File Listing for Snell Response to NPRM, FMVSS 218 Docket No. NHTSA-2008--o157 

 

Document (html)	pdf
Snell's Cover letter to DOT reply	dot reply.pdf
Comments to NPRM Regarding FMVSS 218	dot reply.pdf
Guided Fall Impact Test Devices Monorail and Twin-Wire	mo_tw2.pdf
Swing‐Away Testing, Guided Fall Testing and Time Duration	swing-away1.pdf
Impact Velocity and Time Duration in FMVSS 218	timeduration.pdf

 

Cover Letter

 

Docket Management Facility:

U.S. Department of Transportation,

1200 New Jersey Avenue, SE., West

Building Ground Floor, Room W12–140,

Washington, DC 20590–0001.

 

November 7, 2008

 

Re: Docket No. NHTSA–2008–0157

 

Gentlemen,

 

I and my colleagues at the Snell Memorial Foundation have prepared the enclosed comments regarding the recently announced notice of proposed rulemaking for FMVSS 218.  The Snell Memorial Foundation is a not for profit organization dedicated to promoting the development, manufacture and use of effective protective helmets for use in motorcycling, auto racing, bicycling and other activities.  The Foundation was first incorporated in California in 1957 and has since achieved national and international recognition in the field of helmet safety.

 

The enclosed comments reflect our serious concerns with the changes proposed for helmet compliance testing to FMVSS 218.  We feel that these changes constitute a change in the FMVSS 218 standard itself and we expect them to threaten the status of some of the highest quality motorcycle headgear currently available in the United States.  We have done our best to enumerate and explain our concerns and to support them with technical argument. We have also suggested alternative courses of action to remedy the problems identified in the NPRM.  The enclosure includes several references to technical documents which have not been included but which are available on request.

 

We appreciate this opportunity to comment on the NPRM.  We would welcome the chance to collaborate further on these issues with engineers and technicians at DOT, NHTSA and, where appropriate, with contract testing organizations.

 

Sincerely,

 

Harold A. Fenner, M.D.

President

 

Comments to NPRM Regarding FMVSS 218 - Docket No. NHTSA-2008--o157