Danger to human health or safety assessment for ski and snowboard helmets

Last updated: July 4, 2023

Table 3 was first published in July 2020 to consolidate information for regulated parties in an effort to increase openness and transparency regarding Health Canada's evaluation of products that pose a danger to human health or safety. While this entry was added to Table 3 upon initial posting of the table in July 2020, the danger to human health or safety was previously communicated by Health Canada to regulated parties. This assessment does not present new decisions, and is being published for clarity on the decisions made previously.

Legislative background

The purpose of the Canada Consumer Product Safety Act (CCPSA) is to protect the public by addressing or preventing dangers to human health or safety that are posed by consumer products in Canada, including those that circulate within Canada and those that are imported. Any person who manufactures, imports, advertises, sells or tests a consumer product must comply with all applicable requirements of the CCPSA and its regulations. Paragraphs 7(a) and 8(a) of the CCPSA prohibit the manufacture, importation, advertisement or sale of any consumer product that is a "danger to human health or safety". The CCPSA defines the term as follows:

Danger to human health or safety means any unreasonable hazard — existing or potential — that is posed by a consumer product during or as a result of its normal or foreseeable use and that may reasonably be expected to cause the death of an individual exposed to it or have an adverse effect on that individual's health — including an injury — whether or not the death or adverse effect occurs immediately after the exposure to the hazard, and includes any exposure to a consumer product that may reasonably be expected to have a chronic adverse effect on human health.

Scope of affected products

Ski and Snowboard Helmets

Includes:

• Helmets used in non-motorized recreational snow sports
• Full face ski and snowboard helmets
• Women's, men's, unisex and children's sizes

Excludes:

• Helmets used during activities other than skiing or snowboarding, such as ice hockey or bicycle helmets

Hazards of concern

A ski or snowboard helmet with insufficient structural integrity, stability or strap retention may pose a risk of serious head injury when the user suffers an impact from a fall or collision with other skiers, snowboarders, obstacles, or stationary objects.

Incidents^{Footnote 1}

Health Canada is aware of five reports of incidents that occurred between June 20, 2011 and December 31, 2022 involving ski and snowboard helmets in Canada. Of the five reported incidents, one involved a minor bruising injury.

Health Canada is aware of 45 reports of accidental skiing, snowboarding, and tobogganing deaths that occurred between January 1, 1991 and December 31, 2012 in Ontario. According to a report by the Office of the Chief Coroner for the Province of Ontario, of those 45 deaths, 22 were caused by head injury. According to data from National Ski Areas Association, a trade association for most of the alpine resorts in the United States, an average of 38 people died per year while skiing and snowboarding during the 2009-10 to 2018-19 seasons. The majority of these deaths involved collisions with other skiers, the snow surface, or trees.

Danger to human health or safety assessment

Danger to human health or safety considerations

Considerations for a product to pose a potential danger to human health or safety are outlined in Health Canada's Industry Guidance - "Danger to Human Health or Safety" Posed by Consumer Products. The main considerations assessed are:

1. Unreasonable hazard
2. Existing or potential hazard
3. Normal or foreseeable use
4. May reasonably be expected to cause
   1. Death
   2. Adverse effect on health

1. Unreasonable hazard

The consideration of unreasonable hazard includes the following components.

a. Inherent hazard

Ski and snowboard helmets are used to protect the user from injury if they fall or collide with the people, obstacles, and objects while skiing and snowboarding. These sports mostly involve the user going down hills, which results in a potential impact hazard.

b. Severity of hazard

Ski and snowboard helmets that are unstable or that do not absorb foreseeable impacts may not protect the user from an impact hazard. The severity of the injury can range from a minor bruise to a serious head injury or death.

c. Intended and foreseeable users

The intended and reasonably foreseeable users of the ski and snowboard helmets are adults and children that ski or snowboard.

d. Obviousness of hazard

Adults are expected to be more likely than children to recognize the severity of injuries associated with an impact hazard. Ski and snowboard helmets that do not sufficiently protect against an impact hazard may give users a false sense of protection.

e. Social utility

Ski and snowboard helmets protect users from the impact hazard posed by falling or colliding into other skiers, snowboarders, obstacles, or stationary objects.

f. Available alternatives

There are no identified alternative products to serve the intended function of ski and snowboard helmets.

g. Consensus-based safety standards or government regulations

Health Canada is aware of multiple international consensus-based safety standards applicable to ski and snowboard helmets. These standards set out criteria for the impact absorption, the stability of the helmet on the head, and the retention strap strength that address the impact hazard, including the following:

Impact absorption:

• Z263.1-14 | Product | CSA Group clauses 5.8 and 5.9;
• ASTM F2040-18 – Standard Specification for Helmets Used for Recreational Snow Sports – sections 9.1 and 9.2;
• SNELL RS-98 – Standard for Protective Headgear for Use in Recreational Skiing and Snowboarding – section E4; or
• EN 1077:2007 – Helmets for alpine skiers and snowboarders – subclause 4.5

Helmet Stability:

• CSA Z263.1-14 – clause 5.6;
• ASTM F2040-18 – section 10.3;
• SNELL RS-98 – section E2; or
• EN 1077:2007 – subclause 4.7.1

Retention Strap Strength:

• CSA Z263.1-14 – clause 5.7;
• ASTM F2040-18 – section 10.2;
• SNELL RS-98 – section E3; or
• EN 1077:2007 – subclause 4.7.1

There are products available in the Canadian marketplace that appear to conform to the applicable criteria outlined above.

2. Existing or potential hazard

Incident reports from Canada and the United States indicate the presence of an existing or potential impact hazard.

3. Normal or foreseeable use (including foreseeable misuse)

Normal or foreseeable use of a ski or snowboard helmet with weak structural integrity or poor head stability can lead to serious head injury or death in case of falling or colliding with other skiers, snowboarders, obstacles, or stationary objects.

4. May reasonably be expected to cause

a. Death

A user may foreseeably wear a helmet to protect their head while skiing or snowboarding. The user may fall or collide with other skiers, snowboarders, obstacles, or stationary objects during those activities. If the helmet does not absorb the impact or shifts on the user's head, then the impact could result in a serious head injury.

Health Canada is aware of reports of deaths from Canada and the United States that were associated with serious head injury during skiing and snowboarding.

It is therefore reasonable to expect that ski and snowboard helmets that do not conform to the applicable criteria outlined above to address the impact hazard may cause death.

b. Adverse effect on health

The circumstances that may reasonably be expected to cause death may also reasonably be expected to cause adverse effects on health, including:

• Concussion
• Contusions
• Abrasions
• Fracture
• Hematoma
• Internal organ injury
• Laceration

It is therefore reasonable to expect that ski and snowboard helmets that do not conform to the applicable criteria outlined above to address the impact hazard may cause an adverse effect on human health.

If you require additional information regarding this Danger to Human Health or Safety Assessment, please contact a Health Canada Consumer Product Safety Office via email (hc.ccpsa-lcspc.sc@canada.ca) or telephone at 1-866-662-0666 (toll-free within Canada and the United States).