U.S. TOOLED and MANUFACTURED - QUALITY TRAILER, RV, and Truck LIGHTING
By D. G. Moore Sierra Design Manufacturing (formerly Sierra Products, Inc.) Home of "Dry Launch®"
LEGALITIES and PRACTICALITIES relating to TRAILER Lighting
In the following, I've tried to explain what Legal and Common Sense Considerations should be taken by those buying, supplying
and using Trailer Lighting so everyone involved remains compliant to "Federal Motor Vehicle Safety Standard #108"*, and at
the same time, considering the End User's safety, satisfaction and overall cost!
*FMVSS #108
I have found that using the thought process of imagining myself being surrounded by other Drivers and Pedestrians when
pulling and maneuvering a Trailer … I am able to best estimate what size and locations that my "Presence" and "Signal" Lights
(and Reflectors) would need to be … in order to provide the best "conspicuity"* to those I've put in danger.
*"CONSPICUITY" is the main goal of FMVSS #108
Further! recalling my personal "close call" experiences from 40 years of pulling my personal Boat and Car Hauler* Trailers
… I have become aware of the importance for Trailer Lights to be bright, multi-directional and conspicuously placed …
with the capability for failed lights to be easily, quickly, and economically repaired or replaced .
*I restore old cars as a hobby
The reputation of a Trailer that is supplied with inadequate … easily failed … or "can't fix" Lighting will be diminished,
while also increasing a liability that can end up costing much more than what was saved when Federal, State, and
common sense Requirements are ignored.
Currently, you'll not hear or read about the National Highway Traffic Safety Administration (NHTSA) challenging any Trailer,
RV, or Truck Lighting for being Non-Compliant to Safety Standard #108 … this has been the situation for several years.
This lack of attention by NHTSA (and State authorities) is causing serious Safety consequences and … in my view …
represents a case of “Malfeasance” which NHTSA will, conveniently blame on lack of funds as they have in the past.
Regardless! and in contrast to common beliefs, even if Safety Laws are "not" enforced by NHTSA … Non-Compliances of
Federal Motor Vehicle Safety Standard #108 are still considered "Illegal" in all State and Federal Courts … enforced or not.
ONE OF A KIND Vehicle Lighting Products
Besides trying to distribute Technical, Legal knowledge and my advice, I'm trying to bolster our sales … for "both" … our
new products … and, for our "Ol Reliables" by comparing our legal status and our "one of a kind" features to the Noncompliances and the lack of features offered by our Competitors and what we offer over LED’s … Chinese "Cheapos" …
and “Look-a-Likes”.
Not many are aware that we were the first to introduce the "2 Color, Fender Mount" concept, which has resulted in
many Trailer Manufacturers realizing the dollar savings and safety benefits of using our "360° reliable
Wing Tip®, Fender Mounts" that performs as official, Front "and" Rear Pointing Clearance Lights, as
well as providing an … always appreciated … nearer to Traffic Eye Level … "Location Light", plus adding
Here's our 5 Function … All Lexan®
an Augment Tail Light and a "Side (pointing) Marker Light” … thereby performing 5 Safety Functions in
Wing Tip with a "Step-On-Able"
total … using just “one” light.
Wire "Crossover Bar"
"MODULES" to replace failed LEDs
We have also begun to offer our popular* #400 and #500 Series "Center High Mount Stop Lights"
(CHMSLs*) in "Modularized versions", while also adding 10" and 16" Modularized Designs for "Legal
Replacements" for the many failed 10" and 16" Chinese LED Imports installed on over a million "Caps"
"Canopies" "Toppers" in the U.S. and Canada. Further! we are now offering “3-Wire" Versions of most of
our CHMSL Products, which can provide a Center High Mount Augment "Turn Signal System" in addition
to their CHMSL duty.
These products are also all Lexan®, but are not submersible. However, they can offer FMVSS #108
Compliancy for Brake/Turn and Tail Light applications when “tandem” wired … ask for details.
"MODULARIZED" CHMSLs can also be
used for Non Submersible
Federally Compliant
Brake/Turn/Tail applications
*Over a Million of our 17 Original #400 and #500 Series CHMSL Variations are still in active use … plus another
million+ of Cheapened Chinese, failed, "Copies"
UP AGAINST LEDs! … INCANDESCENTS are WINNING
We've found most people think that the maze of “Sparkles” they see in most of the new Auto, SUV and Pick Up Tail
Light designs are generated by LEDs. In reality, the sparkles are more likely to be generated by "Reflection Facets"
using the latest "State of the Art", "Long Life" Wedge Base Incandescent type Bulbs.
