Interpretation ID: aiam2139
Vice President
American Sports Co. Inc.
P. O. Box 5603
2970 East Maria Street
Compton
CA 90221;
Dear Mr. Webber: This is in response to your request of November 21, 1975, for a opinion regarding requirements for certifying universal sized helmets pursuant to Federal Motor Vehicle Safety Standard No. 218.; The requirements of Standard No. 218, *Motorcycle Helmets*, apply t helmets that fit headform size C. This includes the case where, by means of an adjusting mechanism supplied by the manufacturer for the purpose of permitting adjustment to headform size C, the helmet can readily be made to fit headform size C. Thus, any helmet that the manufacturer intends for use by persons with heads in the size C range must meet the requirements of the standard, including the requirement to affix the label required by section 5.6.1 of the standard.; The 'universal' helmet described in your letter seems to fall withi these guidelines in that it is intended to fit, *inter* *alia*, the size C headform. Therefore, notwithstanding the fact that it may also be adjusted to fit other size headforms, it should meet the requirements of FMVSS No. 218, including the labeling requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel