see attachments for further correspondance 27-Mar-2014 
Jim Hart January 9, 2014 General Manager, Toronto Parks, Forestry and Recreation
Here is a copy of the “special helmets issue” of the Dufferin Grove Park Newsletter for January 2014. It raises a number of points that I hope you will consider now that the outdoor rink season is in full swing:
1. Although the city specifically requires CSA-certified hockey helmets for children under 6 and for shinny hockey players, it now seems clear that the CSA hockey helmet doesn’t do what mainly worries people – prevent concussions – any more than other helmets do 2. Injury rates are vanishingly small for shinny players, with or without helmets 3. The City’s helmet rules are reducing the number of skaters, without a balancing benefit.
In addition, it may be that the skating and rinks policy has made the City legally vulnerable in two ways:
1. The City’s insistence on only Canadian-certified helmets may be a violation of the FTA 2. After nine years of this policy, noncompliance by shinny hockey players continues to rise citywide. The city’s inability to enforce its own policy increases the likelihood of claims against the city, much more than “recommendations,” such as your Division uses for skiing and snowboarding drop-ins.
I hope that consideration of the points in this special helmets issue will contribute to a revisiting of the helmet rules now, but with a different procedure than before. Instead of a staff decision made at a closed meeting at City Hall, please welcome the wide-ranging rink-user input that was missing the first time. This is issue is of concern to many rink users. The newsletter has fairly wide circulation and I have written in it that I plan to send you a copy and report back on your response. I hope that this account makes sense to you, and look forward to your comments.
General manager Jim Hart's response to our helmet questions: "go away!"
Mr. Jim Hart Feb.1, 2014 General Manager Parks, Forestry and Recreation City of Toronto
It would be best to separate the two helmet issues that I have recently analyzed. In reference to the City of Toronto's requirement for children under six to wear CSA-certified hockey helmets for pleasure-skating, you wrote that "numerous municipalities adhere to the national standard."
The City of Toronto helmet policy for little kids who are pleasure-skating at outdoor rinks is not a national standard. Moreover, it is an anomaly in Canada -- almost no outdoor rinks in Canadian cities have this rule. Of the 9 cities I checked with, comprising 1926 outdoor rinks, only the City of Toronto (51 outdoor rinks), Mississauga (3) and Halifax (1) require anyone to wear a helmet for outdoor pleasure-skating. That means, 55 outdoor rinks require it and 1871 (supervised and unsupervised) do not. Harbourfront, the most popular pleasure-skating rink in Toronto, does not require it either.
The U.S. Consumer Product Safety Commission (CPSC) publishes a hockey helmet definition that throws some light on this question. Their website says that hockey helmets are designated as “Team sport helmets...designed to protect against multiple head impacts typically occurring in the sport (e.g., ball, puck, or stick impacts; player contact; etc.), and, generally, can continue to be used after such impacts.” There is no certified pleasure-skating helmet category in either Canada or the U.S., so the CPSC recommends certified bike helmets for pleasure-skating.
Requiring families to buy hockey helmets for pleasure-skating, in addition to the bike helmets most families already have, imposes an unwarranted economic hardship, as well as a disincentive for penalized families to return to the rinks. We've seen this too often -- that's why we're trying to bring it to your attention.
Your letter also refers to "research and information" backing up the City of Toronto policy. I have asked for such documentation from rink management across the country, including from your staff, and have not been sent any. At a national child-and-youth injury conference last November in Montreal, the speakers on the subject said there are almost no data. If your staff have such documentation, could they please send it?
Your letter ends with the assurance that staff will review my information. Could you be more specific?
The general manager's response: NONE
Attachments to document: Correspondance with Jim Hart 2014