We know that competing against LEDs for "New Look" business is a challenge; however, we continue to point out that
3 out of 4 of “all” new Autos, SUVs and Pick Ups now use "Incandescents" and "NOT" LEDs for their Brake, Red Turns
and Tail Light illumination and "all"… that is, 4 out of 4 … use Incandescents" for their Amber, Turn Signals and Back Up
Lights. There are a variety of reasons for choosing Incandescents over LEDs … read on! and consider our "why"
explanations.
INCANDESCENTS DO IT BETTER!
Most Trailer Manufacturer Managers aren't aware that 3 out of 4 of all new Auto, SUV & Pick Up Tail Light Designs now
use "State of the Art" long life, "Incandescents" like the #3157 Sylvania® Long Life, Wedge Base, Incandescent Bulb we
use in our newest … See Thru/Chrome … See the Bulb … "SPLL" Multi Function.
The "SPLL" is designed to capitalize on the "See Thru, mesmerizing magic" that only “Incandescents” can produce.
Unlike LEDs that project light only in one direction … Incandescents put out - at the least - 3+ times the light in "all"
directions. A lot of this all direction light can be collected and reflected to any desired direction - yielding an endless
array of choices for "cool" … "one of a kind" … "intriguing" designs … which represents a designing choice that is being
capitalized upon by most Tail Light Designers and Engineers.
While all the new Tail Lights you'll see lit up at a Traffic Light, may resemble a “maze of LEDs" … where 3 out of 4 times
you are seeing magical "Sparkles" coming from a multitude of gathered and redirected, "Incandescent Rays"*. Most of
these mesmerizing, Incandescent, "See Thru Designs" are still being mistaken for LED using types.
*"Rays" is my term to indicate quantity and direction of light
If you slowly walk through any parking lot, you'll be surprised how many Incandescents are used versus LEDs. If you look a
little closer, you'll also see that "all" of the (≈1 in 4) designs that are using LEDs for their Brake Function use
Incandescents for "both" their Amber Turn Signals and Back Up Lights.
If you'll look around when at a Traffic Light, you'll observe the multitudes of intriguing "Incandescent" designs and you'll
see how much better Incandescents work than LEDs in producing truly unique*, “unregimented”* … very bright …
multi-direction … non-boring looks!
*A bunch of lined up "waffle pattern" Red Dots are far from being unique and intriguing!
3 METHODS for USING LEDs in a MULTI-FUNCTION
For those who insist on using LEDs in their Tail Light Designs, there is only one way that can produce a somewhat
interesting, See Thru LED Tail Light design … while … at the same time … complying to Federal mandated, minimal
Photometric and "Effective Projected Luminous Lens Area" (EPLLA) requirements … "Tunnel Reflectors" must be used*.
Tunnel Reflector Designs are far more expensive than the 6 to 12 "Dot" Systems Trailer Manufacturers mostly buy;
however, now that the "Effective Projected Luminous Lens Area" (EPLLA") Laws are being enforced, it's hard to avoid this
extra expense.
*Practically all LED Designs you'll see in a Parking Lot use "Tunnel Reflectors"
The second and least expensive way to produce a LED … Federally "compliant" … design - is to use a “Multi Grouping”
of ≈40 to 80 smaller, less powerful LEDs packed closely together. This approach still allows the "See Thru Look", but all
that's seen is a bunch of rather uninteresting Red Dots. This method can "currently" be seen replacing* the 6 to 12 LED
“EPLLA” deficient designs used on Big Rigs, etc. over the past 8+ years.
*They're being replaced because owners are realizing the "EPLLA" Non Compliancy can be costly in Court.
The 3rd Option for producing a Federally compliant LED design is to use more expensive and more powerful LEDs that
provide "wide" angle ≈40° to 60° outputs projecting into a series of overlapping Fresnel lenses. This makes the "EPLLA"
mandate possible to pass, but totally spoils the "See Thru Look".
Of course, if the Fresnel Rings don't light up using the definition for Effective Projected Luminous Lens Area … this
represents a Non Compliancy that a sharp lawyer could use to his/her benefit in Court.
CONSIDER our "SPLL" over QUESTIONABLE LEGAL and UNKNOWN QUALITY LED DESIGNS
In all three methods for using LEDs … complying with “Effective Projected Luminous Lens Area” mandates
represents the "hardest to meet" Federal requirement. For Vehicles under 80” in width, "EPLLA"
minimum is 7-3/4 in² and for over 80” Vehicles it’s 11-7/8 in² … which means, at least 11-7/8 in² of area
must be seen "lit" when viewed, from any angle within the 20° Left/Right; 10° Up/Down Federally
required "Test Pattern"*.
