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Updated by Dennis G. Moore – 10/10/06
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CONVOY
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QUALITY VEHICLE LIGHTING PRODUCTS
“TECHNICAL and LEGAL CLARIFICATIONS” from Sierra Products Inc. – Updated 10/10/06
Table of Contents
TLC #101B
“WHO’S IN CHARGE”?
Page 2
TLC #102B
“RECALLS” are neither pleasant nor inexpensive
Page 3
TLC #103B
What’s minimally required for OVER and UNDER 80” Trailers, RVs and Trucks?
Page 4
TLC #104B
Our “SERVICEABLE”, FIVE & DUAL Function, “Optically Combined” #205 WINGTIPS®
Page 5
TLC #105B
Side Pointing, SIDE MARKER* LIGHTS … are for “Intersection Safety”!
Page 6
TLC #106B
Side Pointing and Rear Pointing REFLECTORS … “for Parking Safety”!
Page 7
TLC #107B
Federally Mandated “EFFECTIVE, PROJECTED, LUMINOUS LENS AREA” (“EPLLA”)
Page 7
TLC #108B
Actually “SEEING EPLLA” … Desk Top Test!
Page 8
TLC #109B
INVENTORYING both 7-3/4 in² and 11-5/8 in² (EPLLA) BRAKE/TURN LAMPS
Page 9
TLC #110B
Most “LED” 3 + 7-Function Lights are NON-COMPLIANT to “EPLLA” Requirements
Page 9
TLC #111B
“LEDs” project ONLY ±1% of “GATHERABLE LIGHT” that Incandescents project
Page 10
TLC #112B
“ILLEGAL DECEPTIONS” everywhere! … NHTSA says “Go Ahead” … “HANG YOURSELF”!
Page 10
TLC #113B
“NMMA” and CANADIAN MISINTERPRETATIONS of FMVSS #108
Page 12
TLC #114B
The “EIGHTH FUNCTION” Addition
Page 13
TLC #115B
“LEDs” SHOULD LAST! … But, will their CIRCUITRY & SEALING METHOD?
Page 13
TLC #116B
Did you Know? … WIRE INSULATION … CAN also LEAK!
Page 14
TLC #117B
“RED LIGHTS FACING FORWARD” … Allowable or Not!?
Page 14
TLC #118B
“OPTICALLY COMBINING” … Use this allowance to SAVE Money & Power!
Page 15
TLC #119B
ELIMINATE costly and unreliable “3 TO 2 Wire” ELECTRONIC CONVERTERS!
Page 16
TLC #120B
HERMETICALLY SEALED or AIR TRAPPING! – but NOT “FILL & DRAIN”
Page 17
TLC #121B
MIS-INTERPRETATIONS of FMVSS #108 and “BORDER HARMONIZATION”
Page 18
TLC #122B
LET’S SELL “HARMONIZED” U.S.A. Made TRAILERS, RVs & BIG RIGS all over the world!
Page 18
TLC #123B
6” INSIDE of the “WIDEST PART” … the “EXTREME WIDTH” … the “OVERALL WIDTH”
Page 18
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TLC #124A
NHTSA’S “LEGAL COUNSEL” says “IT’S
ILLEGAL”!
Page 19
TLC #125A
OUR GUARANTEE
Page 19
TLC #126A
WATCH OUT FOR “FILL & DRAIN” DESIGNS that collect DUST/DIRT and GRIME!
Page 20
TLC #127A
We can find only TWO LEGAL “LED” AFTERMARKET BRAKE/TURN LIGHTS!
Page 20
TLC #128A
IT’S THE LAW!
Page 21
TLC #129A
SEEING “Effective Projected Luminous Lens Area” (EPLLA)
Page 21
TLC #101B – “WHO’S IN CHARGE?”
Federal Law* prevails over all State Law relating to the same subject! In this case … publicly used Vehicle Lighting. All States
can copy and adopt (and, I believe all have) FMVSS #108* requirements into their own Codes; however, States must also adopt
similar Enforcement and Non Compliance “Penalties” requirements at the same time. If not … States risk the violation of Federal
Law … and actually face the elimination of Federal contributions for their Highway and Street Improvements, etc.
*FMVSS #108 = Federal Motor Vehicle Safety Standard #108 … see our website www.sierraproductsinc.com/Section108.htm for
details
Private nor Public Associations cannot make up their own versions or interpretations of Federal Law resulting in making FMVSS
#108 Regulations more stringent or less stringent than derived and interpreted by NHTSA (National Highway Traffic Safety
Administration). Furthermore, know that Canadian and U.S. Vehicle Lighting Laws are supposed to be the same – which, I
understand, is required by active Treaties and the most recent “NAFTA” Agreements.
The determination of what’s Legal and what’s Illegal hinges on NHTSA’s (or any State’s) “Compliancy Determination”, which is
accomplished by distinctively testing lighting products used by the public to the many Physical and Photometric requirements
mandated by FMVSS #108.
If just one Non Compliance of the many associated FMVSS #108 regulations is “obvious” and/or uncovered by credible
photometric or physical testing … ”Inconsequential to Public Safety” status must be granted by NHTSA (or by the State) for
“each” non-compliance in order to avoid Recalls.
Contrary to popular belief … NHTSA administrates only a “Self-Certification System”, which requires that those using, selling or
distributing Vehicle Lighting Products must be able to prove, when asked, that the Vehicle Lighting Products they are
involved with are, indeed, “Compliant” to all the many mandated Photometric and Physical requirements of FMVSS #108.
Therefore, there can be no such thing as … “NHTSA Certified or Approved” or “DOT Certified or Approved” claims for
mandated vehicle Lamps and Reflectors … as many dishonest Vehicle Lighting Manufacturers and Importers will try to
convince you of. The currently permitted (not required) D.O.T. Marking only indicates “Self Certification” and that’s all. Since
the allowed D.O.T. marking doesn’t clearly define exactly what single or multiple mandated Functions* are being “Self
Certified”, the D.O.T. marking virtually means nothing and represents another “erroneous and “dumb” NHTSA FMVSS #108
*That is, Brake, Turn Signals, Tail, Side Marker, etc., etc. functions
“enforcement” blunder that needs immediate, common sense repair.
Of course, NHTSA should be requiring … but are not … that every Product being Sold as “Mandated Lighting” to the American
Public should be adequately marked, so as to at least indicate the Manufacturer’s (or Importer’s) Name and Location, as well
as being adequately marked to indicate exactly, which Mandated Function(s) of FMVSS #108 this particular product has been
properly designed and tested to.
Also, know that NHTSA, as well as any State Compliance Authorities can ask any “involved” Company or individual … at any
time … for all necessary “Compliancy Proof”, especially when a “Non-Compliancy is obvious”, or when “just cause” can be
shown. To prove complete Compliancy to FMVSS #108 requires providing credibly engineered and professionally executed
“Photometric”, “Physical” and “Longevity” set of tests*.
*Covered in detail in FMVSS #108 and our “TLCs” (Technical & Legal Clarifications)
Since there are many Mandated Tests required … when inquiring about a specific “suspect lamp”, NHTSA, usually asks for only
what they consider the most important tests, such as the Brake and Turn Signal, Photometric (“Test Pattern”) Data.
Additionally, when there is any kind of unknown/untested plastics, NHTSA should also be asking for proof that the suspect Lamps’
Lenses and Support Materials have indeed passed the very important 3 Year Weather, UV, outdoor Heat, and Water
(Moisture) Exposure Tests … plus all other common sense Tests that guarantees the Public and all involved in all related
industries against “Rip Offs” and unreasonable and premature failures. NHTSA also maintains the authority to ask for any of the
many other mandated tests if they suspect this is necessary. Without hesitation, NHTSA should be demanding to investigate
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FMVSS #108 Compliancy for all “obvious poor quality … and
or soon to be on our roads.
obviously failed” Vehicle Lighting Products that are currently
Municipalities … that is, City, County, State Police and Fire Departments, etc. … are allowed to add Emergency Lights, etc. to their
Specialty Vehicles … more or less, at their discretion. However, everyone else … that is … Vehicle Manufacturers, Parts
Distributors … including Repair and Installation Dealers … that are maintaining, exchanging, modifying and/or selling
“Original” or “Replacement” Vehicle Lighting of any kind … whether for new, older, or modified Vehicles … must be prepared to
prove that all the lighting they’re providing to the Public, totally complies with all the mandated regulations of FMVSS #108.
Also, stating on the product, “Designed to comply with FMVSS #108”, does not mean that the product does indeed comply with the
many facets of FMVSS #108.
In order to avoid costly and embarrassing “Recalls” for any “Obvious” and/or “Test Failing” Non Compliances … NHTSA
must determine each Non Compliance to be “Inconsequential to Public Safety” … using the official Federal Register’s
Public Comment Process*.
*More details on this subject in future writings
TLC #102B – “RECALLS” are neither pleasant nor inexpensive
The most recent? Recall … against “Optronics” products … for over 50,000 “LED” 7-Function Lighting Kits … sold by “Unified Marine” …
NHTSA officially determined that these Optronics’ products failed FMVSS #108 mandated Photometric (“Test Pattern”) requirements in
several ways, which is detailed on the Web under: http://dms.dot.gov – Document Number 19792. These particular 7-Function “LED”
Lights were supposedly meticulously designed and FMVSS #108 tested for “Unified Marine” by the “Optronics” Company of Taiwan.
Furthermore, this is the 1st or 2nd of three recent Recalls for Optronics’ 3- and 7-Function Lights in just the past two years … this time, at
Unified Marine’s embarrassment and expense. Unified’s (Optronics’) plea for “Inconsequential to Public Safety” status on these
many Photometric Non Compliances… was denied by NHTSA, so another Recall is under way for these ≈ 50,000 “LED”6/7
Function Kits, plus Recalls for 2 other Optronics 3- and 7-Function “LED” Lights … see http://dms.dot.gov – Document Number 19792.
*See http://www-odi.nhtsa.dot.gov/cars/problems/recalls
By “studying” these numerous, expensive, and precise NHTSA Tests used in these Recalls … and, at Tax Payer’s (our) expense …
anyone can see for themselves the many and severe Non Compliances that “Optronics”, recklessly (or ignorantly), designed
into their LED Light Designs.
OEMs and Lighting Distributors should take the time to look over and discuss this failing data while addressing the several adverse
“LED” problems and “forewarnings” that become apparent when looking over these standard FMVSS #108 Compliancy Tests and our
“TLC” discussions, which everyone involved, should find very helpful for the selection of “Legal”, “Safe”, and “Grief Reducing” Lighting for
future customer offerings.
Also, realize that these standardized Photometric Tests did not include any demands put on Optronics (or Unified) to supply NHTSA
proof that all the Lenses and Reflectors plus all the Supporting Components of these three Lamp Designs, had indeed, been tested
to the many FMVSS #108 Federally mandated Outdoor and Physical Tests in order to guarantee everyone involved … especially
the public … against premature “Ultraviolet”*, “Hot/Cold Weather”, “Thermal Shock”, “Submersion”, “Grime Buildup” and “Road
Vibration” failures.
*Lens Material loosing its color and/or crazing
Of course, along with detailed Photometric Testing, “Real Life Endurance Tests” should also always be required so as to guarantee
the overall integrity of all components, in the Lamp Design … including any “LED” circuitry used … because … even though LEDs
may “claim” the capability of lasting a long time … their very vulnerable circuitry can, at any time, fail due to heat, moisture or UV
exposure. However, for whatever reasoning, none of these common sense, quality and safety assuring tests were requested by
NHTSA in these recent Investigations!
Further, these reports showed that there was absolutely no demand from NHTSA requiring Unified or Optronics to show Compliancy Data
for the always Mandated “3 Years … Facing South … at 45° … into the Sun … Florida/Arizona Testing”*, which helps to guarantee
“Outdoor Longevity”, which will guarantee all concerned against premature “Ultra Violet Color Fading” and/or, premature Heat
and Cold, degradation of the Lenses and Seals plus helps to guard against moisture and/or rust failures of the Electrical and
Physical Supporting Components.
*NHTSA still “mandates” that the 3-Year Color Fading, Weather and UV Tests must be performed “only in the States of Florida or
Arizona” and NHTSA still mandates that “Accelerated 3 Year “UV” Tests” are not acceptable to them. Detroit Auto Engineers (SAE)
or NHTSA? Engineers dreamt up this ambiguous and impractical test requirement 38+ years ago … which represents what I call, “The
Florida and Arizona, Working Vacation, requirement” … whereas … we all must ask … what’s wrong with “Real Life” color fading
and weather longevity testing performed in Michigan, or in Texas, or in New York … if simply interpolated for “Less Sun”
circumstances?
