Interpretation ID: 1984-2.50

TYPE: INTERPRETATION-NHTSA

DATE: AUGUST 7, 1984

FROM: WILLIAM R. WILLEN -- MANAGING ATTORNEY, AMERICAN HONDA MOTOR CO., INC.

TO: FRANK BERNDT -- CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 9/13/84 FROM WILLIAM R. WILLEN, AMERICAN HONDA MOTOR CO., TO FRANK BERNDT, NHTSA; [A26; REDBOOK 3; PART 556]

TEXT: Pursuant to your letter of July 3, 1984 and Part 573.5, we are submitting a Defect and Noncompliance Information Report regarding FMVSS No. 218 as it relates to motor vehicle safety.

1. Name of Manufacturer of Hondaline Helmets:

Bell Helmets, Inc.

Shoei Safety Helmet Corp.

Name of Manufacturer of Hondaline Headsets:

Clarion Corporation of America

Panasonic Industrial Company

Division of Matsushita

Electric Company of America

2. Identification of Helmets Containing the Noncompliance: Mfg. Model Hondaline Helmet Name Model Year Bell Star International Road Race, Hawk 1982 Bell Tourstar Tour Sport, Hawk 1982 Shoei S-12 & S-22 Britestripe, Stag & Hawk 1982 " Interstate, Stag & Hawk 1982 " Custom, Stag & Hawk 1982 " Britestripe, Stag & Hawk 1981 " Interstate, Stag & Hawk 1981 " Custom, Stag & Hawk 1981

Mfg. Model Hondaline Helmet Name Model Year Shoei S-22 & ER-5 Aspencade, Stag & Hawk 1983 " Interstate, Stag & Hawk 1983 " Britestripe, Stag & Hawk 1983 Bell Star International Road Race, Hawk 1983 Bell Tourstar Tour Sport, Hawk 1983 Shoei S-22 & ER-5 Aspencade, Stag & Hawk 1984 " Interstate, Stag & Hawk 1984 " Tour Sport, Stag & Hawk 1984 Shoei ER-5 Modified Super Sport, Hawk 1984

3. Total Number of Helmets Containing the Noncompliance:

All Hondaline helmets which have the headsets installed. However, our records indicate approximately 20,000 headsets have been distributed by American Honda Motor Co., Inc.

4. The Percentage of Helmets Estimated to Contain the Noncompliance:

100% of those helmets which have the headsets installed but not more than 20,000.

5. A Description of the Defect or Noncompliance, Including both a Brief Summary and a Detailed Description, with Graphic Aids as Necessary, of the Nature and Physical Location (if applicable) of the Defect or Noncompliance:

Audio speakers fitted to the interior of motorcycle helmets distributed by American Honda Motor Co., Inc. do not comply with the requirements of FMVSS 218. Section 5.5 of FMVSS 218 states, in pertinent part: "A helmet shall not have any rigid projections inside its shell."

6. In the Case of a Defect, A Chronology of all Principle Events that were the Basis for the Determination that the Defect Related to Motor Vehicle Safety, Including a Summary of all Warranty Claims, Field or Service Reports, and Other Information, with their Dates of Recepit:

Not Applicable.

7. In the Case of a Noncompliance, the Test Results or other Data on the Basis of which the Manufacturer Determined the Existance of the Noncompliance: Late April, 1984 - American Honda Motor Co., Inc., was notified by Shoei of a possible noncompliance as a result of their recent awareness of the size and shape of the eternally mounted headsets.

May 1, 1984 - American Honda Motor Co., Inc. stopped all sales of the headset units and initiated an investigation.

May 17, 1984 - Meeting between American Honda and NHTSA personnel at the Office of Compliance.

June 14, 1984 - Petition to NHTSA for Exemption for InConsequential Noncompliance.

8. A Description of the Manufacturer's Program for Remedying the Noncompliance:

A Petition for Examination for Inconsequential Noncompliance was filed with your office on June 14, 1984.

9. Notices, Bulletins and Other Communication that relate to the Noncompliance: Not Applicable.