Interpretation ID: aiam3921
Managing Director
Pacific Helmets (N.Z.) Ltd.
P.O. Box 866
Wanganui
New Zealand;
Dear Mr. Bennett: This responds to your inquiry about ventilation holes in the front o motorcycle helmets currently being manufactured by other companies. You give the location of these ventilation holes as being between the reference plane and the test line, one inch above that plane, and ask whether these holes are permitted under Standard No. 218, *Motorcycle Helmets*.; Standard No. 218 requires, in paragraph S5.4, that: 'Each helmet shal have a protective surface of continuous contour at all points on or above the test line described in S6.1.3.' In paragraph S6.1.3, this test line is required to be drawn one inch above the reference plane in the frontal portion of the helmet. The continuous contour requirement is important because both the impact attenuation and penetration tests in the standard are performed on the helmet area above the test line. This helmet test area is the shaded area illustrated in Figure 2 of Standard No. 218. Therefore, any ventilation holes located between the reference plane and the test line in the front portion of a helmet would be permitted under the standard, as long as they are not located on or above the test line.; Sincerely, Jeffrey R. Miller, Chief Counsel