Re: [CR]Questions about CPSC and Campy


Example: Framebuilders:Alberto Masi

Date: Wed, 1 Dec 2004 08:23:14 -0800 (PST)
From: Jerome & Elizabeth Moos <jerrymoos@sbcglobal.net>
Subject: Re: [CR]Questions about CPSC and Campy
To: Tom Dalton <tom_s_dalton@yahoo.com>, classicrendezvous@bikelist.org
In-Reply-To: <20041201154117.99626.qmail@web50201.mail.yahoo.com>


If one really wanted to know, one could go to the libary, or perhaps to an archive on CD if such is available for the mid-70's, and pull out the Code of Federal Regulations (CFR) issued in the years in question, specifically whatever CFR section pertains to consumer safety. However, the volume of Federal regulations published each year is pretty overwhelming, so this would hardly be a casual exercise. As an engineer involved in compliance with environmental regulations among other things, I can also tell you that such regulations are typically very complex, containing both legal and technical jargon, and often referencing some different regulation which must be found in a previous year or another CFR section.

I suspect you may be right about the CPSC regulations being rather general, and Campy perhaps overinterpreting them. What happens frequently is that affected companies determine what agency personnel are actually involved in the application and enforcement of a given regulation, then contact these agency people to ask for clarification of exactly how the agency interprets and intends to enforce the regulation. Most agencies are responsive to such questions, and will often even issue written interpretations as to whether or not the agency considers an action a company is considering to be sufficient to comply with the regulation. It may be that Italian bureaucrats are less responsive to industry questions, and perhaps Campy were not familiar with how the system works in the US, and failed to seek clarification from the regulators which might have avoided some of the sillier details of component redesign.

In any case, while I don't mind wading through the CFR for pay, like so many lawyers and a fair number of engineers make a living at, it is a sufficient pain in the posterior that I personally doubt I'd make the effort simply to determine if Campy overreacted. But there are at least a couple of attorneys on the list, so maybe one of them wants to research this.

Regards,

Jerry Moos Houston, TX

Tom Dalton <tom_s_dalton@yahoo.com> wrote: Someone brought up the interesting point about lower level groups not having the same features as those normally attributed to CPSC requirements on NR/SR. I'd say it is more accurate to say "later groups," becuase we again saw uncoated wheel guides on Triomphe and Victory brakes, and lip-less ft ders on C-record (though on not Victory as stated). Could it be that CPSC backed off on their regs? Or, it could be that Campy over-reacted to the CPSC requirements in 1978? After all, a lot of other brands retained lip-less ft. ders and uncoated wheel guides, didn't they? I really have to wonder if the CPSC mandate took a far more general form than Campy being told to add specific bits and pieces to the components. I remember hearing that the CPSC requirement was for something very general, like "no sharp protrusions." I have to wonder if the feds stepped in and pointed directly at the brake QR, ft der lip, etc., or if these changes reflect Campy's interpretation of the regs. If so, it would explain why other companies reacted differently, or didn't react.

Also, we should consider which of the changes at the commonly accepted CPSC timeframe of 1978 were truly made to address a new requirement. The often cited "plastic trumpety thingies" on the rear ders are probably not a CPSC thing. They are there to guide the screwdriver to the slot, as in whilst hanging out of a car window trying to get your rider's bike to reach the 13t cog. The curved QR too... that was around before CPSC, in the form of the block lettered curved handle. This goes way back according to The Timeline, and according to Chuck was a common cool-guy mod applied to flat QRs. It could be that Campy simply decided to start curving the road QR levers because the end users were doing it themselves. What really reinforces this idea in my mind is that Campy made these levers for a long time, but at some point added the "open" and "closed" markings on the outside and inside of the curves. Now *that* is almost certainly a CPSC change.

Tom Dalton Bethlehem, PA

Thanks to Chuck and Steven B in Vt.