*Mandated "Test Patterns" for all Presence Lights, Signal Lights, and Reflectors are detailed in FMVSS #108 - use our website link!
Our "SPLL" accumulates at least 11-7/8 in² of EPLLA when viewed within the official “Test Pattern”. It is, by
grandfathered reasoning, "OK" to take advantage of the ≈30% "dead areas" allowance* that has been permitted in
Fresnel designs for the past 44 years, which therefore! … all "Tunnel" … "Multi Grouping" and … "Fresnel" LED designs
are also allowed to take advantage of.
*For a better understanding of “EPLLA” and "Dead Areas" - read our other writings on these issues
Also, we ask that you take a few minutes to consider all the other advantages our products have over LEDs and "Same
Ol/Plain Jane/ Cheapos", including the fact that … like all of our "SP" products … the "SPLL" is also entirely made from
Translucent, Lens Grade, Lexan® where the entire Body lights up when the Running Lights are on and the entire body
"brightly pulses" when the Brake/Turn/Lane Change Signals are activated. Further! Lots of pulsating, white, signaling
light can be seen by the Driver projecting down through our "Splash Guard Windows" and thereby illuminating the
Pavement yielding a "Signal Check" feature that can be seen through the Driver's mirrors - a subtle feature that will be
appreciated once its safety value is recognized
Further, consider … like all our "SP" Multi Functions … the "SPLL" provides our popular "Snap Out" Bulb Slide that
provides easy, "No Tools" Servicing and wiring troubleshooting when needed.
We consider the "See Thru", “Tunnel Reflector" using design that Wesbar® currently offers OEMs our only EPLLA
Photometric Compliant Competition. Wesbar® (a subsidiary of Cequent®) took the time and spent the money to Design
and Tool this nice looking*, totally sealed, Submersible** LED Multi Function. It appears to meet all facets of FMVSS #108
and unless the LEDs fail or a leak** ruins them … it will, probably, hold up for a number of years when used in Full
Exposure and Submersible applications … as all our "SPs" are capable of.
*Uses "Tunnel Reflectors"
**LEDs are quickly "killed" when subjected to heat or moisture
There's only one problem with this fine looking Wesbar® Submersible - it's not cheap when compared to any of the
average Chinese made LED Multi Function that always presents quality … legality … and survivability questions.
OUR MISSION:
"COMPETE with all LED and INCANDESCENT FMVSS #108 Compliant Multi Functions for Trailers
as to PRICE - QUALITY - LIFESPAN - SAFETY FEATURES - and "OVERALL VALUE"
Our 5 FUNCTION, FENDER MOUNT, WING TIP®
Several years ago, we introduced the very first Dual Color, Fender Mounted, 5 Function, "WingTips®"
and they have become quite popular ever since. The main purpose of WingTips® is to direct Red Light
rearwards and Amber Light forward thereby representing "Extreme Width". NHTSA calls these
"Presence" … or more particularly … “Clearance” Lights. They are mandated to represent the "presence" of "Extreme
Width"* to other Drivers and nearby Pedestrians.
*”Extreme Width” is the term used by NHTSA in Federal Motor Vehicle
Safety Standard #108
When Fender mounted, they are elevated closer to average Traffic Eye Level* making them more effective in avoiding
"clippings" when Vehicles pass each other. And, since our 360°** viewable WingTip® design also projects "Presence"
light to the sides; it also helps to avoid intersection accidents and pedestrian mishaps. "Up, very High" and "Down, very
Low" mounted Clearance Lights don't provide these safety functions nearly as effectively.
*As opposed to "Step Pad" mountings
**FMVSS #108 Compliant for 360°
A dual color, fender mounted WingTip® will eliminate one Clearance Light (on each side), which saves the cost $ of two
ordinary Clearance Lights … their installation labor cost … and the power to keep them lit over the life of the Trailer.
Also, the Multi Function doesn't need to provide a Clearance Light Function.
The 360° viewable WingTips® are also particularly faceted to direct extra Amber "Location Light" to the Tow Vehicle's Rear
View Mirrors so the driver can view the exact position … the extremities … and direction of travel of the trailer when
backing up at night or in a heavy rain or fog. Big Rig drivers wouldn't be without their "Location Lights"*.
*Big Rig Drivers use their rear (eye level) side mounted Clearance/Side Marker Combination Lights for their "Location Lights"
When used on Boat Trailers, WingTips® can also be used to help "center the boat" during retrievals.
SAVES the $ COST OF TWO LIGHTS and CAN BE STEPPED ON
We designed our "Crossover Bar" so it can be stepped on. The serrated edges and notches
are designed to provide a "grip" for a bare foot or deck shoe. Since it’s entirely made of
Lexan®, it will take abusive treatment and it saves the expense of a 2nd Clearance Light on
each side of the Trailer.
