Interpretation ID: aiam1500
Vice President-Marketing
Bell Helmets Inc.
2850 East 29th Street
Long Beach
CA 90806;
Dear Mr. Coughlin: This is in reply to your letter of May 1, 1974, concerning th requirements of Standard No. 218, *Motorcycle Helmets*. You mentioned that Bell is producing some helmets to the Snell standard 'irrespective of the DOT standard,' and you enclosed the labels Bell is using to allow the consumer to differentiate the helmets produced to the Snell standard. The labels you enclosed contain the following notice:; >>>*IMPORTANT*: THIS HELMET IS MANUFACTURED FOR RACING AND OTHER HIG PERFORMANCE USES ONLY, AND IS NOT REGULATED BY THE U.S. DEPT. OF TRANSPORTATION. IT IS NOT FOR USE ON PUBLIC STREETS, ROADS AND HIGHWAYS.<<<; We do not consider this notice acceptable. We believe that the phrase '...AND OTHER HIGH PERFORMANCE USES ONLY...,' would mislead the consumer into thinking that a helmet with this notice is safer for use on public roads than a helmet produced to Standard 218. Accordingly, the phrase '...and other high performance uses only...' should not be used to describe the purpose of helmets produced to the Snell standard. Instead, we suggest that the following language be inserted: '...and similar off- road sports only...'.; You also ask how to determine which helmets you manufacture qualify a 'fitting' the size C headform. Any 'fit-all' or other helmets that are designed to fit a range of head sizes that includes the approximate dimensions of the size C headform must meet the requirements of Standard 218. A helmet is considered not to fit a size C headform only if it is clearly intended by its manufacturer to be used only by persons whose heads are either larger or smaller than the size C headform.; Yours truly, Richard B. Dyson, Assistant Chief Counsel