As reported back in November, changes are being made to the rules for Isle of Man TT racers, including the requirement to wear certified Personal Protective Equipment (PPE), which means a helmet that’s listed on the FIM Racing Homologation Programme, and CE-certified gloves, boots and leathers.
All riding kit sold in the UK (and Europe) must be certified as PPE. That’s been the case since 2018, and you can see Regulation 2016/425 and the Personal Protective Equipment (Enforcement) Regulations here. But what does it mean?
In brief, gloves and boots have long been tested, but it’s more recently that jackets, trousers and suits have had to be certified. You can read more about what the labels in motorcycle kit mean in this article, and while racers will have to be in leathers that carry either a CE or UKCA label in 2022, the message is the same; it must be PPE.
As ALL motorcycle kit anyone buys must, by law, be certified as PPE, you wouldn’t expect this to be much of a problem; I’ve been reporting on the legislative changes since 2016, and saw the big guns like RST meeting their obligations to the safety of riders very quickly, as well as even small family businesses like the excellent Hood Jeans.
But still, there are companies – predominantly, but not exclusively those importing direct from overseas – that are ignoring the law and selling riders uncertified kit that’s not been proven to be safe. Our recent investigation into leathers sold via Amazon revealed fake armour that could be potentially fatal in a crash – check it out here.
There are also some issues with made-to-measure kit; while certification is entirely possible – BKS for instance has long been tested – there are still some brands that aren’t going through the process. It can be a substantial investment initially, but with careful planning there’s no real reason not to comply with the law.
“I would be interested to know how the organisers are going to check that leathers, in particular, are properly certified,” said Brian Sansom, managing director of BKS.
“There are some good leather suits out there but they continue to be sold without any certification, which makes a mockery of the brands – like BKS – that have been testing properly for safety since 1994. Equally, there are some that are considered ‘good’, but are actually quite poorly made. It’s going to be vital that the organisers enforce these new regulations and physically check the suits for the correct labels as, under these new rules, if the label isn’t there (and backed-up by a legitimate certificate of conformity), the racers shouldn’t be allowed out.
“There will also be suits that have been tested to the so-called highest level of the new industry standard (EN 17092) on the grid, but how many riders understand just how much less protection could be offered compared to suits tested to EN 13595? If the aim of the TT organisers is to ensure riders wear suits fit for purpose, it surely matters that a crash could see someone sliding down the road at up to 180mph at the TT Races?
“To keep it simple and transparent, and to gain customer trust, each manufacturer of leather suits could publish the results of their technical files to demonstrate what each suit was capable of. But more than that the current standard has failed manufacturers of proper high performance kit; I’d want to see additional abrasion testing to the much tougher EN 13595 classification to show this, like we do: https://bksleather.co.uk/information/conformity”
Checking that leathers are certified should be a simple matter of looking for the correct label
I asked Rob Temple of the Isle of Man government what changes racers can expect for 2022; “These requirements are really introduced by ACU Events as they are the race organiser,” he told me. “The Department, as the promoter of the event, has highlighted these changes to bring awareness around them.
“These new regulations make a number of alterations to competitor PPE requirements. Starting with the helmets, all worn must now be listed on the FIM Racing Homologation Programme, and have the FIM hologram and QR code sewn into the chin strap. The FIM tests are specifically designed for racing, with tougher thresholds to be passed in comparison to the ECE 22.06 standard used to sell helmets to members of the public.
“When it comes to leathers, gloves and boots, all equipment must now be CE-certified, with leathers conforming to EN 17092. Gloves must conform to EN 13594, with a minimum level of 1-KP (knuckle protection). Boots must also conform to CE standards, meeting standard EN 13634. All of this is to bring the PPE regulations in line with that of the regulatory authorities – without these changes, competitors on the TT Course could potentially ride in kit that would be so inferior it would not be sold in your local bike shop.
“This work has formed part of the wider Safety Risk Management project. When we looked closely at this, it was clear that our previous requirements for riding gear were below what they should be for the TT Course. The TT is inherently dangerous, and we will never be able to make racing around here perfectly safe, but what we can do is introduce measures that ensure competitors wear the best possible equipment to protect themselves in an accident.
“Checks will be carried out by a team of Technical Officials who will receive expert training on how to identify suitable kit. After the initial pre-event checks, random spot checks will be carried out throughout the event.”
It’s not yet clear whether leathers must be certified to the highest level under EN 17092 – AAA – but it’s unlikely that any racers will go for the lower protection of AA or even, potentially, A.
“As a minimum only EN 17092-2 Class AAA – the highest level specified by the standard – is suitable and sufficient for competition use,” says PPE expert Paul Varnsverry, technical director of PVA-PPE (UK) Limited. “The lower performance levels in the standard offer suitable protection only at lower road speeds. Riders wanting even higher levels of protection on road or track should look to manufacturers of EN 13595-conforming racewear.”
EN 13595 was the tougher standard to which garments could be tested before EN 17092 was introduced, and is still – for now – acceptable in support of certification of PPE. As such, we’d expect it to be recognised by the TT’s Technical Officials as a suitable classification, but the current regulations document doesn’t include it. We’re waiting on clarification.
Note that under the regulations, sidecar competitors are not required to wear certified leathers. The regulations can be found here.