The Automotive Manufacturer’s Equipment Compliance Agency Inc. (AMECA) keeps an updated List of all plastic Lens Materials
that they can verify have been officially tested to the Federally mandated, 3 Year, (SAE J586) Outdoor Testing requirements.
AMECA’s website is www.ameca.org. NHTSA “recognizes” AMECA’s listings so that those using or selling products made from
“questionable plastics” … that are not on AMECA’s list … must be able to independently “prove compliance” to these Outdoor,
Fading and Heat/Cold Tests for all the Vehicle Lighting and Reflectors they’re installing, changing, or selling that end up in public use.
This 3 Year Test … plus several other quality and durability assurance tests, mandated by FMVSS #108 represent the many
Federal and “common sense” Physical and Photometric Tests that practically all? overseas Vehicle Lighting Importers and
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Manufacturers are currently totally ignoring. And to make
obvious violations of Federal Law and Common Sense.
matters worse … NHTSA isn’t challenging any of the most
Note too! The recent 50,000 Recalled Pairs of 7-Function “LED” Lights from “Optronics” were also not tested by NHTSA for real-life
“Thermal and Physical Shock” conditions nor were they tested for “Submersion or Dusty Road Applications”, nor were they tested
for disabling “Thermal Expansion/Contraction/Seal Failures” as required by Federal Safety Acts and SAE Quality Assurance
Goals. Without question, all of these common sense, necessary Tests should be absolutely required … whenever thermal, ultraviolet
and/or moisture vulnerability is obvious … so everyone involved is adequately protected from safety effecting, prematurely failing
… and non-repairable Vehicle Lighting … of any kind.
TLC #103B – What’s minimally required for OVER and UNDER 80” Trailers, RVs and Trucks?
To show what’s minimally required by FMVSS #108 for Brake/Turn and “Running Lights”*, we compare in our Sketches the
application of any of our 7 Function Lights along with the use of our #203, #327 and #205 (Wingtip®) Series “Running Light”*
products to example their best, most economical usage … while meeting Federal Compliance for all mandated “Running Lights” and
“Parking Reflectors” minimally needed for all over as well as under 80” Vehicles. A common Trailer outline is shown in our sketch,
but these applications could represent any RV or Vehicle. *”Running Lights” are – Tail, Sidemarkers, Clearance and I.D. Lights
We show the use of 7-Function Tail Light Assemblies that are FMVSS #108* Compliant and provides the always required (1)
Brake, (2) Turn, (3) Tail, (4 & 5) Rear and Side Pointing Reflector, (6) License and (7) Rear Located (side pointing) Side
*FMVSS #108 = Federal Motor Vehicle Safety Standard #108 is on the web … and for your convenience … we have placed a
Marker Light.
courtesy link on
our website - http://www.sierraproductsinc.com/
The use of our #205 WingTips® shows how lights and power can be saved when using properly, thought out, mounting positions.
Also, realize that the very important “Rear Facing Reflector” can be built into the Tail Light Assembly, or a Hermetically Sealed Rear Reflector
can be mounted where it most effectively represent the vehicle’s presence and width in any Parking Situation.
In Figure A, we use Two Separate Red and Amber #203 Lamps on each side for mandated Clearance Lights, and in Figure B, we’ve
substituted a “single” 2-Color, Red/Amber #205 WingTip® for these two lights; whereas, both arrangements fulfill thel Front
Pointing Amber as well as the (11) Rear Pointing Red Clearance Light Functions mandated by FMVSS #108 for Over 80”
vehicles. Further, both arrangements depict the “Widest Point”*, as well as the “Extreme and Overall Width”*, of the vehicle.
*Note - NHTSA (National Highway Traffic Safety Administration) and DOT (Department of Transportation) and the Federal Highway
Department use the terms “Widest Point” and “Extreme & Overall Width” interchangeably
The Sketch also shows that when only one (single) all Amber WingTip®* is mounted on a typical Trailer’s protruding Tongue …
Federally mandated requirements for necessary “Side Sighting Angles”* and Photometric requirements are indeed
“simultaneously met” for both the mandated right and left (9) Frontal (side pointing), Amber, Side Marker Lights, which also
have been mandated since 1969 for use on all vehicles to provide proper “Side Pointing Conspicuity”** in order to best avoid
nighttime (or foul weather) “T-Bone”, “Intersection Crashes” plus warn nearby Pedestrians of “presence” and length.
*All of which are specifically designed to be 360° Seeable and are Photometrically Compliant to FMVSS #108, whether in our “Solid” or
“Split Color” arrangements
**Side Pointing Conspicuity guarantees that Intersection Traffic and Pedestrians never loose site of the vehicle passing in front of them.
Bottom Line … when any pair of our “7-Function” Tail Light Assemblies are complemented with a pair of our 5-Function*,
Red/Amber WingTips® … and just one of our Dual, (Side Pointing), 360° All Amber, Tongue Mounted WingTips® … and a
pair of (6) Tongue Mounted Amber Reflectors … then … all Federally mandated Lighting and Reflector requirements** are
simultaneously met for any under or over 80 inches*** … less than 30 feet in length Vehicle.
*Dual color, fender mounted WingTips® add driver appreciated “Location Back Up Lights” and augment Tail & Side Lights as a bonus
**Over 30 feet in length, may require Mid Mounted (side pointing) Side Marker Lights and complementary Reflectors and possibly …
“Conspicuity Reflectors” as well
***Except for 3 I.D. Lights … if required.
Remember! The three Identification (12) “I.D.” Lights* and the (10 and 11) “Forward” and “Rearward” Pointing Clearance
Lights represent the only mandated differences** between what is required by FMVSS #108 for Under 80” as opposed to what is
required for over 80” width vehicles** whereas, all other nine mandated Functions … items (1) thru (9) on our “Legal Summary”
sheet … have all been mandated for “all” vehicles** since 1969 – no matter the length, width or kind*** of vehicle.
*Note, that our quality, yet inexpensive, all Lexan® #327 3 I.D. Light Bars provides unique “No Tools, Snap Out/In Bulb
Serviceability” … they’re not Throwaways! … plus, they have “Tough Duty” and Submersible (Air Trapping) capability,
as well as “built-in” Anti-Corrosion features that no other I.D. Lights in the Marketplace offer for a comparable cost!
**With no noteworthy exceptions as long as Over 80” and Under 80” “Effective Projected Luminous Lens Areas” (EPLLA) minimals are met
***Conspicuity Tape” is required on over 10,000 # Gross Weight Commercial Vehicles … but not on RVs/Motor Homes.
Also, be aware that many years ago, the three required (12) I.D. Lights* were first mandated by NHTSA for the purpose of
“Warning Identification” of wide and slow moving “Big Rigs”. Apparently, these were also considered needed on “very hilly”
roads so drivers coming up fast on the Rear of a Slow Moving Truck at the crest of a hill, would sooner rather than later see the
I.D. Lights and apply their brakes sooner when needed. Unfortunately, NHTSA still mandates that “Identification (I.D.) Lights” be
mounted “as high as practical” on Wide and Tall Vehicles, which … considering today’s relatively flat highways and the elimination
of sharp crests on hills … this mandate represents “Inconsequential to Public Safety” status and I.D. Lights would serve a much
more important “Presence Duty”.
*Centered & 6” to 12” apart
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Anyone taking the time to think about this subject would conclude that I.D. Lights … in order to be most “conspicuous” and most
helpful to general traffic safety … should now be mounted as close as practical to the average driver’s Eye Level … not, as
high as they can be mounted … which on Big Rigs can mean up to 14 feet above the pavement.
Further, we’ve also made it a “mission” to point out to all concerned that it would be very beneficial to general public overall
“Road Safety Conspicuity” if I.D. Lights were allowed to be “Optically and Physically Combined”* so they could also act as
an “Augment High Center Mount Stop Light**” (CHMSL) and/or as an “Augment set of Left/Right, close to Eye Level, Center
Mounted, Turn Signals”** … which, a couple of years ago, we Petitioned NHTSA to allow (not mandate!) … but we were
denied by NHTSA for their usual erroneous, non-sensible, arbitrary and dumb reasoning! More on this in later writings!
*or, at least … allowed to “share” the same Housing” and / or … the same Lens Areas
**both are common sense optional additions and would obviously be very effective in reducing “Up Close Traffic” associated accidents (crashes)
In summary, realize that by using any pair of “7-Function Compliant Tail Light Assemblies, along with only three of our
WingTips®” – OEMs can save three Lights and their $ cost for installation and wiring* for all their wider vehicles – and one
Light plus installation is saved* for all Under 80” applications. In both kinds of applications, the Trailer gains our valuable
“Location Lights” as well as mandated Forward and Rearward Clearance Lighting plus augment Side and Tail Light (bonus)
safety features.
*And the Energy to illuminate for the life of the vehicle
TLC #104B – Our “SERVICEABLE”, FIVE & DUAL Functions, Optically Combined #205 WINGTIPS®
Some prudent Trailer Manufacturers* have begun to adopt our 2 Color, #205 Red/Amber WingTips®* because these tough
Lexan®, one bulb Lights … when outboard edge fender mounted … point rearward as well as forward, thereby truly representing
the “Widest/Extreme Overall Width Point”*. They also provide three other bonus! augment safety functions, including
the valuable “Location Light” feature that will enhance the quality and safety of any Trailer or RV.
*Best mounted at extreme outboard locations on Fenders… but, can be legally, practically and conspicuously mounted other ≈”mid-locations”
Our WingTips® are unique in that just a “PAIR” of these all Lexan®, 1/2 RED / 1/2 AMBER*, 360° Visible Lights, simultaneously
provide both sides of any Trailer with FIVE (5) valuable SAFETY FUNCTIONS:
1.
“LOCATION LIGHTS” – Since WingTips are “specifically faceted” for optimum”mirror seeability”, they provide
surrounding drivers and pedestrians bonus! safety conspicuity that isn’t mandated by Federal Law … but should be!
“Location Lights” are best mounted at the “Widest Point” and nearest to average traffic eye level as practical to
allow surrounding drivers and pedestrians to vividly comprehend the “Presence” and “Extreme Width” of the Vehicle,
while also providing the driver better “clearance and direction perception” when backing up at night or in foul weather.
2.
When mounted near to eye level as practical … and while projecting plenty of Amber and Red Light to the sides at
Intersection Crossings provides the vehicle with Bonus “SIDE MARKER LIGHTS”* to better avoid dreaded “T-Bone”
intersection type crashes**.
*”Conspicuity” represents the 1966 Vehicle Safety Act’s “Main Objective” and is the basis for most of the FMVSS #108
Regulations
**Feds now call “Accidents” … “Crashes” … because many so-called “Accidents” are really avoidable!
3 & 4.
FMVSS #108 allows Optically Combining* of a single bulb design with a Red Lens, facing the rear and an Amber Lens facing
the Front … thus providing “BOTH CLEARANCE LIGHTS” and when mid (extreme outboard) mounted, they also truly
represent the “Widest Part”** and “Extreme/Overall” Width of any large vehicle. This arrangement also provides some
bonus “inboard and outboard conspicuity” to close up, and about to pass as well as to adjacent lane traffic … features
not currently mandated by FMVSS #108 … but should be.
*“Optically Combined” is a FMVSS #108 Term that allows the dual use of a Lens Area and/or dual use of the Illumination
Source (See TLC #118).
5.
The fifth function – outboard fender mounted WingTips®, provide a bonus pair of “AUGMENT TAIL LIGHTS” that nicely
compliment the Standard Mandated Tail Lights while most likely being positioned nearer to average traffic and
pedestrian eye level and mounted to represent Extreme Width better than most 7-Function (or 3 Function) Trailer Tail
Light Assemblies in use today.
Bottom Line … all FIVE of these additional Safety Features definitely help surrounding drivers and pedestrians to better see, and
remain consciously (and subconsciously) aware of this Vehicle’s Presence, Size and Location … as well as clearly depicting the vehicle’s
Widest Area*, Extreme Width* and Overall Width*. We can guarantee! that all end users … particularly experienced Trailer
Owners … will (sooner or later) thank those providing them with these kinds of bonus, grief-saving and expense saving features!
*NHTSA and Department of Transportation (D.O.T.) Terms that are used interchangeably
Our TWO FUNCTION, One Bulb, ALL AMBER, TONGUE MOUNTED SIDE (pointing) MARKER LIGHTS:
Also, note that just one of our all Amber WingTips® mounted on the Trailer Tongue, simultaneously provides both of the always
mandated Frontal (side pointing), Side Marker Lamps because both Left and Right functions are “Optically Combined” using
one bulb results in yet another Lamp saved as well as the lifetime energy savings. See TLC 103B and TLC 105B.
