a visor.

Another worry would be that of a rider "caught out" at night or in conditions of failing light without a clear visor. Riders are already well educated and aware of the dangers of the usage of unregulated dark visors and the advantage of carrying a spare clear visor. The members of the National Motorcycle Council will positively support additional educated campaigns on the subject (see member action pledges below).

ENFORCING THE CHANGE
Enforcement by a non-endorsable fixed penalty ticket using the guidelines of official lighting up times would clarify any changes in legislation for police forces in the UK. Firstly, if a rider is wearing a non-regulated visor, secondly if a rider is wearing a regulated tinted visor within the official lighting up times and thirdly advice and warning would be given if a rider is using a non-regulated or regulated tinted visor during conditions of poor light.

SAFETY AWARENESS
Suggestions that a change in the law will worsen motorcycle safety records are of a major concern.

As part of a legislative framework there would be a greater likelihood of riders complying by wearing approved visors and tinted visors during periods between lighting up times than in the current situation when visors with a deeper tint than 50% light transmittance are not legally available.

With a tint of 18%, the sheer practicalities of using such a visor at night would discourage riders from using them after lighting up time.

Without accurate data it is unknown how many motorcycle Road Traffic Collisions (RTCs) are attributed to the wearing of a dark visor at night or in conditions of poor light.

While the current legislation remains in force a concerted safety, education and awareness programme cannot be promoted to uneducated riders presently using dark visors at night or in conditions of poor light. Therefore legislation accompanied by education and set guidelines, backed up by enforcement, could be an attributable factor in improving motorcycle safety.

PROMOTION – EDUCATION - AWARENESS - GUIDELINES
A full education and safety awareness campaign publicising guidelines for tinted visor usage could be initiated jointly between the Department for Transport, Police forces, Manufacturers represented by the MCIA, Retailers represented by MRA, road safety officers represented by LARSOA, Training Schools represented by the MRTA and BMF Rider Training Scheme, Motorcycle Press and Riders’ Groups, MAG and BMF. As part of this campaign the NMC recommend that a tinted visor awareness leaflet be produced through liaison within the Advisory Group on Motorcycling.

The Motorcycle Retailers Association (MRA), British Motorcyclists Federation (BMF), Motorcycle Action Group (MAG) Motor Cycle Industry (MCI) are represented on the British Standards Institute (BSI) Sub-Group PH/2/5. They would use their influence to include in the standard a requirement to mark tinted visors "Daytime Use Only". Instructions for use should also be printed on packaging, with particular reference to when it is appropriate and inappropriate to use them, care to prevent scratching, misting, etc. BSI may also wish to endorse or even join the publicity campaign when the revised standard is launched.

ACTION PLEDGES BY NMC MEMBERS AND INTERESTED PARTIES

Enforcement Agencies
Police forces that operate the "BikeSafe" awareness scheme would have a role to play in the education of riders.
Enforcement agencies would ensure that their officers have up-to-date information to give in response to enquiries from the public.
Trading Standards Officers can continue to ensure that only visors subject to recognised standards are marketed.

Manufacturers
MCI would explore with the NMC the possibility of producing a leaflet explaining the legislation regarding dark visors. If manufacturers and dealers agree, this could be included with each visor and possibly each helmet sold, even if not supplied with a dark visor at point of sale. However, manufacturers would wish to explore the possibility of DfT joint badging for such a leaflet, with production costs shared between Government and NMC member groups.

MCI would explore the possibility of the addition of a removable sticker on each dark visor explaining its legal usage.
MCI feels that an awareness campaign by Government via the trade press, or VED renewal mailings is another means of increasing awareness by end users. MCI would raise awareness in the trade and general motorcycle media with an appropriate press release campaign.

Point of Sale
Retailers, dealers and accessory mail order firms would point out the requirements of using a dark visor by leaflets, posters, etc.
Retailers would usefully advertise the campaign in-store at the point of sale.

Motorcycle Press
A high profile campaign through advertising and editorial comment in the motorcycle press could be undertaken.
Product evaluations on portage options and simple competitions with carry pouches as prizes could be published.

Riders Groups - British Motorcyclists Federation
BMF would publish prominent features in its house magazine Motorcycle Rider to inform members of tinted visor issues with particular emphasis on, "You've been accorded a privilege; don't abuse it."
Feature the issue in the BMF Website, Riderspace for members and visitors to the site.
Use the BMF publicity machine to issue press releases aimed at producing stories in the motorcycle press which promote the above message.
Raise awareness about responsible tinted visor use would be promoted at BMF Shows and other motorcycle shows where the BMF has stands.
The BMF has two set piece campaigns each year. A new tactic for 2003 has been adopted that keeps one campaign open but sets aside funding for a second. Raising awareness about dark visors could be the campaign that fills the bill.
Assist BSI to implement a publicity campaign on usage of tinted visors should a revised standard be issued.

