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In all 3 variations of "Illegal Helmet Contact", the key verbiage is, "initiates contact" with the front, or top, of the helmet. It's not rocket science, when these rules were created it was in response to an increase is very serious injuries to TACKLERS who were using their heads improperly.
The value of the rule is not measured by how many players are caught violating the rule, but in how effectively coaches teach players to avoid using the head improperly when making a tackle. Someone teaching aiming the head at center of mass to make a tackle, but simply relying on cautioning them to avoid making the initial contact with the head or face, is like handing a child a loaded gun, and cautioning them to be very careful.
When the gun goes off, hiding behind a vague note of caution, doesn't provide very much cover. It won't work well when a player winds up in a wheelchair either. Coaching is teaching and in some respects there is significant responsibility and liability related to not only what is taught, but what is learned as well.
When these rules were presented, the problem was considered serious enough to suggest a warning that if the problem didn't reduce sufficiently in the first two years, serious consideration would be given to an alternate suggestion of removing face masks from all helmets as a way of deterring use of the head as a weapon.
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