Mr. Richard J. Quigley
5886-b Fernflat Road
Aptos, CA 95003

Dear Mr. Quigley:

This responds to your request for reconsideration of our July 15, 1994 interpretation letter on Standard No. 218, Motorcycle helmets. In that letter, we stated that a drawing you provided would not meet the requirement in S5.6.1(e) of the standard that motorcycle helmets be labeled with the symbol DOT. You enclosed a new drawing and ask whether it meets S5.6.1(e). The answer is no.

The new version of the drawing consists of three figures that you believe constitute the symbol "DOT." Your new drawing continues to incorporate a corporate logo in lieu of the letter "O." As explained in our July 15, 1994 letter, because the symbol DOT constitutes the manufacturer's certification that the helmet conforms to Standard No. 218, there must be no ambiguity in the symbol. Using the corporate logo in lieu of the letter "O" introduces ambiguity as to whether the manufacturer has certified the helmet. Thus, the new version of the drawing you provided does not meet S5.6.1(e) of Standard No. 218.

I hope this answers your question.

Sincerely,

John Womack Acting Chief Counsel

ref:218 d:8/18/94