However … to our surprise … we've been told by our Sales Reps that some Boat Trailer Manufacturers don't like the idea
of a "single" Dual Color, 5 Function, Presence Light mounted on the Fenders over their current method of using
"separate" Red and Amber lights mounted on their Step Pads or Frame … which is their prerogative.
Apparently, many Boat Trailer manufacturers don't want to encourage anyone stepping on their fenders; however …
during my boating days … I frequently used my Trailer's fenders as steps and occasionally "slipped off" a wet fender …
thereby suffering the consequences! Looking back, I think I would have welcomed some sort of "frictional" step pad on
the fenders, particularly if I could have used the submerged (working) Light to center the Boat on the Trailer while my
wife pulled forward.
Whatever thought process is used … be aware that we have the ability to Design, Tool, and Manufacture any "Custom"
WingTip® design desired … or … for that matter … whatever else! Custom Lighting might be desired … as long as the
projected quantities warrant the Tooling costs.
Also, consider that WingTips® can be supplied with very long pigtails that can reach from the Fender Areas to our Tail Light's*
Hi & Dry® Terminals, which makes it possible for all Side and Rear Lighting Hook Ups to be made in a common "dry" area …
requiring no Wire Nuts or Bullet Connectors and also providing easy wiring troubleshooting access whenever needed.
*Only standard SPs, 701s, and 702s have Hi & Dry® Terminals
OUR MISSION:
for our WingTips® - "To Promote our 5 Function Fender Mounted Safety and
Cost Savings Features, while offering Standard as well as Custom Fender Mount Designs
Our “OL RELIABLES” - SPs, 701s, 702s, 327s, 203s, etc.
All our older Submersible and Tough Duty products are still very popular as numerous Testimonials will substantiate.
However, Dealer and OEM Sales in all but Florida - leaves much to be desired. So, we're hoping that we can convince
Distributors, Dealers and OEMs all over the U.S. to consider Dry Launch® products as "mid price" choices … placed "between"
the more expensive (Federally compliant) LEDs, and the least expensive … questionable quality and unknown legal status …
Chinese Imports.
Lastly, we ask that potential customers keep in mind … when considering buying Imports … directly or indirectly … made of
unknown materials … all Dry Launch® products will not prematurely fade, nor will they easily break or shatter. Also, keep
in mind that all our products use "find anywhere" Incandescent Bulbs that can be quickly Driver or Dealer serviced with
no Tools required.
Our "SPs", "SPCLs" & "SPLLs" can REPLACE a VARIETY of Competitors' "Same Ol" Designs
Our 7/8 Function Designs provide an easy "Tit for Tat" Replacement Update opportunity for improving road
safety and styling on ≈3 million* of already in service Trailers that have been straddled with Troublesome and
"Same Ol" factory supplied 7/8 Function Light Assemblies.
*which doesn't include another Million of ShoreLand'r, E-Z Loader and other quality Trailers already using
our #701s, #702s and SPs
Our “SPs” can Replace
and Update any of these
Rusting/Failing INCANDESCENTS and "Un-Fixable" LEDs products Negative Feelings
As the years go by … many Trailer, RV and Truck Owners/Drivers will come to realize they have been supplied with
unreliable and cheaply made Lights that are not only grief producers … but may also represent violations of State and
Federal Vehicle Safety Laws … and therefore, will be viewed as illegal in the eyes of all Federal and State Court Systems.
Realizing they were supplied low quality … and perhaps, illegal Lighting products … simply to save someone a couple
bucks … you can bet negative feelings will be generated towards the Vehicle Manufacturer, the Distributor, or Dealer (or
all 3) that supplied the problems.
Over the years, I have heard many of my friends and acquaintances curse* troublesome Trailer, RV and Truck Lighting
and those that furnished them. In fact, the continual rusting of the 7 Function Lights originally supplied on my personal
Boat Trailer led me to the development of Dry Launch's® original “Air Trapping” #701 Design - one of these days, I'll
write out all the details!
*including myself! … ask my wife!
Pointing out competitor’s Quality, Technical, and Legal problems … in these writings … doesn’t mean that we are claiming our
designs will cure all lighting problems … however, we do want to point out that our quality and unique features, will indeed,
help drivers avoid many unpleasant and unsafe situations that our competitors don't bother addressing.
