Interpretation ID: aiam2174
Vice President
Rol'on America
Inc.
Melbourne
FL 32901;
Dear Mr. Coughlin: This is in response to your letter of December 10, 1975, regarding th applicability of existing Federal regulations to the manufacture of 'Helmate.'; At the present time, there is no regulation pertaining directly to th type of helmet accessory your corporation produces. The general regulation concerning motorcycle helmets is 49 CFR S 571.218, Motor Vehicle Safety Standard No. 218, *Motorcycle Helmets*. This standard establishes minimum performance requirements for helmets designed for use by motorcyclists and other motor vehicle users.; If a manufacturer, distributor, dealer, or motor vehicle repai business were to install 'Helmates' on helmets, the helmets would have to remain in conformity with the requirements of Standard 218. However, persons other than manufacturers, distributors, dealers, and repair businesses may modify products, after purchase by a user, without regard to the requirements of a Federal safety regulation. Thus, if 'Helmate' is mounted on the helmet by an ordinary consumer, safety Standard 218 is inapplicable.; There is some question as to whether motorcycle helmets will still mee the performance requirements of Standard 218, after the 3/8 inch hole required to mount the 'Helmate' is drilled. If it becomes apparent that installing 'Helmate' type helmet accessories causes the performance level of helmets to drop below the requirements of Standard 218, the NHTSA might find it necessary to enact regulations to rectify the situation. Our main concern is to assure that motorcycle helmets afford riders the protection and safety needed.; If I can be of any further assistance, please feel free to write. Yours truly, Richard B. Dyson, Assistant Chief Counsel