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John,
in NFHS an IHC does not require anything about using the helmet as a punishing tool. But it does REQUIRE the contact is INITIATED by the helmet. It's the basic defintion of illegal helmet contact. We as officials don't get to make up rules or change them to suit our personal beliefs.
If you don't like the rule as written, berating officials about it is not going to do you a bit of good. If you truly feel the initiation requirement is unreasonable, you really need to work on the NFHS to change the definition, because you are not going to achieve anything here by what you've stated in this forum.
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