I am sorely distressed by the recent action of the Consumer Product Safety Commission concerning the ban/recall of three-wheeled all-terrain vehicles {Dec. 31}. Citing some 900 ATV-related deaths since 1982, many among children, as the principal reason for the ban, the CPSC has truly overstepped and abused its lines of authority by means of faulty reasoning. I will clarify at this point that I have no interest in the ATV industry, nor do I own or operate an ATV.

The three-wheeled ATVs are motorized tricycles. Instability of the vehicle is inherent in the design. Adult owners of ATVs accept personal responsibility for the proper and safe use of these vehicles at the time of purchase, much as they do when buying a car or other inherently hazardous manufactured items. Therefore, injury to the owner due to inappropriate or unsafe use of the vehicle is the owner's responsibility, as is liability for incurred expenses.

The CPSC citation of deaths among "children" (undefined by age) is used as an emotional tool to garner support of the general public for the ban of three-wheeled ATVs. In fact, responsibility for the deaths of "children" fall directly upon adults who have abrogated their parental duties for the care and safety of their children. Most rational people would accept the permitting of children under 16 to operate a three-wheeled ATV as grossly negligent parental behavior. To penalize ATV dealers and manufacturers for parental negligence is a gross abuse of CPSC authority and certainly not a rational approach to the perceived ATV problem.

An analogous situation would be the banning of automobiles because parents permitted underage children to operate them. In this case, I believe parents would suffer financial liability and legal sanctions for their actions, not the auto manufacturers and dealers.

T. T. PALMER Germantown