Interpretation ID: 1984-2.6

TYPE: INTERPRETATION-NHTSA

DATE: 06/06/84

FROM: AUTHOR UNAVAILABLE; Z. Taylor Vinson; NHTSA

TO: Memorandum - Interpretations file

TITLE: FMVSS INTERPRETATION

TEXT:

Subject: Standard No. 218 - "Rigid Projection"

From: Z. Taylor Vinson Senior Staff Attorney

To: Interpretations File

Paragraph S5.5 Projections of Motor Vehicle Safety Standard No. 218 states in pertinent part: "A helmet shall not have any rigid projections inside its shell." The term "rigid projections" does not appear to have been interpreted up to now.

The Office of Vehicle Safety Compliance has brought to our attention a type of helmet which has a lever inside the helmet, below the shield, by which the visor shield is released to open. It has also procured another type of helmet which comes equipped with a headset. Inside the helmet are two speakers, made of hard rubber, which fasten into the shell. Each speaker is roughly an inch in height. Its shape is odd, basically eliptical, and about 1 1/2 inches at its longest point. OVSC has asked whether the lever and the speakers are "rigid projections" prohibited by the standard.

Assuming that the lever is made of either plastic or hard rubber, it would appear to be "rigid" in the sense of "unyielding," as are the speakers. The speakers do not lie flush with the shell or liner but just out an inch from their mounting points, and would appear to "project" in the normally understood sense of the word. The lever presumably also does not lie flush in the inner chin area of the helmet. Rigid projections are allowed on the exterior of a helmet provided that "they shall not protrude more than .19 inch" and "are limited to those required for operation of essential accessories." But neither the lever nor speakers could meet both criteria were they externally mounted, leading a fortiori to the conclusion that, internally mounted, they are prohibited.

OVSC says that motorcycle helmet headsets are illegal in at least 5 states.