The Raider coverage really irritated me in the lack of understanding regarding the lowering of the helmet as to why Michael was NOT called for a penalty. I could tell right away, but one of my biggest pet peeves is when announcers don't know the rules of the games they are covering. It's their job to know.
The rule only applies outside the tackle box or three yards past the line of scrimmage.
There are THREE components to this foul:
First, the player must line up his opponent.
Second, he must lower his head.
And third, he must initiate contact with and deliver a forcible blow with the crown of his helmet to any part of his opponent’s body. The crown is the very top of the helmet.
If any of the criteria is not met, it is NOT a foul under this new rule.
Michael was clearly running at an angle and did NOT line up his opponent. Thus, no foul. It is NOT simply lowering the helmet that causes this new rule to come into effect.