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In the past couple of years, we have found four Lighting Manufacturers/Importers illegally selling “Confusing” and/or “Exact
Copies” of our Patented and Trademarked Wing Tip® Designs. Included in these infringements is Optronics who have Tooled
and are currently selling cheaply made, exact looking copies of our Dual and Single Color, 360° FMVSS #108 Compliant
WingTip® Designs that undoubtedly violate our Patents, and perhaps Optronics is also violating our U.S. Registered Trade
Names?
We will be forced to file Patent and Trademark Infringement complaints against all those who remain “involved” in any
way of violating our Patents and Trademarks … Ask “Wesbar” (now “Cequent”) about our 5 week “Federal Trial” in
Milwaukee against Wesbar for “Patent Infringement” and “Product Disparagement” (with malice) where a Milwaukee Jury
found for us and against Wesbar … We will always defend our Inventions, Trademarks plus our Quality and Integrity
Reputation.
TLC #105B – Side Pointing, SIDE MARKER* LIGHTS … are for “Intersection Safety”!
The “1967 Vehicle Safety Act” resulted in the mandating of Front and Rear Side Marker* Lights for all Vehicles. Prior to this, all
vehicles entering Intersections at night (or in foul weather) … had only its’ Headlights and Tail Lights to warn surrounding
Traffic and Pedestrians, of its’ presence, length and width; which produced a significant safety problem because Tail Lights and
Head lights were only designed to project light primarily forward or rearwards. It had became very obvious that many
Intersection Crashes** could be avoided if all Vehicles were equipped with separate or Optically Combined lamps … that
deliberately project mandated warning light to the sides.
*Should, more descriptively, be called “Side Pointing Lights”
**Feds now use the term “Crash” rather than “Accident”
To fully comply to the intent of this Federally Mandated “Side Seeable* (conspicuity) Objective” … Vehicle Manufacturers should
always try to locate their, side pointing, Side Marker Lighting as near to average traffic and pedestrian eye level as possible
and spaced … no more than 30’ from each other in order to be FMVSS #108 compliant and “Conspicuous”** to all
Intersections drivers and pedestrians.
*Side Pointing Conspicuity guarantees that Intersection Traffic and Pedestrians never loose site of the vehicle passing in front of them.
**The Federal Term … “CONSPICUITY” … represents the “Main Objective” for all the Side Pointing and Rear Pointing
Lights & Reflectors mandated by FMVSS #108
As pointed out in TLC #104B … just one of our … Tongue Mounted, all Amber WingTips® simultaneously provides both the
Left and the Right, Frontal, (Side Pointing), Amber required Sight Scopes*. Also, note that any of our single bulb, 360°
viewable WingTips® … if strategically located … can additionally provide some appreciated, useful, economical and practical
Tongue area illumination – for the hooking and unhooking of the Tongue Winch/Hitch Mechanism and similar lighting aid choices.
See Sections TLC #103 and TLC #104.
*Side Pointing Conspicuity guarantees that Intersection Traffic and Pedestrians never loose site of the vehicle passing in front of them.
TLC #106B – Side Pointing and Rear Pointing REFLECTORS … “for Parking Safety”!
Most persons in the Trailer, RV and Big Rig Industries do not realize the “Parking Safety Philosophy” that’s behind the 1969
mandating of Rear and Side Pointing Reflectors for all vehicles and most do not realize why the 4 Side Reflectors (2 Red and 2
Amber) must be mounted near the extreme ends of the vehicle, pointing “straight out” to the sides - and a pair of Red
Reflectors are mandated to be mounted so as to point straight back - and all six are mandated to be projecting exactly
perpendicular or parallel to the lengthwise Axis* of the Vehicle.
*Unless specifically designed and “Lab Tested” to FMVSS #108 Standards for non-parallel, or non-perpendicular mounting angles
To fully comply to 1967 Vehicle Safety Act objectives … All six Reflectors should be mounted as close as practical to best
represent the extremities of the vehicle’s length and width and all should also be mounted as near as practical to the average
traffic eye level in order to be most effective (“Conspicuous”) in parking situations. Mounting mandated Side Reflectors high
up … or, at a non-approved angle … are violations of FMVSS #108 regulations and probably common sense as well. Of
course, other, non-mandated, “augment reflectors” can be mounted (pretty much) anywhere and at varying angles … but
understand!! … these Reflectors would not be considered “complaint” to FMVSS #108 mandates.
I have a Newspaper Article* with a photo of a parked “Big Rig” Trailer involved in a “Parking Lot Accident” that shows the tongue
of a large trailer that had No, Side Pointing (Amber) Reflectors. This accident tore off a Fireman’s arm because the driver of
the Fire Engine simply didn’t see this massive steel Trailer Tongue “sticking out” from the Trailer while rushing to a night time
industrial fire … thus, causing an unfortunate calamity and a terrible injury that really didn’t have to occur. Imagine how this
kind of oversight can represent a real life safety problem in any Vehicle Parking Lot and also imagine the tremendous liability that
can be involved in a loss such as this.
*We’ll mail a copy on request!
Note also that FMVSS #108 Compliant, Side and Rear Pointing Reflectors are already “built into” all of our “SP”, “SP-LL”, “SPCL” and “WA” Seven-Function Tail Light Assemblies, and when properly orientated and located, will, conspicuously and
compliantly identify the rear extremity and the width in any parking or “sitting on the shoulder” situation.
TLC #107B – Federally Mandated “EFFECTIVE, PROJECTED, LUMINOUS LENS AREA” (“EPLLA”)
FMVSS #108 … and Common Sense … mandates that traffic directly following and adjoining must be exposed to fairly
Contiguous, Large Lit Up Areas of properly directed “Light Rays” in order for adequate Brake, Turn and Lane Changing
signal responses.
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Federal Law mandates that single Brake and Turn Signals used
on all Over 80” Wide Vehicles must have an “EPLLA” of at
least
11-5/8 in² as required by SAE J1398 – ‘85*. The mandated Brake/Turn Signal “EPLLA” is reduced to 7-3/4 in² for Under 80”
Vehicles specified by SAE J586 FEB ‘84* and the 1994 Section § 5.1.1.26 addition. EPLLA mandates have been neglected for the
past few years and NHTSA has recently tried to more clearly define and verify EPLLA importance in their 2005 “Rewrite” of FMVSS
#108 (Docket No. NHTSA-2006-23634). *Check out “SAE” Specs and compare with the Federal, “Definitions” stated below:
Referring to the “Definition” Quotes from FMVSS #108:
§ 571.108 Standard No. 108; Lamps, reflective devices, and associated equipment
Effective light-emitting surface means that portion of a lamp that directs light to the photometric test pattern, and
does not include transparent lenses, mounting hole bosses, reflex reflector area, beads or rims that may glow or …
produce small areas of increased intensity as a result of uncontrolled light from an area of 1/2 degree radius
around a test point.
Effective projected luminous lens area means the area of the orthogonal projection of the effective light-emitting
surface of a lamp on a plane perpendicular to a defined Test Pattern direction relative to the axis of reference.
Unless otherwise specified, the direction is coincident with the axis of reference.
and:
§ 571.108 … Section S6.3 The term ‘‘functional lighted lens area’’ in any SAE Standard or Recommended Practice
incorporated by reference or by subreference in this standard, has the same meaning as the term ‘‘effective
projected luminous lens area.’’
also,
Note! That “EPLLA” … for Under 80” Vehicles … was increased from 5¾ in² to 7¾ in² by the below 1994 FVMSS #108
addition:
§ 5.1.1.26 Section … On a motor vehicle whose overall width is less than 80 inches:
(a) The effective projected luminous lens area of a single compartment stop lamp and a single compartment rear
turn signal lamp, shall be not less than 50 square centimeters (7¾ square inches).
Unfortunately, the above Definitions and the terms “Effective Light Emitting Surface” and “Effective Projected Luminous Lens
Area” (“EPLLA”) … are rarely understood by OEM Designers and Aftermarket Buyers.
Below, I’ve “tried” to write a couple of “clarifying paragraphs” … explaining the term “Effective Projected Luminous Lens
Area” using my humble vocabulary, which hopefully makes the “EPLLA” mandates easier to visualize and understand!
Imagine the usable light output (“Rays”) from any source of Illumination (Bulbs or LEDs), which are directed thru a
Fresnel Lens or are simply Reflected and/or Refracted using any combination of Reflective/Refractive Faceting,
which results in specific, seeable, lit-up areas that are effectively projecting “controlled” and distinguishable rays of
light, within the mandated “Test Pattern” … of 20° Left/Right; 10° Up/Down … but not beyond.
All the “Lit Facet Surface Areas” of a Test Lamp that are compliant to the official FMVSS #108 EPLLA Definition can
be “officially tallied” towards meeting the mandated “EPLLA” requirements of FMVSS #108. If the total of all
qualifying Lit Facet Surface Areas (pointing straight out) add up to at least 11-5/8 in² … the Test Lamp can,
legally, be used as a “Single, Brake or Turn Signal” on any Over 80”, or Under 80”, width Vehicle. However, if
only 7-3/4 in² (or under) … then the Lamp can be used for Single, Brake/Turn Signals on only, Under 80”
vehicles. If the Lamp has an “EPLLA” total below 7-3/4 in² … it does not legally qualify for any U.S.A., or
Canadian mandated Single, Brake or Turn Signal use, except perhaps, for 3rd Brake Light (CHMSL) or Motorcycle
uses.
Always keep in mind when tallying up officially qualifying “EPLLA” … you must disregard all “Faked”, “Non-Operative”,
“Misdirecting & Transparent Areas”, that are producing small areas of increased intensity as a result of uncontrolled
light”.*
*Quote from above Definition
Also, as you can witness in real-life observations … to be compliant to mandated “EPLLA” requirements … it will take many standard
20° Conal Output LEDs - not just a few … to meet “EPLLA” requirements for a single Brake and Turn (Lane Change) Sized.
See TLC 111B for more details
TLC #108B –Actually “SEEING EPLLA” … Desk Top Test!
Obviously … “EPLLA” is not an easy mandate to define, however, the “EPLLA OBJECTIVE” is fairly easy to comprehend
knowing that NHTSAs early extensive Testing showed that humans must see “Distinguishable”, “Contiguous”,
“Significantly Large”, and in total, “Very Conspicuous” Signals to assure that they (drivers and pedestrians) quickly and
adequately react to all safety signals generated.
“Human Reaction Testing” accomplished many years ago by NHTSA (and SAE?) disqualified Brake and Turn (Lane Changing)
Signals emanating from small, non-contiguous areas … because, it was found that small Brake, Turn and Tail Light lens
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areas did not have the capability of triggering the necessary
and immediate reactions from humans … as a result,
Minimal “Lit Areas” (that is…“EPLLA”) and a minimal range of Photometric output covering defined “Test Patterns” were
derived and mandated for all Brake and Turn Signal Manufacturers to comply to.
“EPLLA” can be fairly accurately estimated for any Brake and Turn Signals by simply tallying up all the obvious lit up
“Effective Light Emitting Surface Areas” that, indeed, projects seeable light when viewed within* the mandated 20°
Left/Right, 10° Up/Down** “Test Pattern” (See TLC 107B).
*not beyond
**Under special circumstances …only 5°
Downward is mandated.
To circumvent a complicated mathematical tallying process of “EPLLA” areas … a simple, yet, accurate enough, “Desk Top,
Eyeball Viewing Test” … can be easily performed by simply “lighting up” (using a simple ±12 Volt Battery Charger) any EPLLA
questionable, “Incandescent” or “LED” Brake/Turn Signal Lamp. This approach makes it possible for anyone to fairly, accurately
tally what Facet Areas properly light up and are projected within the Test Pattern Scope; while at the same time, showing up
all of the “Dead”, “Overlapped”, “Transparent”, and “Beyond Test Pattern” areas that can’t be recognized by the above
“EPLLA” Definition of FMVSS #108.
By marking over (or covering over*) all the “effective Light Emitting Facet Surfaces” that are, indeed, projecting seeable,
controlled light within the Test Pattern Limits … a Desk Top Test will fairly closely reproduce what, indeed, will be seen by
*We use small pieces “of ¼” x ¼” Tape”, which works adequately
following, passing and adjoining lane drivers.
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are seeably projecting controlled light rays to only within
“Mark Over” or “Cover Over”* only obviously Lit Facet Areas that
the “Test Pattern”, while disqualifying all the “Inactive”, “Dead”, “Uncontrolled”, “Glowing”, “Wrong Direction”,
“Overlapped” and “Transparent” areas … so these are not tallied** in the final EPLLA. You can use a simple protractor or a
“distance ratio system” for estimating … about 5° to 10° apart “Eyeball, Check Points” within the 20° Left/Right; 10°
*Can also use a “Temporary” Marking Pen, so Lens isn’t ruined by permanent ink
Up/Down mandated “Test Pattern”.