Riders Groups - Motorcycle Action Group
MAG would highlight the safety issues surrounding tinted visors in the members magazine Streetbiker, also in Network, the activists newsletter thereby informing and encouraging members and affiliated clubs who are promoting the awareness campaign.
Raise the awareness through the Internet including MAG websites and electronic mailing systems to the motorcycle and mainstream press.
Promote awareness at MAG Shows and MAG stands at major exhibitions.
Include the issue and raise awareness through inclusions in ongoing campaigns and promotional literature.
Assist BSI to implement a publicity campaign on usage of tinted visors should a revised standard be issued.

MRA and MRTA
Provide support for a Government awareness campaign, for example give feedback on design or content of literature, also assistance with distribution to retail and rider training members, etc.
Participate in an integrated campaign alongside other NMC members to ensure consistency and effective delivery of message to target audiences

Use (MRA) representation in the BSI Sub-Group PH/2/5 to include in the standard a requirement to mark tinted visors "Daytime Use Only" and include instructions for use with particular reference to when it is appropriate and inappropriate to use them, care to prevent scratching, misting, etc in the packaging
Assist BSI to implement a publicity campaign on usage of tinted visors should a revised standard be issued
Include prominent features in own member publications to inform members of visor issues and any legislative changes
Use the RMI Press Office to issue press releases to promote awareness to the necessary audiences in a variety of media particularly the trade press
Encourage MRA members (and the wider retail trade) to display and promote point of sale awareness information
Encourage MRTA members and the wider training community to promote appropriate information and advice regarding visor usage to training customers including new riders

LARSOA
Provide endorsement and support for a Government led awareness campaign.
Participate in an integrated campaign alongside other NMC members to ensure consistency and effective delivery of message to target audiences
Include features in own member publications to inform members of visor issues and any legislative changes.
To include relevant features on the LARSOA website.
Encourage LARSOA members to promote and distribute awareness information.

Despatch Association
Provide support and endorsement for a Government awareness campaign.
Participate in an integrated campaign alongside other NMC members to ensure consistency and effective delivery of the message to target audiences.
Include features in own member publications to inform of visor issues and any legislative changes.
Encourage DA members to promote and distribute awareness information via its Association Magazine.

Motoring organisations
Feature information and a summary of legislation changes regarding tinted visors on their websites.
Include information on visor issues, where suitable, in their in-house and member magazines.

GUIDELINES
Guidelines could be formulated through the AGM’s sub group on Vehicle Security and Safety Taskforce.

TIMESCALES
To maximise publicity to all interested parties The International Motor Cycle & Scooter Show at the NEC Birmingham starts on the 14th November and would be seen as an ideal launch vehicle for an announcement to the change in the usage of dark visors given the high profile the show enjoys with the motorcycling public, press and mainstream media.

SUMMARY
Members of the NMC, representing the wider motorcycle community, recognise both the risks and benefits associated with a possible change to visor regulations. In addressing the risks, the community believes that an integrated awareness campaign and other associated activities would minimise the likelihood of illegal use of dark visors at night to an acceptable degree. Equally, the safety benefits for riders in having adequate protection against sun glare (and visor quality) are extremely important. Given that any regulation change will also allow the opportunity to reduce the allowable level of tint for night time use (from 50% to 80% transmittance), the NMC strongly supports the case for permitting visors with an 18% light transmittance for daytime use only.

NMC November 2002

MAG will also continue to fight for a sensible solution to Dark Visors through the Government Advisory Group on Motorcycling (GAGM) and standards bodies such as The British Standards Institute (BSI).

Not forgetting how to achieve our objectives through:

Lobbying and meeting Members of Parliament
Well organised demonstrations
Publicity campaigns
Alerting and enlightening the non motorcycling public

Write to Your MP

Suggested Letter to Your MP

(Your MP) (Your address)
The House Of Commons
London
SW1A 0AA

(Date e.g. ??th January 2003

Changes in the Legislation for Motorcycle Helmet Visors

Dear [Your MP]

I am a member of your constituency. [ and a member of the Motorcycle Action Group/Club etc.]

I am writing to raise my concerns on the recent decision following a consultation document by the Department for Transport to sustain its prohibition of dark helmet visors for day time use only.

The announcement was made by the Transport Minister David Jamieson despite the support by the majority of motorcycling organisations to change the legislation.

Legislation requires that motorcyclists' visors comply with UN ECE Regulation 22.05 or British Standard BS4110:1979 (as amended).