The TT rules make sense when you remember that it’s a legal requirement for all riding kit sold to be certified as PPE; the organisers have to ensure they’ve taken sufficient steps to keep riders as safe as possible. But there is no legal obligation for a typical road rider – outside of competition – to wear anything except a helmet in the UK.
Of course, I’d suggest you’re a fool not to wear some form of protection, but the certification of riding kit simply gives you – the buyer – some level of confidence that what you’re spending your money on will, to some extent, be of some potential use if the worst happens.
If you were involved in an accident that was caused by someone else, and you weren’t wearing any proper riding kit, there could be a reduction in your compensation due to ‘contributory negligence’, but you can read more about that here.
Basically, you don’t have to dump your old leathers, but if you’re buying any new kit now, it should – by law – be tested and certified. Think carefully before trusting anyone who tells you otherwise.
At the time of writing, there were 28 approved helmets on the FIM homologation site, though this is globally, and not all might be readily available in different regions
The new standard of ECE 22.06 means helmets are tested a lot more thoroughly than under ECE 22.05, but it also covers open-face and flip-front lids. While presumably the TT rules could have stated ‘full-face helmets only’, the FIM homologation does mean the approved helmets have been thoroughly and independently tested at a designated laboratory; this is far more than a simple sticker.
“Race teams have responded very positively,” Rob Temple tells me. “We have had a few competitors get in touch, but this has been queries clarifying what kit is needed/acceptable as opposed to a disagreement to their introduction.”
Peter Hickman told BikeSocial that the changes are valuable. Photo by Pacemaker Press (Stephen Davison)
“The changes are a good thing, and show that the TT is really doing what it can to improve safety for riders,” says TT lap record holder Peter Hickman. “The changes to kit won’t affect me personally as all my kit was already at the level that is now required, which I’m sure most of the riders were the same too. But still, it’s a good thing to improve safety for everyone.”
Peter’s sponsored by Weise, but what about some of the privateers? I also spoke to Dave Hewson; “It's good to see the organisers are looking at ways to try and improve the safety at the event,” he told me. “We all know there are risks involved, so it seems sensible to me to try to confirm that we're all riding in safe kit, although I don't think any TT racers would ride in cheap kit nowadays!
“Some of the rules have brought about a few issues though; I have a set of top-quality AM made-to-measure leathers that are a few years old now (and luckily untested in that time), and as they are very high quality they’re still perfectly good, but I have to get a new set as they pre-date the CE approval. I don't mind this as I was looking to get an airbag suit so it just means I now have to update.
“I've always had two helmets, just in case of a silly slip-off, or if one is very sweaty. One had timed out as it was five years-old so I was going to have to replace it, but now I need to buy one – or possibly two – more expensive helmets to get the FIM homologation status. As the manufacturers only send certain options to be approved by the FIM they’re generally more pricey.
“Now don't get me wrong, I value my head and its contents, but a £500 helmet that’s 5-star SHARP tested, ACU approved and very good quality is no longer deemed enough and I have to get the £800 version instead. There are a few cheaper options from some manufacturers, but most aren't available in the UK and if I bought one in from abroad it wouldn't be ACU legal for any other races. So it looks like I'm going expensive. Still, I was lucky that I didn't bother buying any kit last year; at least I've not bought two Arais I can't use, like a mate of mine.”
Privateer Dave Hewson also thinks the rule changes are a sensible move, but is worried that some riders could be faced with expenses they weren’t prepared for
Ultimately, the majority of off-the-shelf motorcycle brands in the UK already offer certified PPE with the correct labelling in place. Anyone attempting to sell anything else is, quite simply, breaking the law.
What remains to be seen at the TT is how scrutineers check the kit that racers take to the course in. Realistically, it’s as simple as finding a CE or UKCA label, then the only way any will slip through is if manufacturers fake it, which is a huge news story.
On the other hand, if we do see kit out on the grid this year that hasn’t been certified simply due to the rules not being enforced, that would be a big disappointment, even given the lack of action taken by some local Trading Standards in clamping down on those who continue to flout the law when selling to the average road rider like you and me.
Of course, it also remains to be seen how the leathers of some racers are labelled, given they may have a sponsor’s name on the outside, but actually be made by a company that hasn’t certified it’s garments previously.
You can download the PPE regulations for the 2022 TT here, but it’s interesting to see the phrase ‘Dispensation may be granted at the discretion of the Race Organiser.’ If uncertified gear is allowed out on the circuit, it could upset some of the manufacturers that have invested a lot of time, energy and money into complying with UK law. It could also be a tricky situation for the organisers if someone were to be injured, but this wording may well be in place simply to ensure that products correctly certified to the tougher EN 13595 are rightly allowed through.
“From a team and competitor point of view, this is all done to protect them whilst competing on the TT course,” says Rob Temple of the IoM government. “We will educate them the best we can, and get them to think about whether wearing leathers that they may have had for 10 years and crashed in a dozen times are really the ideal piece of kit to use. If they want to use that kit on short circuits, then fine, but they need to bring the best kit to the TT.
“There may be some very experienced and skilled manufacturers out there whose work may not meet these requirements simply because of the need to be CE certified. However, there is equally some poor-quality kit available, especially with the rise in online markets.
“It is easy for someone to say they make a great set of leathers but, if tested, some of those would fall apart as soon as any strain is put on them.
“With the introduction of these standards, we as organisers – and the competitors – have some comfort in knowing the kit has been tested independently to a suitable level.”