**Treat these areas as if they don’t exist
Remember - you can add up only Facet Areas* that are distinguishably lit and only Facet areas projecting within the mandated
“Test Pattern”. Also, recognize that “overlapping” Facet outputs can add only the resultant overlapped areas to EPLLA even if a
particular facet projects at several different angles within the Test Pattern. *Tallyable EPLLA Areas never include “Transparent” Lens Areas
By using this fairly simple estimating system and knowing it takes 16 “complete” (not overlapped) Pieces of ¼” x ¼” Tape (or ≈ ¼”
x ¼” Mark-Over’s) to yield One Square Inch (in²) … anyone can fairly accurately estimate what EPLLA any Brake/Turn Vehicle
Light is generating, as long as only the “seeably lit” and properly directed Facet areas are added.
Further, be aware that the obvious “Dead Rings” that always exist to some degree between “Lit Up” Fresnel Rings … have
(since 1969) been allowed by NHTSA* to be added into the “EPLLA” total tally, as long as all these dead areas don’t
represent more than about one-third** of the total active Fresnel area being credited towards “EPLLA”.
*“Grandfathered in”
**Ask NHTSA’s “Regulation Department” for the exact percentage of “Dead Fresnel Area” allowed
Further, know that all the “other” obvious Dead Areas between each set of Fresnel Rings and all other obvious Dead Areas
… are not, legally, addable into the “EPLLA” tally for compliancy determination. After tallying up only the FMVSS #108
qualifying “EPLLA” areas of the Test Lamp … you’ll then have a good idea if the mandated “EPLLA” requirements are going to
be met.
TLC #109B – INVENTORYING both 7-3/4 in² and 11-5/8 in² (EPLLA) BRAKE/TURN LAMPS
The “EPLLA” mandate for Under 80” Wide (Single) Vehicle Brake/Turn Signals is only 7-3/4 in² compared to 11-5/8 in² for Over
80” Vehicles. Considering this … most Trailer, RV, and Trucking OEM’s … as well as Aftermarket and OEM Lighting Suppliers …
must ask themselves … “Why would we consider buying and inventorying legally, Compliant 7 or 3-Function* under 80”
Lighting Assemblies that have only 7-3/4 in² of “EPLLA” qualifying Lens area when we know we are also being required to
buy and warehouse 11-5/8in² “EPLLA” Lensed Area Lamps. This kind of “Two Sized” 7 and 3-Function* Inventory
approach doesn’t save much money, and greatly complicates inventories, and therefore is simply not practical for most OEM and
Aftermarket Suppliers to consider! Logical conclusion! … all Brake/Turn Signals inventoried should have a minimum of 115/8in² of “EPLLA”.
*That is, the popular 6” Ovals and 4” Round 3 Function “Big Rig” Type Lights, both of which have ≈ 12in² EPLLA’s when no reflector area is used
TLC #110B – Most “LED” 3 + 7-Function Lights are NON-COMPLIANT to “EPLLA” Requirements
In the case of the latest* “Optronics” 7 and 3 Function Lamp Recalls … apparently, Optronics still thinks that by simply projecting
the ≈20° Conal Output from a small number of LEDs thru a “Transparent Outer Lens” … they can somehow?, magically, increase
their deficient “Effective Projected Luminous Lens Area” (“EPLLA”). Their latest Recalled 7-Function Lights use only fourteen
rd
3/4” diameter “Fresnel Ring, Sets” illuminated by fourteen fairly powerful LEDs.
* 3 Failing Design in 2 years … all are being
“Recalled”
The qualifying “Effective Light Emitting Surfaces Total” for this array of 14 Fresnels produce a maximum of 14 x Π (Pi) x (3/8)²
(Radius Squared), or only 6.2 in² of EPLLA; which is a long way from the 11-5/8 in² needed to comply to FMVSS #108 Mandated
Law for Single, Over 80” Brake and Turn (Lane Changing) Signals.
Keep in mind … that all of the “Transparent and “Dead” areas between these Fourteen 3/4” Diameter Fresnel Ring Sets, as
well as all the areas between the Fresnel Ring Sets and the outer lens perimeter, do not … by definition!” qualify as
“Effective Light Emitting Surfaces”, and therefore can not be tallied for “EPLLA” compliance.
These fourteen, 3/4” Diameter (.44 in², each!) Light Emitting Areas are all the “EPLLA” that Optronics can squeeze out of these
typically limited … ≈20° Conal Output* LEDs, representing what we call a “Narrow Projection Handicap”, which all LEDs suffer
from. The only way to compensate for this handicap is … to use many more LEDs to attain necessary compliant “Effective
Projected Luminous Lens Area”.
*A 20° Cone Output creates only small amounts of light, where believe it or not! “Incandescents” project ≈ over one hundred, 20° Cones of Light
This Narrow 20° Conal Output of Light from LEDs is a good feature for “Traffic Light” type uses, but it’s proving to be a serious
detriment for the manufacturing of inexpensive, yet FMVSS #108 compliant, Brake and Turn Signal Vehicle Lighting.
Furthermore, by deliberately molding in fake and/or non-operational Fresnel Rings, or other “Inert Faceting”, or by
pretentiously using transparent and non-counting areas that don’t effectively gather and redirect light to within the
mandated 20° Left/Right; 10° Up/Down “Test Pattern” … represents “Illegal Deceptions” and outright Safety Hazards that
should initiate immediate Recalls by NHTSA. These kinds of Illegal deceptions are now widespread over all of the U.S. and
Canada, etc. … just look around!
After three huge, embarrassing and costly Recalls, you’d think Optronics would try and find out what “Effective Projected
Luminous Lens Area” really means, and then produce Photometric compliant … as well as EPLLA Compliant … as well as
Lasting products as honorable U.S.A. Lighting Manufacturers have produced over the past 4 decades!
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TLC #111B – “LEDs” project ONLY ±1% of “GATHERABLE LIGHT” that Incandescents project
Most “LED” … OEM or Aftermarket … Single, Brake/Turn Signal* Lighting that are now available in the marketplace … will
almost certainly be “EPLLA” non-compliant when all the obvious “Non-Contributing”, “Dead”, “Transparent”, “Beyond
Test Pattern”*, “Overlapping” and “Faked” faceted or not faceted areas are subtracted from the entire exposed outer lens
area … resulting in a total EPLLA that is much below the 11-5/8 in² area required to meet FMVSS #108 mandated “EPLLA”
requirements* for over 80” wide, Single Brake & Turn Signal uses.
*Must be within the mandated 20° Left/Right; 10° Up/Down “Test Pattern” in 7 Function Tail Light Assemblies
Remember, common “Light Emitting Diodes” (LEDs), produce only a very directional and very small cone angle of
measurable light … usually represented by a tiny ≈20° “Conal Shaped” Output … and that’s all.
This limited and very directional output represents only about one percent of all the directions of output that always emanate
from the length and circumference of the typical Incandescent Bulb Filament. This means that over a hundred 20° Cones of
Output Light Rays are generated by the typical #1157 or #3157 Brake/Turn Bulb Filament compared to the single ≈20° Conal Output of a
typical LED!
This “very limited and very directional, Laser-Like* Output” is why “LEDs” draw less energy and, this is also why it takes so
many LEDs to meet the mandated “Effective Projected Luminous Lens Area” (“EPLLA”) Requirements of FMVSS #108.
*very directional … more or less, straight out
Therefore, by using just a few “LEDs” … where each puts out only a tiny ≈20° Cone of EPLLA qualifying light … the
typical, very compact*, 7 or 3-Function “LED” Lamp now being sold in the marketplace will almost always fail the
mandated “EPLLA” requirements of FMVSS #108. *as opposed to the massive sized (and very expensive) Auto and SUV Tail Light
Assemblies.
To solve this inherent “LED” problem, “many” LEDs must be used, and the many used … must be properly lensed so every LED
properly projects its’ output within the mandated Test Pattern, and at the same time, not loosing significant output because of
“LED Heat Build-Up”. It’s time everyone concerned realizes that just projecting some Red Dots of light … even if “Photometric
Compliant” … does not guarantee a FMVSS #108 “EPLLA” Compliant Brake or Turn Lamp.
TLC #112B – “ILLEGAL DECEPTIONS” everywhere! … NHTSA says “Go Ahead” … “HANG
YOURSELF”!
By pretentiously molding in “Phony” and/or “Non-Qualifying” Refractive Fresnel Rings, or other obvious Inactive and Ineffective
Faceting on the inside or outside of a Lamp’s Lens Surface does not mean that the entire lens area qualifies for “EPLLA”
compliance.
To meet “EPLLA” compliancy using LEDs … all qualifying Effective, Light Emitting Faceting will likely receive “LED” “Light Rays”* at no
more than a ≈10° angle and then the Rays must then be properly redirected (Refracted/Reflected) so as to project all to following traffic
“within” the limits of the Test Pattern angles … meaning that “Rays” directed beyond 20° Left/Right and 10° Up/Down don’t qualify as
*Imagine “Rays” of Light
EPLLA usable area.
Lamp Manufacturers that leave out needed LEDs*, or produce fake holes* where “LEDs” should be … but aren’t … represents
serious illegal practices* and the resultant consequential Public Safety Hazards must be recognized and dealt with by
NHTSA.
*Obvious and seeable, Illegal, practices currently used by many short-lived, “fly by night” “LED” Lamp Manufacturers are
blatantly violating “Mandated Federal Law” while being essentially unchallenged by NHTSA’s Compliance Department – Why is this?
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“EPLLA, Non-Compliances” are currently being marketed by
most (if not all) Manufacturers of “LED”, 7-Function and 3Function Lamps. Combine these obvious Non-Compliances with other ongoing LED problems, such as Heat Degradation,
Moisture Sensitivity and Color Fading cause Longevity and Serviceability problems and you’ll begin to see the many serious
quality, safety and liability problems that many Vehicle Manufacturers and Lighting Distributors are unknowingly becoming
involved in.
If you have the time, you should read about the latest? Optronics Federal Recall for their 4 inch round LED Lights sold in 2002.
Their extreme Non-Compliances can be partially blamed on the inherent confusion and ambiguous and erroneous wordings of
current FMVSS #108 Regulations as to what exactly is a double or triple sectioned lamp using common sense logic.
I find it very troubling that NHTSA seems to be continually following an “uninformed” and “who cares” attitude towards the
many FMVSS #108 safety degrading non-compliances that are now absolutely obvious all over the U.S. thereby encouraging
U.S. Vehicle Lighting Manufacturers as well as “OEM” users into thinking they can (with Legal and Liability immunity) Import
and supply the public illegal, cheapened and unreliable Vehicle Lighting Products with no consequences. This “head in the sand”
attitude is simply fanning safety compromises and promoting “Liability Suicide” for all concerned … except NHTSA … who
can’t be sued for their part in this mess; however, check it out with your Lawyer - everyone can be sued for any and all lighting
non compliancy “Crash Claims” that they can become involved in.
Further, it’s absolutely nonsensical and totally irresponsible that NHTSA doesn’t even try to effectively inform Lighting and
Vehicle Manufacturers about the millions of Non-compliances already “everyday obvious” to them.
NHTSA could easily warn the few Vehicle OEM Trade Organizations of what non compliances their members should be “looking
out for”. They should also be routinely providing everyone in all related industries with thought out, easily understood
“warning and policy writings” plus thought out “Legal Interpretations” while also providing accurate, effective, to the point,
“visual aids” to show everyone concerned “what is FMVSS #108 compliant and what will last” versus what represents proven
and/or obvious quality and longevity problems. This kind of information should immediately be distributed by NHTSA to help all
concerned recognize and address all vehicle lighting problems before OEMs and Distributors become unknowingly involved in
Liability problems they would have just as soon avoided.
NHTSA’s current practice of simply “letting the unaware and uninformed … hang themselves” is unacceptable. This
represents an absurd and inept attitude that I intend on complaining about … in writing … as well as in person … to several
influential Senators and Congressional personnel, while also “reporting” these incompetence’s to any interested Congressional
Committees or “Watchdog Groups”… that shows a desire to eliminate waste, increase road safety and improve efficiency in
government.
A few years ago, I gave a “Congressional Record” talk before a DOT Congressional Committee (in Washington, D.C.) on the
subject of how to save money while more effectively administering FMVSS #108. I was surprised to find out that this
Committee of both Republicans and Democrats were not particularly interested in saving money, but I did get some
“temporary” satisfaction because my paper was printed in the “Congressional Record” and some improvements were
made.
We have in our archive files; several official “Legal Interpretations” issued by NHTSA authorities over the past ≈30 years where for
instance … NHTSA reiterates the importance of adequate “Effective Projected Luminous Lens Area” coupled with
emphasizing the importance of adequate and specifically aimed Photometric outputs. Problem is! - this kind of information
is not distributed to Vehicle Trade Groups who really need to be aware of the associated facts. Just a copy of the Question sent
in* with NHTSA's reply outlining a Real-Life example and sent out to but a few Vehicle Manufacturers Trade Organizations (and also
put on the web*) is all that’s necessary.
