Yes that would be an example of an egregious comfort issue causing safety concern.
Venting that directs airflow to the eyeball would be another, in my own experience. Cheap plastic visors that scratch easily and put up distractions or aberrations directly in line with your vision as well.
All of these not covered by SNELL, ECE or even FIM.
So I agree. But a blanket "comfort = safety" statement needs clarification. Nobody ever crashed because their liner was slightly rougher than a top-of-the line Arai or Schuberth. Or that the lid is 200 grams heavier than a carbon fibre shell. Some people dont have the budget to afford those helmets. Doesn't mean anything less is unsafe.
I'll give you an example of comfort impacting safety. My son follwed my lead a few years ago and bought an RF SHOEI from Cycleworld. He wore it for a couple of years, it was a great quality helmet meeting top safety standards. It had 2 problems: 1) a windstream past the ears that caused an earache on long rides, and 2) too much cheek pressure that caused him to constantly adjust the chin.
Now, the latter was a fitting mistake made by the folks at Cycleworld, should not have happened. But the ear-aches were IMHO a design issue, I got them in my RF too.
The bottom line is that those were comfort issues. Anything distracting me while I'm riding is a safety issue.
Long rides = wear ear plugs so you can still hear in your grey years, tinitis sucks, ask my friends who have it, but ask them LOUDLY
Cheeks too tight = just buy a different inner pads for your helmet
I sold helmets for a couple years when I worked at the dealership. A LOT of people will spend hundreds and hundreds to buy a helmet, but then won't spend the extra $50 to buy the right sized inner pads for their face. It's not even their fault. A lot of people just don't even know that the helmet manufacturers make thinner and thicker pads that you can order separately.
You buy the helmet for your head shape, and then you buy the pads for your face shape. Most of us don't need to do this, most of the time the (good) manufacturers get it right, but not everybody fits off the rack and a lot of people neglect how much more they'll love their helmets if they buy the right cheek pads for them.
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