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DOT Motorcycle Helmet Label
Requirements Change
U.S. DOT Proposes Changes to Motorcycle Helmet
Labeling Requirements
The U.S. National Highway Traffic Safety Administration
(NHTSA) has proposed a change in the
Federal Motor Vehicle Safety Standard (FMVSS) No. 218,
which addresses motorcycle helmet safety standards in
the U.S.A.
According to NHTSA, "The purpose of FMVSS No. 218 is to
reduce deaths and injuries to motorcyclists and other
motor vehicle users resulting from head impacts.
To do so, the standard establishes minimum performance
requirements for helmets.
These requirements include three performance tests: (1)
an impact attenuation test; (2) a penetration test; and
(3) a retention system test; as well as various labeling
requirements."
One of the proposed changes addresses the methods used
to add the familiar "DOT" label on motorcycle helmets
sold in the U.S.
Currently, just about anyone can place a label marked
"DOT" on the back of a helmet, but this has caused
confusion in the marketplace and for local law
enforcement because there is no standard DOT label
requirement.
The current requirements are very limited. "Aside
from the size, location, and contrasting color, the
configuration of the symbol is not specified", according
to NHTSA.
"Motorcycle helmet manufacturers are required to affix
the certifying “DOT” symbol to the outer surface of the
helmet. The color of the symbol’s lettering must
contrast with the background.
The “DOT” letters must be at least 3/8 inch (1 cm) high,
centered laterally with the horizontal centerline of the
symbol located a minimum of 1 1/8 inches (2.9 cm) and a
maximum of 1 3/8 inches (3.5 cm) from the bottom edge of
the posterior portion of the helmet."
The Department of Transportation says that the proposed
amendment "would help
realize the full potential of compliant helmets by
aiding state and local law enforcement officials in
enforcing state helmet use laws, thereby increasing the
percentage of motorcycle riders wearing helmets
compliant with FMVSS No. 218."
How a standardized DOT helmet label might increase
helmet usage is unclear, since many states have
eliminated their mandatory helmet use laws.
It is also proposed that FMVSS 218 be amended to "aid NHTSA in enforcing the
standard by specifying a quasi-static load application
rate for the helmet retention system".
Other amendments include revising the
impact attenuation test by "specifying test velocity and
tolerance limits and removing the drop height
requirement; providing tolerances for the helmet
conditioning specifications" and "revising requirements
related to size labeling and location of the DOT symbol;
correcting
figures 7 and 8 in the Standard; and updating the
reference in S7.1.9 to SAE recommended practice J211."
For reference, the following information is from various
NHTSA/DOT public regulations and documents:
NHTSA DOT Motorcycle Helmet Impact Attenuation Test
The impact attenuation test is "designed to ensure that
helmets retain structural integrity and attenuate impact
energy during a variety of crash scenarios.
The test measures acceleration imparted to an
instrumented test headform on which a complete helmet is
mounted. The helmet/headform combination is
dropped in a guided free fall upon either a fixed
hemispherical anvil or a fixed flat anvil.
DOT Motorcycle Helmet Penetration Test
The penetration test simulates a head impact with a
piercing object. This test is conducted by
dropping a penetration test striker in guided free fall,
with its axis aligned vertically, onto the outer surface
of the complete helmet when mounted on a headform.
DOT Motorcycle Helmet Retention Test
The retention system test is a test designed to help
ensure the helmet remains securely fastened to the
rider’s head. It is conducted by applying a
tensile load to the retention assembly.
Helmet Conditioning
For each test, the helmet is conditioned in one of four
different ways prior to testing.
These include:
-
An ambient condition;
-
A low temperature
condition;
-
A high temperature
condition; and
-
A water immersion
condition.
DOT Motorcycle Helmet Labeling Requirements
Labeling requirements are also set forth in Standard No.
218. These require that the manufacturer label
each helmet permanently and legibly with the
manufacturer’s name or identification, precise model
designation, size, month and year of manufacture, and
instructions to the purchaser.
The manufacturer must permanently label each helmet with
the “DOT” symbol, which constitutes the manufacturer’s
certification that the helmet conforms to the applicable
FMVSSs. Standard No. 218 also sets forth the
requirements and acceptable locations of these labels.
(The proposed changes address) several issues relating
to the enforceability of state mandatory helmet laws and
FMVSS No. 218.
The first issue relates to the difficulties that States
have had in establishing that some motorcyclists are
using helmets that have not been certified to the
Federal Standard.
A second issue relates to the inability of some helmet
manufacturers to locate the certification label as
required by the standard, due to the presence of edge
rolls on helmets.
Third, there have been issues relating to determinations
of noncompliance in the agency’s own testing of helmets
under the guidelines in FMVSS No. 218.
New Proposed DOT Motorcycle Helmet Labeling
Requirements
NHTSA is proposing three requirements for helmet
certification labeling:
-
The application of a
“DOT” symbol water decal to the helmet beneath clear
coating;
-
Lettering on that decal
indicating the manufacturer’s name and/or brand name
and the helmet model designation in the space above
the “DOT” symbol; and
-
The word “certified” in a
horizontally centered position beneath the “DOT”
symbol on that decal.
Size Labeling and Location of the “DOT” Certification
Label
The agency is proposing that the required label on
helmets be positioned such that the horizontal
centerline of the DOT symbol is located between one and
three inches (2.5-7.6 cm) from the lower edge of the
helmet.
In addition, the agency is proposing that helmets be
labeled with a “discrete size,” which will correspond to
the appropriate test headform.
Proposals to Aid Enforcement of State Motorcycle
Helmet Use Laws
The proposed rule would establish additional
requirements for certification labels that would entail
processes that are inexpensive for the helmet
manufacturer, but would be more difficult and expensive
for those who may be producing false “certification”
labels.
The new requirements would also help consumers and law
enforcement personnel distinguish between certified and
uncertified helmets, facilitating the enforcement of
state and local helmet laws.
The proposed additional requirements would make it
difficult for stores selling misleading “DOT” labels to
claim that they did not intend to sell labels indicating
certification, but were merely selling “Doing Our Thing”
stickers (Some merchants sell “DOT” stickers for novelty
motorcycle helmets, claiming that the stickers are not
intended to be counterfeit certification labels, and
that DOT stands for “Doing Our Thing.”).
It would be difficult to establish a plausible reason if
such a sticker would include manufacturing information
or the word “certified”. It would then be clear
that any store selling a sticker with the proposed
labeling requirements would be selling labels intended
to deceive law enforcement officials about whether a
helmet is certified.
NHTSA is proposing the use of a water decal for the
“DOT” symbol which would be affixed to the motorcycle
helmet before the shell’s clear coating is applied.
Additionally, the label would be required to bear
lettering indicating the manufacturer’s name or brand
name and the helmet model designation in the space above
the “DOT” symbol, as well as the word “certified” in a
horizontally centered position beneath the “DOT” symbol.
These additional requirements would make production of
labels that create the misleading impression that a
helmet is properly certified more difficult and
expensive, which would both deter the production and
sale of such labels and help law enforcement officers
enforce state helmet use laws.
For more information and to comment on these proposed
amendments, visit the
Federal eRulemaking Portal and follow the online instructions for submitting comments.
The proposed rules are in the following document,
published in the U.S. Federal Register:
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
49 CFR Part 571
[Docket No. NHTSA-2008-0157]
RIN 2127-AK15
Federal Motor Vehicle Safety Standards; Motorcycle
Helmets
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking (NPRM).
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