Cycle lanes on pavements are pose a risk to people with impaired vision according to the National Council for the Blind.
They have written to Dublin City Council urging that cycle lanes be restricted to roads.
A submission by Fiona Kelty states that if essential to put a cycle track on a pavement a raised delineator strip must be installed to define the boundary.
Ms Kelty says this would allow people with impaired vision to avoid the cycle lane and prevent white cane users causing an accident by swinging their cane into wheel spokes.
She points out that although it is still the law that all bicycles are fitted with bells to warn pedestrians of their approach, very few are.
Meanwhile the city council say it is currently drawing up a cycle action plan aimed at doubling the number cycling within five years.
A total of €700,000 has been spent on repairs to cycle lanes in the past three months and work is expected to start on the canal cycle routes in the new year.
The council has confirmed that the Dublin Bike scheme will get another 200 bike stands with one third of stations having their capacity increased by 50%.
A report found that demand is particularly heavy in the south east of the city where employment is concentrated.