*Questions asked NHTSA are not put on the web – just NHTSA’s answers
FOR INSTANCE: Here’s a noteworthy example that NHTSA could effectively use to demonstrate the point that “MANY LEDs are
rd
NEEDED” to meet the “EPLLA” requirements for 3 Brake (CHMSL) and conventional Brake/Turn Signal Lights …
The popular General Motors “LED” … “Center High Mounted Stop Light” (CHMSL) used since 1995 and installed on
millions of GM® Van and SUV Roof Tops, use a total of 40 (forty) high quality “LEDs” arranged in a straight line array*
that provides just over 4.5 in² of, “official qualifying” “EPLLA” area, which fulfills the 4.5 in² “Effective Projected
Luminous Lens Area” requirement of FMVSS #108 mandated by NHTSA for CHMSLs.
*each illuminating source is represented by … no more than a 3/8” Diameter Set of Fresnel Rings providing Pi(3/16)²X40 ≈
4.5in² of “Effective Projected Luminous Lens Area” (EPLLA)
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Comparably – it would take 40 =
?_ or ≈ 70 (seventy)
and 40 =
? or ≈ 100 (one hundred) of comparable size
and
4.5 7.75
4.5 11.75
quality “LEDs” to meet FMVSS #108 Compliancy for the, 7-3/4 in² “EPLLA” (70 LEDs) and the 11-5/8 in² “EPLLA” (100
LEDs) covering under 80” and Over 80” (respectfully) requirements for a Brake or Turn Lamp to officially comply to FMVSS
#108 for mandated “EPLLA” requirements.
TLC #113B – “NMMA” and CANADIAN MISINTERPRETATIONS of FMVSS #108
The “National Marine Manufacturers Association’s (NMMA) Trailer Certification Program” and the Canadian D.O.T. are
incorrect in some of their Interpretations of U.S.A. FMVSS #108 Regulations. U.S.A. Federal Law prevails* over all State and Local
laws on the subjects covered by FMVSS #108 … as a result …no Government in the U.S.A. can make Vehicle Lighting Laws
“for the public” more or less stringent than what FMVSS #108 mandates … this restriction applies to all State, City and County
Governments and, we believe, because of “Restraint of Trade” and “Antitrust” Laws … this type of rationale applies to Trade
Organizations as well. As to Canada … having “Identical Laws” to ours – but not! See TLC 101B!
Below are our Comments on what we see as mis-interpretations of FMVSS #108 allegedly inferred by NMMA and/or Canada
Inspectors:
1.
Our #205, Single Bulb, “Optically Combined”, all Amber, one bulb WingTip® mounted on a Trailer Manufacturer’s
typical Trailer Tongue*, does indeed, legally fulfill all “Visibility Scope” and associated “Photometric Output”
requirements of FMVSS #108 simultaneously for both Left and Right, Forward (side pointing) Side Marker Lights**.
*Side Pointing Conspicuity guarantees that Intersection Traffic and Pedestrians never loose site of the vehicle passing in front of them.
**See Section FMVSS #108, S5.4.
However, we understand that NMMA and/or Canadian? Inspectors are saying some Tongue Mounted applications they’ve
witnessed using our Dual Function (both sides) #205 WingTips® are not compliant to FMVSS #108 Regulations;
therefore, are not fulfilling the intent of the 1966 Vehicle Safety Act … which is untrue and, NMMA and/or Canada? must
stand liable for any costly results from any insinuations that this is an “Illegal, Optical Combination application”.
Our concept of using one long life bulb to light up both sides of the Trailer Tongue Area also “saves energy” because this
approach saves the electricity required to energize a second, “superfluous” Side Marker Bulb Filament – which can
amount to a significant amount of saved energy (and gasoline) when totaled over the lifespan of a typical Trailer.
2.
The specific “39-60 inch”? lateral mounting “set back” from the Tongue’s Tip that Canada (and NMMA?) insists upon
for Amber, Frontal (side pointing) Side Marker Light positioning, is erroneous and, indeed, is not required* by U.S.
FMVSS #108 mandated law; whereas, “as far forward as practical” is still the current mandated FMVSS #108 location
requirement.
*It’s allowed by FMVSS #108 … but not mandated!
Remember! that FMVSS #108’s main goal for side pointing Side Marker Lights is to warn intersection traffic (and
nearby pedestrians) of a Vehicle’s “presence” and “length”. The “distance apart” objective is not clearly* written into
FMVSS #108, but it can be concluded that all Side (pointing) Marker Lights on any Vehicle must be placed “no further
apart than 30 feet” from each other, while at the same time, representing the entire length (ends) of the Vehicle.
*More on this issue in future writings
Yes! – Perhaps Canada’s Front Side Marker Interpretation for FMVSS #108 … of “39 to 60 inch back from the Hitch
Point”, is easier to delegate compared to the more ambiguous “as far forward as practical” requirement … but,
nevertheless, neither “NMMA” or Canada can’t derive their own U.S.A. interpretations … especially when it’s realized
that their erroneous interpretations can result in unnecessary cost and energy consumption to USA (and Canadian)
citizens.
3.
“Conspicuity Tape*” is only mandated by FMVSS #108 for U.S.A. “Big Rigs” and the like… that is… over 10,000# gross
weight Commercial Vehicles however, over 10,000# RVs are excluded. Therefore, if NMMA or Canada is telling OEMs
that Conspicuity Tape is required by U.S. or Canadian law** … when it isn’t … this results in yet another superfluous
expense. *or equivalents
**Beyond the 4 side and 2 rear Reflectors mandated by FMVSS #108
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4. Also, contrary to what (allegedly) “NMMA” Inspectors
have been telling “NMMA” Certification Program applicants
and members … our Rear-Facing and Rear Side-Facing Reflectors (built into our 7-Function Assemblies), do provide the
mandated “20° Left to 20° Right “Visibility Reflection Scope”* … required by FMVSS #108 … when mounted
perpendicular and parallel (respectfully) to the vehicle’s axis. Our Reflectors are indeed Compliant to the FMVSS
#108 “Scope Requirements”, contrary to any doubts allegedly claimed by NMMA Inspectors.
*as long as trailer components don’t shadow this Scope
In summary, adding unnecessary expense* to U.S.A. made Trailers, RV’s, and Big Rigs because of NMMA, Canadian or others
misinterpretations of our Federal Law, clearly violates the intent of the 1966 Vehicle Safety Act and other active Federal
Regulations and Treaties, and therefore, must not be tolerated.
*which would include very expensive Border Crossing confrontations
TLC #114B – The “EIGHTH FUNCTION” Addition
When required, we can add, at any time, the “Eighth Clearance Light Function” to any of our 7 Function Tail Light
Assemblies by simply using an additional small bulb and perhaps a small dedicated lens area that indeed does add a
Compliant Rear-Pointing “Clearance Light” to the 7 existing Functions. However, realize that an eight function Tail
Light Assembly … ours or anyone else’s … must be mounted to represent the “Widest Part”* … that is … the “Overall”*
and “Extreme” Width*, of the Vehicle in order for this combination to be compliant with FMVSS #108.
*Used interchangeably by
NHTSA and D.O.T.
th
To add the 8 function in our 7 Function Tail Light Assemblies, we simply add an additional* small bulb to fulfill the rearward
th
Clearance Light requirement of FMVSS #108 because this 8 Function is “not” allowed by FMVSS #108 to share (Optically
Combine) with the Tail Light Filament of the most often used #1157 or #3157 Bulb, even if the 7 Function Lamp is mounted to
truly represent the “Widest Part” of the vehicle, which of course, causes a redundant Clearance Light circumstance where
*See Section FMVSS
power for two bulbs rather than one must be provided by the Tow Vehicle for the life of the Trailer.
#108, S5.4
In direct contrast, be aware that the Tail Light Filament of say a #1157 or #3157 Bulb “can” be … and always has been allowed by
FMVSS #108 … to be “Optically Combined” so this filament can compliantly also represent the Side (side pointing) Marker
Light whereas “both” the required Tail Light and the Side Marker light are illuminated using just one lit filament rather than two.
For the past 26 years … we have provided this “8th Function” to OEM customers that “officially” needed it* by simply adding an extra
common #168 Bulb and Socket to our 7 Function Light Assemblies. However, recently we’ve been trying to sell our OEM customers
on the Idea of saving the additional ≈40¢ (times two) expenditure and applying the savings toward using a pair of our Five (5)
Function WingTips®, which when mounted on the outboard top edge of their Fenders, fulfills not only both the Rear and
Forward mandated Clearance Light requirements, but at the same time, provides an appreciated “Location Lamp” placed fairly
close to eye level elevation, so it can be easily seen in any Rear View Mirror system for safer backing up at night or in foul weather.
*Most OEMs now use Fender Mounted Clearance Lights on their over 80” trailers, which generally is close to “Extreme Width”
At the same time, this extreme outboard mounting position truly represents the “Widest Part”** and Overall** and Extreme**
Width of the Vehicle to following, passing and to side traffic, plus nearby pedestrians … while only using power consumption for one
bulb! See TLC #104B.
*3 terms used interchangeably by NHTSA and D.O.T.
TLC #115B –“LEDs” SHOULD LAST! … But, will their CIRCUITRY & SEALING METHOD?
Recently, we’ve photographed and tested many quite expensive, “in use”, 3 and 7-Function “LED” Stop and Turn (lane
changing) Lamps including many failed CHMSLs … where because of Seal Failure … have prematurely (partially or totally) quit
working, and in most cases, are also, displaying “trapped” moisture droplets behind their also Sun Faded Lenses. We even
found a number of high-priced, and supposedly, high-quality Glass Lensed “LED” Emergency Lamps mounted on new, $200,000+
Fire Engines … where 40+% of these very expensive “LED” Lights already had seeable water droplets* trapped on the inside
*Thus, 100% humidity
surface of their Glass Lenses.
It’ becomes apparent to anyone taking the time to study outdoor used LED Light Designs … that sooner or later, “seal failure” leads
to water (and/or 100% Humidity) getting inside the lamp, which … “first, degrades” … and soon, “fully destroys” the “LED”
Electronic Circuitry that’s needed to keep the “LED Array” illuminated.
So what good is a PROMISE of a LONG “LED” LIFE? … which is basically the only feature that “LED” Lighting Manufacturers have to
brag about … if, in reality, the LED Circuitry can’t be reliably protected from Heat and Moisture degradation so that their LED
Lighting can be “Unconditionally Guaranteed” by a reputable U.S.A. company for at least, 10 years of normal, uninterrupted
use?
Furthermore, take notice of how a fading and/or partially lit* “LED”** lamp … that’s wet inside … and has Lenses and Reflectors
internally coated with grime appears to the public. Their obvious high failure rate, non compliancy record and Non-Serviceable
*Looks like “missing teeth”
**or even Incandescent Lamps for that matter!
Designs degrades any Vehicle!
On any given day, anyone can easily find, anywhere in the USA and Canada, already in public use … all kinds of “LED” CHMSLs and
other Brake/Turn LED Lamps that are partially or totally disabled from water infiltration, which was, most likely, “sucked in” when
the Lamp Assembly was “super heated” from extended use … in hot outdoor temperatures … while gaining even more heat from
the Sun’s Ultraviolet Rays … and, most probably … from a “combination of all three”* … and then, imagine! … all of a sudden …
this entire “Hot” Lamp Assembly is totally inundated with cold water … from a sudden rain storm … a garden hose … from a Car
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Wash nozzle … or by being totally submerged at a Boat Launch
Ramp.
- 14 *Such as can be caused by a common Traffic Jam on a
hot, sunny day
Under real life, accumulated “Hot” outdoor conditions … which will sooner or later be applied to all Trailer and RV Lighting … the typical
“Sealed” Multi-Function LED or Incandescent Lamp will be drastically “thermally shocked” and thereby, instantly collapse the
trapped air inside, resulting in water being literally “sucked in” through any tiny factory crack or later acquired imperfection in the
Factory Seal. Realize that no matter how good the “hermetic factory seal” is designed … it will most likely succumb to the heat
generated, instantly changing negative and positive pressures that unprotected outdoor vehicle lights are subjected to regularly.
Under these conditions, “Water Suck-In” can take place thru any tiny flaw in any temporary or permanent Seal used because the
cold water that … from time to time … will be engulfing and “chilling” the entire Lamp will also … sooner or later … be flowing across
any flaws in the Seals or across “stress cracks”, which are generated in most all Hermetic Seals from repetitive, thermal lens
flexing* forces.