Our Helpful "PAVEMENT LIGHT UP" SAFETY CHECK! FEATURE
PULLING A TRAILER IS ALWAYS A NERVE-RACKING EXPERIENCE … particularly, for those who
don’t pull Trailers frequently. Trailer Drivers always feel more relaxed and confident when they
are assured there are no problems that may be keeping their Brake/Turn/Lane Change Signals
from working effectively. At night, Drivers can fairly easily verify that their frontal "Running
Lights" are working by simply using their Rear View Mirrors; however, Drivers can't readily
determine if there exist any problems with their Brake/Turn and Lane Change Signals.
Unique "Rear Signal Verification"
Pavement Light Up Feature
To be sure the Rear Signals are working properly … a "helper" is generally used (if available*) to stand at the rear and
verify that the Brake and each Turn Signal is working properly . Our “Pavement Light Up" Feature eliminates the need for
helpers and/or for back and forth trips by the Driver.
*Otherwise, the Driver must personally perform the required "walk back and forth" rituals
All our "SP", "SPCL" and "SPLL" Multi Function Designs project lots of light in "all" directions … including downward
through "both" the Right and Left, Transparent “Splash Guard Windows”. This powerful light becomes "see-able" as
it is reflected off the Pavement … thereby … during dusk and night hours … provides the Driver a "Rear View Mirror
Signal Verification System" to assure that the Brake/Turn and Lane Change Signals are working effectively!
I can say, from personal experience - "This is a worry and effort reducing … feature”! that none of our competitors can offer.
MEETING Minimal FEDERAL MANDATES for PHOTOMETRIC and "EFFECTIVE AREA" OUTPUTS
Current Federal Photometric Mandates require a minimal Candela output for Standard Brake/Turn and Lane Change
Signals … of 80 Candela* straight back with falling intensities* within the "Test Pattern" of 20º to the Left to 20º to the
Right; 10º Up to 10º Down.
*See FMVSS #108 for Photometric Details … Use our Website "Link" to minimize wasted time and confusion
Then there is the frequently ignored … Federal Mandate that requires at least 11-5/8in²* of "Effective Projected
Luminous Lens Area"** ("EPLLA") projecting within the official NHTSA “Test Pattern” … and “not” beyond**.
*For over 80" wide vehicles … 7-3/4 in² for Under 80” Wide Vehicles … 4- 1/2 in² for CHMSLs …
discussed in detail here and on our Website
**Areas that are projecting beyond the "Test Pattern"! - cannot be EPLLA tallied
Expressions most misunderstood … or outright “ignored” … in these definitions are: “Effective Light Emitting Surface” …
and, "a result of uncontrolled light" … “functional lighted lens area” … and, "does not include transparent lenses".
“Ignoring” “Effective Projected Luminous Lens Area” Mandates continues to be an ongoing “major” safety
problem that no authorities … I'm aware of … are challenging. Non Compliant products are still being brought
into the USA by the "Millions" by ignorant … or "don't give a damn" … Importers. This includes a
Brake/Turn/Lane Change Signal Light made by "Blazer" that is currently being sold by Wal-Mart® … shown to
the right.
Wal-Mart’s,
Non-Compliant
Brake/Turn/Lane Change
Signal Light
The big advantage Incandescents have over LEDs is that typical #1157 and #3157 Brake/Turn Incandescent
Filaments develop! much more usable light than what a typical, 6 to 12 Brake/Turn LED Array can develop. Additionally!
this high intensity, "Incandescent" output is projected in "all directions" making it fairly easy for an Engineer … and a
sophisticated Computer Program … to gather and redirect much of this "all directions" light to within the official Federal
"Test Pattern"* confines … thus yielding enough "functional lighted lens area” to comply to NHTSA's 11-5/8 in² "Effective
Projected Luminous Lens Area" mandated requirement … with a bunch of "output leftovers" that can be used for
projecting extra “Presence” and “Signaling” to adjoining lane drivers and nearby Pedestrians, that LED Designs are not able
to supply.
*Meaning within the 20° Left to 20° Right; and 10° Up to 10° Down "Test Pattern" and not beyond
Be aware! … Most LEDs used for Trailer Brake/turn/Lane Change signals, produce only narrow Conal Projections of Red
Dots. Using these types of LEDs - it will take many of them to produce 11-5/8 in²* of, tally able, "Effective Projected
Luminous Lens Area" (EPLLA) that projects within the 20º Left/Right, 10º Up/Down "Test Pattern" … while leaving
practically nothing extra for Side Lane and Pedestrian "Presence" and "Signaling" warnings.
*Minimal Mandated "EPLLA" for Vehicles over 80" in Width
OUR MISSION:
for all our “Ol Reliables” … "Keep providing superior Quality and
Unique Features … while innovating New Designs, and
welcoming Custom Requests"