The NCAA has made significant progress in dealing with catastrophic
injuries since the early 1900s when deaths were common in college
football.38 From 2004 to 2009, for example, “there were no fatalities from
direct catastrophic injuries in NCAA football.”39 However, “[n]ationwide,
across all sports levels, there have been more deaths from heat stroke in the
2005–2009 time block than any other five-year block during the past 35
years.”40 The NCAA, in turn, reports that, “[t]he overall injury rate in
NCAA football is 8.1 injuries per 1,000 athlete exposures (games and
practices combined)” and that “[t]here were more than 41,000 injuries and
25 million athlete exposures from 2004 to 2009.”41 Of those injuries 7.4%
were concussions and 4.3% were head, face, and neck injuries