OPERATION HELMET The Honorable Kenneth J. Krieg …

                     OPERATION HELMET

The Honorable Kenneth J. Krieg                                            March 19, 2007
Under Secretary of Defense
Acquisition, Technology and Logistics
3010 Defense Pentagon
Washington DC 20301-3010

Dear Sir:

On March 13, 2007, we received a copy of your letter to the House Armed Services
Subcommittee dated Feb 22, 2007 with the attached U.S. Combat Helmet Suspension
System Comparison Summary and Findings dated Dec 2006. We have completed an
initial review of the data and provide comments below. We have limited our discussion
to the lightweight helmet (LWH) now used by the Marine Corps and to the Personal
Armor System for Ground Troops (PASGT) helmets used by most of the services.

It is rather disturbing that no one contacted Operation Helmet to ask questions or
confirm the facts. It appears that even a simple review of the web site did not occur.
We clearly state in the on-line request form that each helmet requires a different pad
system.

Since February of 2004, we have shipped BLSS kits to troops who have requested
upgrades for Personal Armor System for Ground Troops (PASGT) helmets. We have
shipped the BLU-6 kit if a troop has the Lightweight Helmet (LWH). Given the $29
difference in our charity's cost in sending a $71 BLU v. $100 BLSS, it only makes sense
to send what is needed. We have also sent 1,000 kits from Skydex to non-frontline,
fixed base troops, primarily Air Force.

We chose the Oregon Aero BLSS/BLU kits as our preferred upgrade, as it had been
used in combat conditions with excellent results for several years in the MICH, ACH and
PASGT.

The current Marine upgrade is the Team Wendy (TW) pad which share the same
dimensions and National Stock Numbers (NSN) as the Oregon Aero (OA) BLU pads,
which we understand are each equally available. We also understand from field
feedback that the USMC is now providing ¾" or 1" front, side, and rear pads and 1"
crown pad, often requiring a larger sized helmet in order to fit the same head. The BLU
kit is available with similar dimensions and provides the same degree of protection as
the Team Wendy (TW) pads in both the PASGT and LWH, and adds comfortable
wearability and stability.


                                 74 Greenview Street
                                Montgomery, TX 77356
                                   EIN 20-1756585
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From the report, "Pad placement on the test form was done in accordance with that
recommended for the ACH in airborne operations."

      OH Comment: This placement emphasizes forehead and neck/occipital
      protection during a PLF (parachute landing fall), and does not take into
      consideration the manufacturer's recommendations for dispersal of pads in the
      helmet to mitigate blast/impact protection in the IED environment which is not
      mentioned in the report

From the report, "Within helmet system fitting types, the performance in blunt impact
protections appear to be dependent on the test temperature conditions."

      OH Comment: Cold temperature testing was done on headforms that reflect
      ambient temperature in the test environment instead of on headforms that
      simulate human body temperature. All foam pads become firmer in extreme cold,
      as water is an integral part of the foam itself. When the firm pad is placed on the
      warm human head, the pad quickly (2-5 min) assumes the temperature of the
      head and resumes its 'conforming' capabilities. The same can be said of the hot
      temperature testing. Pads do NOT assume the ambient temperature when worn,
      but reflect the head's cooling/heating ability on the pad temperature.

From the report, "A Helmet fitting system that allows water accumulation could alter
blunt impact performance when saturated and/or the fitting system performance could
change after drying."

      OH Comment: This is perhaps the most important laboratory test, after blunt
      impact testing and was not included for reasons unknown to us. In the real
      world, pads are worn continuously in hot environmental atmospheres where
      sweat production is ongoing and pads are in danger of becoming waterlogged.
      An appropriate test should be designed in which the pads are immersed in water
      and subjected to continuous pressure equal to helmet weight on the wearer's
      head for a time equal to most combat patrols, then tested immediately.

      Objective testing needs to include testing under realistic conditions. For
      example, test dry and wet pads; test new pads and pads that have been worn for
      at least 100 hours (about 8 days under combat conditions) to as long as 1000
      hours (90 days).

