John, if you read the 38.1 spec, it basically describes a HANS. Including the basic architecture. Hubbard et al state that the loads must be transferred to the body via the armature or yoke thing. (I'm going from memory so my wording isn't exact, but the point remains)
(On edit, it appears Gregg feels differently. I'll dig up the spec later when i get a minute and reread, but I swore that it was more complex that just the release)
The Isaac as you probably know, doesn't work that way, it utilizes the belts for it's 'anchor'.
Isaac could pay all the fees and such, but the device will get rejected every single time.
The spec is written in an overly narrow manner. It's a shame, as it's restrictive to innovation. It's as though the UL stepped in after the lightbulb was invented, and demanded that all future artificial lighting products have a filament, a glass bulb and a socket. We'd have never seen the wide plethora of lighting like LEDs, Sodium vapor, HID, etc etc.
Or, if you're HANS, the spec is written wonderfully, and their abilities to have their device mandated as the ONLY device acceptable by a number major series, and their ability to position themselves as the 38.1 "Kleenex" brand as resulted in major market share and sales.