If you are basing on totally detached statistics, maybe..
But what's obviously missing is context. Safety is all about context. Walking shouldn't require protection until excessive risk is added to it, like walking on ice or across a busy intersection.
The moment that risk is added, it needs to be balanced with safety. Helmets might be an effective safety measure, but they are situationally inconvenient for pedestrians; and rely on too much behavioral discipline.
But what's obviously missing is context. Safety is all about context. Walking shouldn't require protection until excessive risk is added to it, like walking on ice or across a busy intersection.
The moment that risk is added, it needs to be balanced with safety. Helmets might be an effective safety measure, but they are situationally inconvenient for pedestrians; and rely on too much behavioral discipline.