These standards currently allow visors to have a light tint with a light transmission of no less that 50%.

Motorcyclists requested a reduced to 18% of light transmission for day time use to bring visor standards in line with the current permitted light transmittance for motorcyclists' goggles.

The light transmittance value relates to the percentage of visible light which the visor material allows to pass through.

The greatest worry of riders is the effects of sun glare especially at this time of year.

A rider who is not suffering glare discomfort is more inclined to look longer and more carefully for potential hazards than one that is dazzled. This is perhaps difficult to express in scientific terms. In layman's terms however, it is the difference between taking a quick squint into bright sunlight and thereafter taking a chance on perceived hazards, compared to taking a longer and more careful look with the benefit of a dark visor.

There are some concerns that riders would be caught out in bad weather conditions of failing light and be tempted to ride with a dark visor in these conditions or at night, recommended promotion of rider awareness and safety on the use of dark visors would be undertaken.

In these conditions a pair of cheap and nasty sunglasses can be worn by a rider under a clear visor yet a positive safety aid in the form of a dark visor is illegal.

MAG [I/We] would respectfully request that you would write to the minister requesting why the majority of motorcyclists views were ignored or to put forward a Parliamentary Question to the minister on the issues above.

I would welcome your comments on this issue. If there is any further information you require please do not hesitate to contact me.

Yours [sincerely if you know their name or have dealt with them before]
[faithfully if you do not know their name]

Your name

What Next

As you have read through this document you may want to include some extra points that you think are relevant or even some views of you own.

If you receive a reply FOLLOW UP with a letter of thanks and answer any points the MP raised which were left unanswered.

Send a copy of any letters received to Director of Public Affairs MAG UK PO BOX 750 Rugby CV21 3ZR. FAX 0870 444 8 449 Email public-affairs@mag-uk.org

It's important that we update the overall picture of MPs' views so that we know where our support lies.

MAG supporters get results by writing letters. As few as five individual letters to an MP make him or her sit up and take notice.

Your MP is not compelled to adopt your views just because you are a constituent.

It may be assumed that MPs take their constituents' views into account when forming their own but they can and sometimes do disregard a majority view held by those they represent

If you do not have email and aren't sure who your MP is then you may phone the House of Commons Switchboard: 02072193000

If you have email then you can search the websites listed below.

www.upmystreet.com put your postcode in and get lots of information including MP and council contacts.

www.faxyourmp.com enables you to Fax your MP.

www.mpexchange.co.uk allows you to campaign on certain issues.

www.ukonline.gov.uk information on local and central government.

www.tagish.co.uk/ links lists of Government department, councils, hospitals, Universities etc.

MAG E-mail Lists
The Following e-mail lists are available to provide people with regular information on MAG's activities:

mag-uk-info
Official press releases. Sent to magazines, on-line publications, and anyone else that wants to receive them.

mag-uk-network
Text-only version of Network - MAG's monthly activists' newsletter. (Copies available on-line.)

mag-uk-activists
Information for MAG activists. Campaign information, requests for help, items of interest, etc.
FEMA info presss releases and news.

Sending a blank (contents is ignored) e-mail to activate@mag-uk.org will subscribe you to all of these lists. The messages you receive on subscription will provide information on how to unsubscribe from the various lists.

MAG Activists In Forums
It's important that MAG be able to gauge the views of its members, and motorcyclists in general, when responding to Government consultations and deciding how to campaign on various issues.

Traditionally we've relied heavily on our network of local groups, reps and regional reps for this. This network is one of MAG's unique strengths, and we'll continue to use it and expand it.

However, we recognise that that not all members can attend local meetings, and not all motorcyclists are MAG members. To address this, we're asking our active members to help us do the best possible job of assessing rider views on various matters.

Many of our members are active on motorcycle-related Internet e-mail lists or forums - such as Ixion or Bikersweb. Various of these forums are quite receptive to discussing legislation or MAG-related issues. We're not asking that people stand on a soap-box and preach. What we're suggesting is that if an issue comes up, and you're a member of a forum that may be interested, consider raising the matter there, and starting a discussion.

Your regional rep (e-mail listed at http://mag-uk.org/contacts.html#reg ) will be interested in hearing the kind of opinions voiced, and any consensus reached. It's probably courteous to the forum to let them know you'll be reporting back when you initially raise the matter. Many forums are sensitive about material being quoted from the forum without permission, so a short summary in your own words may be best.

When e-mailing your regional rep on these matters, please include your name, membership number and post-code, for verification purposes.

Hopefully, this will result in MAG being better informed of riders' views, and participants in these forums being better represented.