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TX,
In general, I agree that the player has to be targeting his opponent. But I can think of at least one exception, and that is the defender attempting an open field tackle who lowers his head and makes contact with the top of his helmet, usually at the runner's thigh or knee. The NCAA put together an excellent video a couple of years on helmet contact/targeting, and this was one they wanted called. It's the most dangerous play in football. It needs to be called whenever we see it, at any level.
Also, the fact that we have rulebooks doesn't absolve us of the responsibility to use some common sense:
A defender is in perfect position to make a tackle: Head up and to the side, butt down. He commits to the tackle and the runner cuts, resulting in the defender making initial contact with his facemask instead of his shoulder. No way that's a face tackle.
Or a blitzing LB or safety launches himself helmet-first at the side of the QB's head, delivering a classic helmet-to-helmet shot. But just before the helmet contact, he made contact on the QB's shoulder with his hand. Is he getting a flag? You betcha, and in HS probably an ejection too.
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