Interpretation ID: 1983-1.25

TYPE: INTERPRETATION-NHTSA

DATE: 03/11/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Ms. Susan Reilly -- Reilly Manufacturing

TITLE: FMVSS INTERPRETATION

TEXT:

Ms. Susan Reilly Reilly Manufacturing P.O. Box 51 Mt. Vernon, Iowa 52314

Dear Ms. Reilly:

This responds to your letter asking whether a motorcycle helmet fastener your company produces, called "Alpha Clip," complies with Federal requirements.

By way of background information, this agency does not give approvals of vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to ensure that its vehicles or equipment comply with applicable standards.

Safety Standard No. 218, Motorcycle Helmets, includes various minimum performance requirements for motorcycle helmets. The only requirement directly relevant to your fastener is the retention test, which is set forth at section S5.3. The letter you enclosed from the University of Southern California suggests that the clip passes that test.

I would note that Standard No. 218 only applies to new motorcycle helmets and not to replacement equipment for motorcycle helmets. Thus, unless your clip was sold as part of a new motorcycle helmet, the requirements of Standard No. 218 would not be directly applicable. (Please note, however, that the agency discourages helmet users from modifying their helmets. Section S5.6.1 of the standard requires that the following instruction be placed on helmets: "Make no modifications..")

I would also note that should a safety-related defect be discovered in your device, whether by the agency or by yourself, you as the manufacturer would be required under sections 151 et seq. of the Act to notify owners, purchasers, and dealers and provide a remedy for the defect. These provisions apply regardless of whether the device is covered by a safety standard. A copy of the Act is enclosed.

Sincerely

Original signed by Frank Berndt, Chief Counsel

Reilly Manufacturing P.O. Box 51 Mt. Vernon, IA 52314 (319) 895-8479

Mr. Frank Berndt 400 Seventh St. SW Washington, DC 20590

Dear Mr. Berndt:

At the advice of Mr. Gilky of the NHTSA Safety Compliance Office I am writing for your judgement as to the compliance of our Motorcycle Helmet Fastener to Federal requirements. We believe the "Alpha Clip" meets all requirements and is a safe and reliable product. I have included the clip, packaged for mail order, for your review. As of now, we market only the clip, not O-rings or helmets, and the consumer is responsible for installation.

I have also included a copy of a (unreadable) of U.S.C.. He then tested our fastener as a public service. Since receiving his letter we've added a plastic vinyl cap fitted to the hook, creating an interference fit.

Other recent information is as follows: 1 The hook is designed to fold in within itself when tension is released (we are in the process of moving the design patented)

2. Made of nickel plated (unreadable) steelwire of .142 +.005 - .000 inches dia. Length .900 I .020 in., width l.l90 I .020 in., width .702 I .010 Weight .

3. Has a deformation point of 600 pounds tensile

4. Does not protrude from the helmet

5. Installs directly to helmet strap - nothing is removed from the helmet.

I have also sent a clip and information to Mr. B. Roven, Coordinator of Motorcycle Safety for the Iowa DOT, if you wish to contact him for comment. Please let us know your judgement on our clips compliance as soon as possible.

Thank you for your time and cooperation.

Sincerely, Susan Reilly

June 3, 1983

Mr. Steve Reilly RR 2 Mount Vernon, IA 52314

Dear Steve,

Thank you for sending your new retention clip to us for evaluation. Professor Hurt asked me to run some tests on it and give you some comments.

The beauty of your clip design is that it could be retrofitted to most helmets providing a much more convenient method of fastening than conventional D-rings.

The first test I did was to use your clip on a complete helmet for the actual DOT retention test. Enclosed is that portion of the standard. I used an Electro E3 which has an extremely strong retention system. This choice of helmets made your part the weak link. With the Reilly clip in place, the test result was 0.54 inch elongation @ 300 lbs., about normal for an Electro. The clip showed no deformation at this load.

Taking the entire system up in loading, the strap began to slip at 640 lbs. when the unwelded ends of the clip deformed. This load at failure is typical for many helmets that pass the DOT requirements.

The problem that your design has is answered by many industrial safety codes that require a safety snap latch on all hooks. This spring-loaded device swings inward when engaging the hook and then returns to block the throat of the hook creating a closed loop. Bell Tourlite bicycle helmets use a somewhat similar hook with a safety latch made by Fastex. A less satisfactory solution would be to close up the radius of the hook bend to create an interference fit onto the D-ring.

Please feel free to send out any future revisions to us for evaluation. As with the better mousetrap, the world is ready for a better helmet retention strap fastener.

Sincerely, Original signed by David Thom, Laboratory Technician