From the report, "Additionally, the effects of ageing, and normal use wear and tear, on
pad performance were not evaluated in this study."

      OH Comment: An appropriate sample of used pads can be readily obtained from
      combat elements that have been used under combat conditions (not from

                              www.Operation-Helmet.org
                                74 Greenview Street
                               Montgomery, TX 77356
                                  EIN 20-1756585
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       garrison based users) and sent to the test facility for testing. Ample amounts of
       used pads should be available in the real-world environment to render artificial
       lab replication of conditions unnecessary.

From the report, "...the Oregon Aero BLSS system includes an integrated chin and
nape strap system attached to a 0.1 inch thick head band. The head band occupies
space along the circumference of the inner shell surface and necessitates a thinner pad
to accommodate the same head size".

       OH comment: This is erroneous. The reason for the BLSS kit's ½" front, side,
       and rear pads is based on the PASGT and LWH's specifications which call for ½"
       `standoff' between helmet and head. This is considered a safe distance to
       accommodate back-face-deformation if the helmet is struck by a non-penetrating
       ballistic missile such as a bullet or small ballistic fragment. The BLSS kit's pads
       meet that requirement.

       Additionally, Operation Helmet has shipped BLSS kits with ½" and ¾" front, side,
       and rear pads.

From the report, "The comfort of the helmet fitting system is critical for proper and
continuous wear of the protective equipment."

       OH Comment: We propose a test format (below) to evaluate wearability and
       comfort. We have a number of reports from troops indicating that the Team
       Wendy pads are so firm and uncomfortable the troops smash them with
       hammers in an attempt to make them wearable for their long patrols. This is a
       dangerous practice and compromises the pad system. Helmet pad inserts must
       conform to the irregularities of the skull. When an area of skull/scalp is subjected
       to ischemia (lack of blood supply) due to continuous pressure, severe migraine-
       type headaches often occur, leading the wearer to loosen the chin strap, delete
       pads or remove the helmet for relief, all dangerous practices in the combat
       environment. Some variation in pad placement and orientation is allowable for
       comfort and fit as earlier tests have indicated.

       Subjective testing is the only way comfort can be tested. It must be done in a
       double blind scientific way under realistic field conditions. For example, 25
       troops in Group I test kit "A" for the first week, "B" for the second, and "C" for the
       third. Group II tests in the order "B" "C" "A" and Group III tests "C" "A" "B", etc.
       Subjects for each group should wear the helmet for at least eight hours per day
       preferably under field conditions. There should be no contact between groups
       during the test period. Testing should occur in hot and cold desert (29 Palms/Ft
       Irwin) and hot and cold temperate conditions (Camp Lejeune/Ft Bragg).


                                www.Operation-Helmet.org
                                  74 Greenview Street
                                 Montgomery, TX 77356
                                    EIN 20-1756585
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We have contacted Oregon Aero, manufacturer of the BLSS and BLU systems, to see if
they can elucidate the widely divergent test results when the BLSS kit is used in the
LWH. In the USAARL testing, the BLSS failed the blunt impact tests, while in the
manufacturer's and independent laboratory testing, the BLSS kit passed blunt impact
requirements.

Finally, we want to help protect our troops and get them home safe and sound. Nothing
more, nothing less.




Robert H. Meaders, MD
CAPTAIN, US Navy (Retired)
President and CEO, Operation Helmet
docbob@operation-helmet.org
936-449-9706

cc:
House Armed Services Committee and Subcommittee Members
Senate Armed Services Committee and Subcommittee Members
Vice Chairman, Joint Chiefs of Staff
Chief of Staff of the Army
Chief of Naval Operation
Commandant of the Marine Corps
Chief of Staff of the Air Force




                             www.Operation-Helmet.org
                               74 Greenview Street
                              Montgomery, TX 77356
                                 EIN 20-1756585