*expansion/contractions
Factory Imperfections and vulnerabilities are inherent in any inexpensive (or even expensive) Hermetic* Sealing** method
and can easily appear after just one (or a few) drastic thermal expansion and contraction cycles … which, in reality … is nearly
an impossible problem to avoid when trying to design “Serviceable, inexpensive, 100% Waterproof” Multi-Function Lamps
that are fully exposed to all the outdoor Elements while also experiencing instantaneous, 100+°F thermal changes from
submersion or inundation.
*Hermetic means “Air Tight”
**Remember the “Challenger’s” O-Ring problem?
Bottom line - you can bet that nearly all Hermetic Seals will … sooner or later … allow some resultant water to leak inside
the Lamp or into the LED Circuitry Chamber so you must consider, what will be the effect of this water and resultant 100%
humidity* … on the insides of the Lenses/Reflectors and on the very water-sensitive “LED” Circuitry, while also
*and deposited “grime”
considering the unavoidable “Disabling Rusting” of inside Steel parts.
TLC #116B – Did you Know? … WIRE INSULATION … CAN also LEAK!
Be aware that instantaneous differential pressures caused by sudden 100°F+ Temperature changes can actually force air as
well as water through the inside voids of any Trailer Wire Insulation.
When a “Truly Hermetically Sealed Chamber” is absolutely required, the “Wire Strands” entering the Sealed Chamber, must not
have any insulation gaps in order to guarantee an airtight (hermetic) seal … meaning that each “Whisker” of any typically
used Stranded Wire must be reliably “Potted” to guarantee an always working Hermetic Seal.
If only the outside surface of the Insulation Jacket is Potted, sufficient paths will still exist for water and air to be transported
back and forth inside the Insulation Jacket because of extreme thermal/pressure variables, which are commonly present in any
“LED” or Incandescent “hermetically sealed” outdoor application.
TLC #117B – “RED LIGHTS FACING FORWARD” … Allowable or Not!?
We have been asked if we think … NHTSA will allow “Augment” Red Lights to be mounted so they can be seen by “Forward” and
“Passing” (in the opposite direction) Traffic, which would, indeed, be the case if a 360°, Visible, “Dome Like” Red Light was used
on the top or on the outboard side of a typical “Guide On Post”, which some Boat Trailer owners like to use for helping them
more easily and more accurately “Float Position” their Boat over the Trailer Pads before extracting the Trailer from lake or sea
water.
We see nothing wrong with this, as long as the forward pointing Red Light output is “minuscule” and “incidental” because this added
light in this position (whether Red or Amber) would obviously make the Trailer’s “Extreme Width” and “Presence” more conspicuous to
passing, adjoining lanes, and Intersection Traffic as well as to nearby pedestrians … but then we would have to define “miniscule” and
“incidental”, which NHTSA would probably not agree with. Therefore, we’re telling everyone that asks us … “NHTSA doesn’t want to
permit any significant pointing forward “Red” Light of any kind, which will obviously occur when using a 360° seeable, Red light put on a
“guide on post” that is not properly shrouded or “split” in color using a Forwards pointing Amber* Lens and a Rearwards pointing Red Lens.
*Forward pointing Clearance Lights are mandated to be “Amber”, not Red.
To address this problem, we suggest that OEMs use our one bulb, “Split Color”, 360° … 180° Red to the rear … 180° Amber to the
front #205 WingTip®, which we’ve specifically designed with the FMVSS #108 mandated Frontal and Rearward Pointing
Clearance Light mandates in mind … thereby, also providing a legal, FMVSS #108 compliant pair of Clearance Lights as well as
Augment Tail and Side Marker Lights that can “conspicuously” be seen by Traffic and Pedestrians in both Forward and
Rearward as well as to the Side and Rear directions. In addition, this arrangement can be seen “Straight Up”, which … in the
case of Boat Trailers … that’s taking advantage of our Air-Trapping Submersible feature when on “Submerged Fenders” … also
helps position a Boat in the center of the trailer before extraction from lake or sea water – even when these lights are submerged*.
*Remember, our #205 WingTips® are also Submersible (Air Trapping) plus they’re still Bulb Serviceable
TLC #118B – “OPTICALLY COMBINING” … Use this allowance to SAVE Money & Power!
As pointed out in TLC #103B and #104B … our Single, all Amber 360° FMVSS #108 Photometric Compliant, Tongue Mounted,
“Two Way (side pointing) WingTip® Combo Side Marker Light” takes advantage of the “Optical Combination” allowance written
into FMVSS #108 … which can simultaneously project a 90° “Test Pattern” (covering from 45° Forward to 45° Rearward*) of
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Amber light to both Left and Right sides; thus compliantly
and conspicuously lighting up both sides of the Trailer
Tongue as FMVSS #108 requires for avoiding Intersection, and “T Bone” type Crashes that could come from either the
Driver’s or Passenger’s side.
*If a full 45° is needed – which depends on other Side Marker positions
Realize that FMVSS #108 … for many years has allowed “Optical Combinations” except for what’s outlined below:
Section S5.4 Equipment Combinations. Two or more lamps, reflective devices, or items of associated equipment may
be combined if the requirements for each lamp, reflective device, and item of associated equipment are met, with the
following exceptions:
(a)
No high-mounted stop lamp shall be combined with any other lamp or reflective device,
other than with a cargo lamp.
(b)
No high-mounted stop lamp shall be combined optically, as defined by SAE Information
Report J387 Terminology—Motor Vehicle Lighting NOV87, with any cargo Lamp.
(c)
No clearance lamp shall be combined optically, as defined by SAE Information
Report J387 Terminology—Motor Vehicle Lighting NOV87, with any taillamp.
We certainly don’t agree with NHTSA’s (a) and (b) restrictions put on CHMSLs (Center, High Mounted, Stop Lamps). Taking into
account common sense, real life observations, and the fact that “Conspicuity” for “Presence “ and “Intentions” are
supposed to be the prime objectives of FMVSS #108 to meet … it’s apparent to anyone of average reasoning ability that
there is nothing that would confuse nearby traffic if NHTSA was, to at least, allow (not mandate) the Optical and Physical
Combining of a Center High Mounded Stop Lamp (CHMSL) with either (or both) of the three I.D. Lights and/or with Center
High Mounted Augment Turn Signals*. Further, NHTSA should be encouraging, not discouraging, that I.D. lights be mounted at
close to ≈average Traffic Eye Height … not 14 feet off the pavement. See our “Request for Legal Interpretations” on this subject.
*Centered High Mounted Augment Turn Signals were allowed by SAE J186 since 1970 and for 20+ years, were unchallenged by NHTSA
as
to being a possible source of misguidance or confusion to following or adjoining lane traffic when combined with a CHMSL.
Using this rationale, our 2nd Petition* to NHTSA … asking to allow these beneficial Optical and Physical Combinations … is soon to
be sent in*. If our Petition is granted, NHTSA will be asking for comments from interested parties during the standard “Federal
Register” Commenting Process … keep in touch to “comment on” and/or to follow the results of this Petition.
*NHTSA denied our 1st Petition
By imagining the 3 I.D. “Running Lights” being “Optically Combined” with an augment Center High Mounted Stop Light
(CHMSL) as well as a pair of augment Center High Mounted Turn Signals …we ask, “what can be possibly wrong with a 3 I.D.
light bar center mounted at average traffic eye level that also completely lights up when the Brakes or Emergency Signals are
applied and also serves as a pair of “Center Mounted” Turn and Lane Change augment indicators allowing more conspicuous and
safer lane changing.
Take into account the NHTSA conclusion that their early Taxi Cab tests proved, following drivers most often try to look through the
middle of the vehicle in front of them – thus the great decrease in Rear End Crashes and this “center watching” is the reason Center
High Mounted Augment Turn Signals will save crashes too!
Regardless, know that if a CHMSL is not mandated*, there is no NHTSA restriction against Optically and Physically
Combining this CHMSL with a mandated “I.D. Light” and a pair of “Augment Center, High Mounted Turn Signals”. The only
objection NHTSA can put forth is that they won’t allow a mandated 3 I.D. light to be mounted at average Eye Level … which is
absurd … see our latest “Interpretation Requests” on this subject.
*Whereas, CHMSLs are not currently mandated by FMVSS #108 for Trailers, RVs, Motor Homes and Big Rigs?
Also, realize that “Optically (and Physically) Combined”*, Side Pointing and Rear and Front Pointing, “Side
Marker/Clearance Light” Combinations are FMVSS #108 compliant, as long as all the FMVSS #108 Photometrics and the
“Mounting Angles” are compliant … plus all the other Physical testing requirements of FMVSS #108 are also met.
Have you ever noticed a 180° Seeable Red Light mounted 45° to both vehicle axis’s and placed at the rear corner of a Big Rig
Trailer or on Over 80” Flatbed Truck? When a 180° Photometric Compliant small light is used in this kind of a 45° tilted “Optical
Combination”, it simultaneously informs Cross Traffic and nearby Pedestrians that this Vehicle, indeed exists, and is
passing in front of them, as well as simultaneously, truly indicates the “Widest Part” and “Extreme/Overall” Width to
following and passing and lane changing traffic. All this “conspicuity” is provided while using just one filament of light on
each rear corner of Big Vehicles. Also, this kind of “Optical Combination” means fewer Lights; therefore, saves extra costs
and saves energy to boot!
TLC #119B – ELIMINATE costly and unreliable “3 TO 2 WIRE” ELECTRONIC CONVERTERS!
Our recently developed, “RED/AMBER SWITCHOVER SYSTEM” provides any Trailer with a Lighting System that can immediately
adapt to either a “SPLIT”, or “COMBINED” Brake/Turn Lighting System Tow Vehicle, thus eliminating the need for any
costly and unreliable “3 to 2 WIRE” Electronic Circuitry always required for “Split” system Tow Vehicles towing a
“Combined” system Trailer. These kinds of “Black Boxes” have been required … at great expense… for millions of trailer owners
over the past 30+ years … but needn’t be required anymore if our new “SWITCHOVER SYSTEM” is adopted, which in total,
costs about the same as using any Special Adapter Plugs and “3 to 2 Wire” Electronic Converters – check it out!
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“Separated Turn Signals” (that is, “Split” Brake--Turn Lighting Systems) now include about 50% of all newer Tow Vehicles
whereas, these Vehicles have to use and maintain special “Electronic Converters” in conjunction with the typical 4 wire* (round
or flat) Wiring Connectors, which are still used on most small and medium sized Utility, Cargo and Boat Trailers.
The expense of adding a separate set of our SP-LL “Split Off” Amber Turn Signals is about a “push” considering the elimination
of the expense for a “3 to 2 WIRE” Converter plus its installation and upkeep expense. Additionally, by incorporating this option,
the Vehicle ends up with a Cool! Dual Color, modern and more massive Lighting System that most everyone will notice and
like!
*Most using the 40+ year old Industry Standard, 4 Wire Hook Up “Wishbone” wiring approach:
Brown = Running Lights … Green = Right Brake/Turn …Yellow = Left Brake/Turn …White = Ground
Be aware that this “Switchover System” is strictly an optional add on choice that can be used with our Standard, Universal, Red,
7-Function SP-LL Kit while still using the existing wiring system plus adding the supplied 5th (Red) Wire* along with the pair of
Amber/Clear SP-LLs and corresponding 2 Blade SWITCHOVER Connectors.
This combination allows anyone, anytime to instantly “Switchover” any Trailer from “Split to Combined”, or “Combined to Split”
Brake, Turn Systems at a moment’s notice, depending on which type of tow vehicle is being used at the time … thus, providing an
invaluable, one of a kind, feature when different Tow Vehicles are (or will be) used over the lifetime of the Trailer or RV.
*Supplied in the Amber/Clear SP-LL Kit
This system really works well, plus it adds the latest Detroit/Japan “Styling” plus the now popular “Red/Amber and/or
Amber/Clear color combinations” … and these extra costs will still be about the same as buying, adapting, installing and
maintaining a “3 to 2 WIRE” Electronic Converter - check it out!
*Which also increases “perceived and true value” of the Trailer
For those ≈50% of Tow Vehicles that don’t immediately need “Separated” Brake/Turn Signals … the Two Amber/Clear lights can be
used temporarily or permanently as Clear Back Up or Clear Area Lights or with Amber Bulbs … Amber Flashing Signals or ??
… which are simply wired into the Tow Vehicle’s Back Up or Emergency Flashing Circuits using the extra wire provided in the
Amber/Clear SP-LL Kit.
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TLC #120B - HERMETICALLY SEALED or AIR
TRAPPING! – but NOT “FILL & DRAIN”
A Sealed (Throwaway) Submersible Lamp must have reliable, lasting hermetic seals, especially needed for the millions of
popular ≈Industry Standard … “6 inch Ovals” and “4 inch Rounds” currently used on many Big Rig vehicles. These 3-Function
“Throwaways” are usually mounted in a Rubber Protection Bezel* … and cost about $5 when Incandescent versions and
about $15 to $30 for FMVSS #108 Compliant (legal) LED versions (if compliant LED versions can be found).
