Interpretation ID: aiam1522
American Safety Equipment Corp.
16055 Ventura Boulevard
Encino
CA 91316;
Dear Mr. Kidwell: This is in reply to your letter of May 29, 1974, concerning th labeling requirements of Standard No. 218, *Motorcycle Helmets*. You ask for our 'review, comments, interpretation, recommendations, and opinions' on two test reports you had done with respect to the placement of the DOT symbol and its attachment on helmets manufactured to the standard's requirements.; The National Highway Traffic Safety Administration does not provid approval of any item of motor vehicle equipment as conforming to any motor vehicle safety standard. Each item is required to conform, and each manufacturer must determine, by methods within his discretion, whether his product conforms to a standard. With respect to the method of affixing the DOT label to the helmet, any methods that are reasonably designed to provide a label that is clearly legible for the expected life of the helmet would be satisfactory.; We would like to point out, however, that from the photograph an drawings you enclosed, it appears that the DOT symbol on your helmet is partially obscured by a goggle snap and its related material. We do not consider this obscuring of the DOT symbol to conform to the intent of the standard. Accordingly, we recommend that you either reduce the length of the snap and its related material or raise the symbol to attain complete visibility.; Yours truly, Richard B. Dyson, Assistant Chief Counsel