Interpretation ID: aiam1915
Public Information Officer & Legislative Liaison
Oklahoma Highway Safety Program
1118 United Founders Tower
Oklahoma City
OK 73112;
Dear Ms. Holliday: Pursuant to your conversation of May 9, 1975, with John Womack, I a enclosing a list of companies who have registered with us as manufacturers of motorcycle helmets. The list is subject to change as manufacturers enter and leave the business, and does not include manufacturers who have neglected to follow our identification requirements. If your agency intends to follow this list, you should take care to keep it current.; The list is not an 'approved' list, but rather a list of manufacturer who are certifying the compliance of their products to Federal standards. Under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq.*), each person who manufactures a motor vehicle or item of motor vehicle equipment to which a Federal safety standard applies must manufacture his product in accordance with the standard. Our motorcycle helmet standard (Standard No. 218) went into effect on March 1, 1974, with respect to the medium-sized helmets that constitute about 50 percent of helmets sold. All manufacturers on the list who make helmets in that size range must therefore meet the standard and affix a label to the helmet certifying its compliance. To regulate these helmets at the State level, it would be easiest to specify that they be certified in accordance with Standard No. 218.; The balance of the helmet population, however, is not presently subjec to Federal Standards. The National Highway Traffic Safety Administration is well along in rulemaking to cover all helmets, but it has not yet issued a final standard. Until a Federal standard is issued, all helmets outside the regulated size range may be sold without certification. The reference in Oklahoma's bill to Federal standards would therefore impose requirements on only a portion of the helmets in the State.; Before the issuance of the Federal standard, the dominant industr standard was Standard No. Z-90.1- 1966 *Protective Headgear for Vehicular Users*, adopted by the American National Standards Institute, 1430 Broadway, New York, New York. In addition to the Z-90 standard, the Snell Standard, a more rigorous standard, has been administered by the Snell Memorial Foundation, Inc., 761 Laurel Drive, Sacramento, California. Most helmets made by reputable manufacturers in the years immediately before the effective date of the Federal standard on March 1, 1974, were certified as conforming either to Z-90 or to Snell and labeled to that effect. With respect to the helmet population now in use, it would therefore be possible for the Administrator to specify helmets that are certified as conforming to either ANSI Standard Z-90, the Snell Foundation specifications, or the Federal standard.; Sincerely, James C. Schultz, Chief Counsel