These sizes of “Incandescent or LED (Throwaway) Lights” have been sort of unofficially standardized and Replacements for them
can now be found pretty much any time, any place, but realize that they must be supplemented with Rear and Side Pointing Reflectors, plus
the Clearance, Side Marker and License lights, to provide 7 functions that the OEM or Trailer Owner would get if they simply used 7-function
lighting. These two Grommet* Mount Sizes provide a fairly reliable, serviceable program for Big Rigs that use these size 3 Function Lights.
*Which protects seal flaws from “water inundation” … and therefore limit “Suck In” problems …
See “Legal Interpretations” on this issue
As to the use of 6” Oval and 4” Round 3 Function “LED” Lights on Boat Trailers where they are less protected from leakage using
Rubber Grommets … the Economic and Dependability Jury is still out on these issues.
Of course, both 6” Ovals and 4” Rounds are rather bland looking and are only 3-Functions and not necessarily waterproof …
always leaving the OEM or Owner the responsibility to buy, mount, wire and maintain the other 4-Functions that 7-Function
Lamps already supply. In the case of Big Rig Trucking Companies … this approach probably makes economic sense*.
*When the actual “lost time” costs are figured using $25+ per hour labor rate
Coming up with a Serviceable, 6” Oval or 4” Round that has a perfect “Hermetic Seal”* for Boat Trailer Use … is nearly an
impossible task when trying to design an inexpensive, yet serviceable 3-Function “LED” or Incandescent Lamp Assembly;
however, Perfect Seals are not needed in our “Air Trapping” Designs.
To eliminate the need for a perfect Hermetic Seal, yet minimize water infiltration and 100% humidity failures, our Company was the
1st to develop our unique “Air Trapping” designs … that have worked amazingly well for millions of Boat Trailer users over the
past 30+ years. Our Air-Trapping Designs eliminate the high temperature expansion/contraction and hermetic seal
problems that almost always result in “Sucked In” water collection in all Sealed lighting designs when used on “fully
exposed” Trailer applications … explained in more detail in TLC #116B and in one of our latest “Requests for Interpretations”
recently sent to NHTSA.
We find our “open bottom” and special Hook Up features, plus our famous Snap Out, “Instant Serviceability”, no tools Bulb Slide
(with Dust/Splash Guard) also works very reliably for many other Trailer, RV and Big Rig tough duty, outdoor applications.
When instant 100°+ Fahrenheit temperature changes are forced upon our Lights when submerged or inundated with cold water,
our Air Trapping System automatically “equalizes” water and air pressures, thus eliminating leakage and water trapping
moisture problems. And after extraction from submersion or from an “inundation” situation, our designs “breathe”, thus …
“airing out” any tiny water droplets or 100% humidity condition that “Fill and Drain”* and “Leaking, Sealed Lights” never
eliminate.
*More details in future writings! – Also see “Requests for Interpretations”.
Our “Air Trapping”, Open Bottom design, used with our famous Bulb Slide and our protective Splash Guard, eliminates
“hermetical sealing” requirements, while still keeping cold water away from the bulbs, therefore eliminating any chance of “Bulb
Thermal Shock Breakage” and “Disabling Steel Component and Bulb Corrosion”. Air Trapping also significantly stops the
“Wetting” of the inside “Reflector Reflex Pins” and “Lens Facets”, while also eliminating most inside Grime build-up* and
*From “Fill & Drain” Designs
the resultant degradation in Public Safety.
We find these benefits can also be enjoyed in many RV and Big Rig applications – while at the same time, providing
Instantaneous, “No Tools” Bulb Serviceability, which Fill & Drain LED designs will never be able to offer!
As to “Fill and Drain” photometric degradation problems - see our latest “Legal Interpretation Requests” recently sent to NHTSA.
TLC #121B – MIS-INTERPRETATIONS of FMVSS #108 and “BORDER HARMONIZATION”
In our company files, we have ≈30 years of NHTSA’s official “FMVSS #108 Legal Interpretations” that consists of many Lighting
questions sent in to NHTSA by OEMs (and others) and NHTSA’s various answers that we’d be glad to share with Customers and Trade
Groups.
The recent NMMA, National Marine Manufacturers Association and Canadian interpretations of FMVSS #108 Law* we’ve being
hearing about … if true … must be immediately dealt with at the higher levels of Government because, if true … NMMA Inspectors are
unnecessarily threatening their Boat Trailer members with “non-certification” and Canadian Inspectors are causing needless and
costly “border hold ups”.
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We’ll soon be Petitioning NHTSA and the President’s “Trade
Representative”
asking
to
clarify
NHTSA’s
latest
Harmonization of FMVSS #108” Program that they started 12 years ago. We’ll also ask this Office to explain what’s legally allowed in
“Varying Interpretations” of our FMVSS #108 with the Canadian FMVSS #108 (so called) Equivalent.
Several years ago, I personally complained to the U.S. Commerce Department about Canadian Border Inspectors “doing their
own thing” on FMVSS #108 interpretations. I told the Commerce Officials that I understood the Treaties between the U.S. and
Canada were designed so we would have identical Vehicle Lighting Laws. As a result, I believe our Treaties were “re-read” by all
concerned and we saw satisfying (but temporary) results, so that … for a time … our Vehicle Lighting laws were again
considered “the same” as Canada’s.
Canada should certainly not be causing unnecessary border crossing confusion and expenses, which, as we all know, are
ultimately passed on …in the way of higher prices… to the Public in both of our countries. Apparently, it’s time this “Re-Read”
of Treaties process is asked for again.
Meanwhile, if U.S.A. Trailer Manufacturers continue to “kowtow” to these commerce limiting (and illegal?) demands … instead of
“complaining loudly” to NHTSA and to the appropriate Congressional Persons and Committees … this kind of harassment,
confusion and unnecessary expense … and restraint of trade … will continue and we’ll all pay for it … one way or another.
If our related Industries can see to it that these costly, grief generating issues are logically dealt with while also demanding that
D.C. Bureaucrats start giving our Industries some meaningful “Harmonization Efforts” – everyone will benefit.
TLC #122B - LET’S SELL “HARMONIZED” U.S.A. Made TRAILERS, RVs & BIG RIGS all over the world!
“Worldwide Harmonization” would include all* significant Vehicle Lighting Laws in the World. NHTSA was supposed to be
working on “Harmonization” efforts for the past 12+ years, but unfortunately, the small amount that has been accomplished, has really
only benefited the SAE and the Vehicle “Importers”, whereas NHTSA has virtually contributed nothing in the way of making it
easier for the Exporting of American made Trailers, RVs, Big Rigs and their associated components.
*Besides Canada … which supposedly already has the same Lighting Laws as the U.S.
If our Washington Bureaucrats (thru NHTSA) would only, “face to face”, confront all the Countries that currently do everything
they can to shut off U.S.A. Imports* from crossing their Borders … we could begin to generate export profits for the good ole’
U.S.A., and perhaps even recoup some of the jobs that have been given up to foreign countries because of unfair import restrictions
that have been essentially unchallenged by Washington D.C. Bureaucrats and who are apparently afraid of face to face confrontations.
*particularly France, Germany, etc.
Yes, labor rates are high in the U.S.A.*, but U.S. quality, along with our Yankee “innovation processing capabilities” can produce
products that “can always compete … and sell well … anywhere in the world” … if given a fair and uninhibited opportunity.
*compared to many other countries
All we need is some common sense Harmonizing of our Vehicle Safety Laws with European, Japanese, Australian, etc. Regulations
and some bona fide, meaningful efforts from Washington D.C. and, I believe, we could greatly increase our “Other Vehicle”* and
Component export sales, while at the same time, helping to improve our sad “Balance of Trade” situation. *Other than Autos and
SUVs.
Wouldn’t it be terrific if U.S. Manufacturers could start filling the half full Ships currently leaving our Ports with Harmonized …
and Uninhibited … U.S.A. Made Trailers, RVs, Big Rigs and associated components?
TLC #123B – 6” INSIDE of the “WIDEST PART” … the “EXTREME WIDTH” … the “OVERALL WIDTH”
I was told by a few NATM* Members at their last trade show, that they were told by NHTSA (indirectly or directly?) that mandated
“Clearance Lights could be placed up to 6” Inboard of the Widest Point” on any over 80” Trailers they manufacture, which I
questioned. I have heard of this 6” inboard allowance before; however, I never investigated where this 6” “Rule of Thumb” came
from. So I took the time to search our extensive FMVSS #108 “Legal Interpretation s files” that we’ve built up over the years.
*National Association of Trailer Manufacturers
As a result, I found the two attached 1997 “Legal Interpretations” sent to Donald Vierimaa from the 1997 “Chief Council” at NHTSA …
John Womack. After reading it carefully … I believe this Interpretation does say 6” Inboard is better than further Inboard? for this
particular Cargo Trailer case, but I believe it does not say the Widest Part can be routinely represented at 6” inside the real life
Extreme Width of the vehicle.
I believe what Mr. Womack is saying here is that if there is no other practical place to locate the Forward Facing (Amber) Clearance
Light on the … in question … over 80” wide Cargo Trailer … so that the Clearance lamp can truly represent the real life “Extreme
Width” … then 6” Inboard makes for the best “practical sense” in this particular case because the front outboard edges of most
Cargo Trailers routinely use ≈6” Radiuses for styling and for the lowering wind resistance.
However, if this Trailer had Protruding Fenders … the extreme Outboard Edge of the Fenders would represent the “Widest Part”*
and the “Extreme Width”* and the “Overall Width”* … and recognize that when mounted on the Fenders, the light is mounted close
to Average Traffic Eye Level, thus being very conspicuous to following and passing traffic and to nearby pedestrians as well.
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- 19 *all of these terms are used by NHTSA and D.O.T.
interchangeably.
It should be obvious to all concerned that if the “Extreme Width” of a very Wide Vehicle is not clearly represented to Passing Traffic* and
to nearby Pedestrians in both Forward and Rearward directions … “Clipping” or “Side Swiping” can more readily occur … after
which, it’s anyone’s guess what can result from a soft or hard “Clip” or “Side Swipe”. *At near eye level height
January 12,2007
TLC 124A – NHTSA’S “LEGAL COUNSEL” says “IT’S ILLEGAL”!
The recent (attached) letter sent to me by NHTSA’s new Chief Counsel, Mr. Anthony Cooke, affirms my statements that
indeed, the 7-3/4in² and 11-5/8in² “Effective Projected Luminous Lens Area” (EPLLA) mandates* spelled out in
Federal Motor Vehicle Safety Standard #108 are indeed, “The Law of the Land”, which dictates how much … and over
what areas … all Brake and Turns Signals Outputs required to be designed and tested to. Note that this Law pertains to
“LED” Designs, as well as to Incandescent Designs.
*Even though not mentioned … this also applies to the 4.5in² - EPLLA mandate for CHMSLs as well.
Mr. Cooke states that it is unlawful for Dealers to sell any vehicle or vehicle equipment that does not meet applicable
NHTSA standards. Although he only refers to Dealers, this of course, includes everyone involved in the chain of Distribution
for supplying the public.
He also points out that the Office of Vehicle Safety Compliance is responsible for how the Effective Projected Luminous
Lens Area mandates will be enforced.
Bottom line – anyone with a basic Technical Background, studying the official definitions of “effective light emitting
surfaces” and “effective projected luminous lens area”, will find that nearly all of the Aftermarket LED Brake and Turn
Signals now being supplied to OEM Trailer Manufacturers are indeed, illegal, thereby making all involved subject to
Recalls. Further, those supplying Non-Compliant Lighting that’s involved in any Rear End, Turning or Lane Changing Crash
can be partially or wholly blamed and held Liable for some - or all - of the resulting damages and injuries.
January 12,2007
TLC 125A – OUR GUARANTEE
Here’s our Submersible Guarantee Sticker that we offer to our Boat Trailer Manufacturer Customers, which shows the faith
we have in our products compared to our competition’s typical “LIMITED WARRANTY” statements … that basically
“mean nothing” when scrutinized.
I believe most will agree that our Guarantee is very comprehensive … and maybe too lengthy … but it is clearly aimed at
Boat Trailer problems that past and present Boat Trailer Users can and will relate to.
Of course, we can provide similar Guarantee “Tongue Stickers” for any and all kinds of Utility, Cargo, Horse, etc., etc. type
Trailers – just tell us what’s needed!
January12,2007
TLC 126A – WATCH OUT FOR “FILL & DRAIN” DESIGNS that collect DUST/DIRT and GRIME!
