Interpretation ID: 12072.OGM

Mr. Geoff Smith
709 Glen Cove Road
Vallejo, California 94591

Re: Goal of FMVSS 218 "Motorcycle Helmets"

Dear Mr. Smith:

This is in response to your electronic mail message of June 17, 1996 to John Womack. As Mr. Womack explained in his electronic response, the National Highway Traffic Administration (NHTSA) is responding to your letter by conventional mail.

Your message posed several questions relating to Federal Motor Vehicle Safety Standard No. 218, "Motorcycle Helmets" (Standard 218) that take issue with the agency's position that Standard 218's performance tests ensure that helmets will reduce deaths and injuries to motorcyclists resulting from head impacts. I will repeat your questions below (in italics), followed by the response.

A. Since Standard 218 is only a series of bench test on helmets and does not involve any simulated crash tests, how do you claim that: "Standard 218 sets forth a series of performance tests to ensure that motorcycle helmets will reduce deaths and injuries to motorcyclists resulting from head injuries."????

Answer: The performance requirements of Standard 218 are intended to simulate conditions that may be encountered by a motorcyclist in an actual accident. For example, the impact attenuation requirements found in S5.1 of the Standard, in which a helmet is subject to a perpendicular impact onto a test anvil, are designed to replicate the vertical component of an angular or indirect impact at a much higher speed. As it is unlikely that a helmet would experience a direct perpendicular impact in a real accident, the selection of test criteria designed to simulate an angular impact is an appropriate performance test.

Because Standard 218's performance tests are designed to simulate conditions that may be encountered in a crash and the existenceof the standard requires manufacturers to produce a helmet that will meet test requirements, Standard 218 helps to provide protection in the event of an accident.

B. What is the connection between bench tests and actual crash situations? Do you have some other tests that will make this connection? I don't mean statistics claiming that helmets reduce injuries and deaths, I MEAN REAL, ACTUAL TESTS OF HOW PARTICULAR HELMETS PROTECT THE HUMAN HEAD IN A REAL CRASH????

Answer: As noted above, the performance requirements of Standard 218 are intended to simulate the conditions produced by a real crash. Studies performed by NHTSA contractors and others indicate that the performance tests incorporated in Standard 218 and other similar standards are representative of conditions encountered in real world crashes. NHTSA does not test helmets to any other standard other than Standard 218 and, for obvious reasons, has not considered testing using human subjects.

C. Question No 1:

If you don't have this test(s), how can you claim that Standard 218 will "reduce deaths and injuries to motorcyclists ..."? (Please no statistics, just proven tests).

Answer: As stated above, the performance tests incorporated into Standard 218 simulate conditions that may be encountered in real world crashes. NHTSA therefore believes that Standard 218 protects helmet users by requiring that helmets meet minimum performance requirements.

D. Question No. 2:

And conversely, can helmets INCREASE the risk of death and injuries in some situations?

Answer: While NHTSA is aware of claims by some individuals that helmets can increase the risk of injury in some types of crashes, the agency is not aware of any studies based on actual accident data that establish that helmets increase the risk of death or injury.

I hope that this information is helpful. If you have any questions, please contact me or Otto Matheke of my staff at 202-366-5253.

Sincerely,

John Womack Acting Chief Counsel

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