Deliberately submerging a Boat Trailer Light and allowing it to fill up with water when launching a Boat in our typical
greasy, grimy, salty “launch area” water, produces inside deposits that quickly deplete the effectiveness of Reflective and
Refractive operating surfaces.
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As a result, both Projected and Reflection Outputs are depleted significantly and in all probability, the Brake/Turn Light and
Rear Reflector functions quickly degrade to below minimal FMVSS #108 Standards.
SAE (Society of Automotive Engineers) addresses degradation problems with this Regulation Where it is expected that lamps must perform in severe environments, for example, be totally immersed in
6.2.4
water periodically, the user should specify lamps designed for such use.
Of course, this would disqualify any “Fill & Drain” Boat Trailer applications and other “Utility use” Designs that don’t
provide Dust and Dirt Guards to avoid degradation of the Inside Faceting and Reflex Pins.
Furthermore, the very important Rear Reflector that is generally built into the lower portion of a typical 6/7/8 Multi Function
Light Assembly used on Boat Trailers must be protected from Grime, Salt and “Water Droplet” Degradation, which
is an impossible task in a “Fill & Drain” design.
Even in Boat Trailer “Air Trapping” Lights, the Rear Reflector can quickly be degraded from Grime Deposits when the
“lower” portion of the typical Lens/Reflector Combination is not properly protected from getting wet when submerged even
though the upper lens area doesn’t get wetted.
We have always protected our Rear Reflectors in our “SP” Designs by adding a separate window that
keeps submersion water from getting to our bottom located Reflector – an added feature that all the Taiwan “knock offs”
of our “SP” design do not supply … obviously to save costs, while compromising safety and your overall Liability.
In any case, know that degraded Rear Reflectors, as well as compromised Brake and Turn signals are very libelous.
Many years ago, I was getting my hand bandaged for a chemical burn at our small town hospital when Ambulances
brought in a whole family that had pulled off onto the shoulder of a local highway and “crashed” into a “left behind Boat
Trailer” that had a flat tire. They were all hurt and bleeding and I could hear the father saying “I didn’t see the trailer
because it had no reflectors”.
I’ve told this story over the years to all boat trailer manufacturers that would listen … trying to warn them of the Liability
involved with allowing the Rear Reflectors and Brake and Turn Signals in multi function tail light assemblies to degrade
below FMVSS #108 minimals due to grime, dust, dirt and/or water droplets accumulating on the inside of the Reflex
Lens Facets.
These kinds of liability circumstances can produce large jury awards (and large out of court Settlements) that you should
always think about when selecting your Lighting. Yes! currently FMVSS #108 does not address inner lens and inner reflex
grime and dust degradation problems … but should! However, you should be aware that NHTSA is under obligation to
Recall any kind of apparent safety hazards on our roadways using the main objective statement of the 1966 Vehicle
Safety Act – check it out!
This means if the Lights and Reflectors you use are not designed to take Submersion* and Dusty Roads without
dropping below the minimal outputs spelled out in FMVSS #108 – they are in violation of the main goal of the Safety Act.
*for Boat Trailers
.
April 20, 2007
TLC 127A – We can find only TWO LEGAL “LED” AFTERMARKET BRAKE/TURN LIGHTS!
The first is a Custom Aftermarket “LED” “Exchange” Tail Light Assembly” that we saw at the last SEMA and AAPEX Shows. This Multi
Function Light Assembly we can confidently bet is fully compliant to Federal Motor Vehicle Safety Standard #108.
It is made by HELLA®, who, we all know, make 1st Class Vehicle Lighting Products … so we can pretty much be assured all of Hella’s
lights are indeed legal for use in the USA* as well as in ECE* Countries, plus Japan, etc. These Lights (see attached) were
exclusively designed as “Exchange Lights” to upgrade and provide quality custom uniqueness for the new Ford 150 Trucks.
*Remember, USA and ECE Lighting Regulations are supposedly “Harmonized”
This Hella® “LED” Design uses about 30 High Quality, High Intensity LEDs, plus it uses the very attractive “Conal Reflective
System”*, which assures that the “Effective Projected Luminous Lens Area” (EPLLA) represents at least
7-3/4in² of Effective Projecting Facets all of which are aimed within the “Test Pattern” of 20° Left to 20° Right …
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10° Up to 10° Down … while not including any of the
Transparent or Unlit Cover Lens Areas in the EPLLA tally.
Further, I’m sure Hella® has also provided extra Photometric Output for the Brake/Turn Lights to compensate for expected “LED Heat
Losses”. *Like Cadillac first introduced ≈3 years ago
A pair of these Cool! Looking Lights Retails for over $500 … need I say more?
The only “LED” Aftermarket Trailer*, RV* and Big Rig* Brake/Turn Signal Light being sold in the U.S.A. that we could confidently bet
is also fully Compliant to FMVSS #108, is made by Peterson®. Peterson’s 56 LED “Model #45” (see attached) design is also very
expensive … Retails for ≈ $120 each! It’s advertised as “ECE Compliant” and therefore, must also be FMVSS #108 Compliant.
*All Non Motor Driven Vehicles’ Lighting is under FMVSS #108 Law as is Motor Driven Vehicle Lighting as well!
In European countries and Japan, there is “no way” any Importer could get “ECE” Approval for non compliant or borderline LED
designs that can be expected to lose 1/3 of their output when heated and/or allow the deposit of grime or road dust on the inside lens and
reflector surfaces … which brings up the subject of the degrading effects of launch water and road splash grime deposits on “Fill and Drain”
lenses and bottom mounted rear reflector designs by Optronics®, Cequent® (Wesbar) and Peterson®.
Furthermore to get “ECE” approval, also requires provable “EPLLA” and provable Candela Compliance when tested under all
physical conditions the lighting product may experience during its “guaranteed 10 year ?? life time”.
The early Taiwan made “Exchange Lights” we’ve all seen “Turning “Pink” … with “Plating Peeling” and with obvious deficient
Photometric outputs and obvious below compliance “EPLLA Tallies” … are still being put on our Roadways. Look on “eBay”
under “Tail Light” and you’ll see all the imported junk being allowed into the U.S.A. at the expense of our U.S. job market and our GNP,
not to mention the degradation of road safety. *Other than all Auto, SUV and Pick Up Manufacturers
Further, we can confidently bet that both the Hella® and the Peterson® “LED” Brake/Turn Lights described above are made of proven
materials that will “last” and will have no fade or warping problems. Plus, I’d bet both are designed and tested so moisture, dust
and grime won’t effectively infiltrate and deplete the original Lens and Reflector compliant photometric outputs to below
FMVSS #108 minimal values during the minimum 10 year ? life span of these products. And, I’d bet, they both have been compensated for
outdoor, exposed “Heat Up Losses” that can typically deplete output by 1/3rd and more.
On the other hand, I can also confidently bet that practically all of the Trailers using LED Brake and Turn Signal Lights put into
service in the last 10 years … are not compliant to FMVSS #108 … in many ways, including the very obvious “Effective Projected
Luminous Lens Area” and “Heat Loss” deficiencies; that is … except for the Hella® Ford 150 and the Peterson® Model 45 and perhaps
some of the Lights shown in the attached photos that I took at the recent Work Truck Show that use 60-80-120 LEDs. Also, note that
Toyota Work Trucks have declined the use of LEDs and are restyling using the See Thru/Plated approach like we’re offering.
In contrast to the typical Trailer LED Brake/Turn lighting being offered Trailer, RV and Truck OEMs … we can all be assured that 99.9%
of all new Motor Driven Vehicles … that is … all new Autos and Pick Ups and SUVs … put onto U.S. and Canada roads, are indeed
fully compliant with all sections of FMVSS #108.
Realize too, that regardless of what’s going on with Imports and the ignoring of Federal Laws, our Company continues to make products
that do comply to FMVSS #108 as to “EPLLA” and Photometric Mandates, while also satisfying the “Lasting Material” mandates, which
adds additional costs for Engineering, Tooling and Testing, and for the use of Lexan® type materials where “copying” and “cheapening”
Taiwan competitors spend little or nothing on Engineering and Testing, and less on materials. Therefore, no one knows how effective
their products are, or how long they’ll last in real-life use … nor does anyone know how many Recalls or unhappy customers or Liability
Lawsuits they will instigate!
Who else makes legal LED “Exchange” or LED Trailer Brake/Turn Light Assemblies? … as of this date …
we know of no one else in the U.S.A.!
April 20, 2007
TLC 128A- IT’S THE LAW!
All Lighting used on our roadways is mandated to comply to specific Federal Regulations – in the case of Vehicle Lighting, Federal Motor
Vehicle Safety Standard #108, otherwise known as FMVSS #108, which can be studied on the Web under www.nhtsa.gov … or we can send
you a “consolidated copy” at your request.
The regulations spelled out in FMVSS #108 are based upon previous human traffic and pedestrian tests that resulted in NHTSA
establishing minimal “Candela Outputs” and minimal “Distribution of Light Areas” to assure adequate levels of “Conspicuity”* for
“Presence” and “Signaling Intentions”. Furthermore, FMVSS #108 also establishes mandates for the Testing of materials used in
lighting and reflective devices to assure Longevity. This includes testing to see how lighting devices perform under normal and
extreme physical circumstances so as to assure the Public … effective and lasting “Presence” and “Signaling” Vehicle Lighting.
*Main Objective Goal for all Lighting Laws
If a Vehicle Manufacturer or Distributor/Dealer/Installer has anything to do with putting Non Compliant Lighting Products on a vehicle
involved in a “Crash” on our roads, they can be named as Defendants in any resultant traffic collision lawsuits … making them liable
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(wholly or partially) for any damages, injuries or deaths that occur
in any “accident”, “crash”, “wreck” or “multi vehicle pile up” involving
Non Compliant Lighting that they supplied the public, either directly or indirectly.
The attached National Association of Trailer Manufacturers Articles show that Trailer Manufacturer Trade Groups as well as Liability Insurance
Companies are now warning of this avoidable “Liability, but so far, these warnings are generally being ignored.
When Federal Law mandates that minimal Photometric Outputs* must be maintained, plus mandates the exact specific
directions of these minimal outputs … this represents enforceable Law that any Civil Lawyer expert can use against you and/or
your Company to ceremoniously point out in Court Non Compliances’ to FMVSS #108 that you’ve supplied the public, which could
have partially or wholly caused Damage, Injury, or Death, resulting in you and/or your Company being required to give the Plaintiff’s as
much money as the Lawyer and his client can get approved by an almost always sympatric Judge or Jury.
*in Candelas
Of course, we are all aware that pleading that you were unaware of the law/s in question has always proven to be a futile
defense, so this way of rationalizing any Non Compliancy associated with Vehicle Lighting is not an option.
Currently, three major violations of FMVSS #108 mandates are blatantly being practiced in the U.S. They are:
1. NON COMPLIANCY to “Effective Projected Luminous Lens Area” Mandates:
11-5/8in² of Effective Projected Luminous Lens Area* (EPLLA) is mandated for all Brake and Turn Signals on all
vehicles (motor driven or not) over 80 inches in width …7-3/4in² of “EPLLA” is mandated for vehicles under 80 inches in
*See attached definitions for EPLLA
width.
2.
UNTESTED LENS/REFLECTOR MATERIALS:
We know that practically all Lenses and Reflector materials used in Imported Lights (and associated components) is not
backed with credible proof of complying with the FMVSS #108 Mandated 3-Year Outdoor Fading, Heat, and Warping
Testing. Ask Vendors calling on you for this data! … and see what you get!
3.
LOW PHOTOMETRICS for Brake and Turn Signals!
Seven out of Ten tested “LED” Brake/Turn Lights failed a recent FMVSS #108 NHTSA Testing Program … therefore
requiring Recalls, plus implicating all persons and companies involved with the installation and use of these Recalled
Lights, and making them liable for any now or future adverse results.
Realize that since Recalls typically retrieve very few Non Compliant lights … the remaining Non Compliant Lighting extends
Liability to all involved for the life of these essentially “Illegal” Lights that have been put into public circulation.
These mandates are currently being violated all over the U.S. and are causing long term Liability for all
involved that cannot be wished away. Also, we all know … violations of Law cannot be defended in any
Court … using the excuse … “EVERYONE ELSE IS DOING IT”!
Bottom line – our Company, Peterson®, Grote®, Truck Lite® have been required to comply with FMVSS #108 mandated Law for the
past 38 years and now these Laws are being allowed to be ignored by practically all Importers and, by some American Lighting
Manufacturers as well whereas, this cannot go on any longer.
April 20, 2007
TLC 129A – SEEING “Effective Projected Luminous Lens Area” (EPLLA)
Effective Projected Luminous Lens Area (EPLLA) is the portion of the faceted projecting areas of a Brake/Turn Light that you
actually can see, specifically directed light emanating from when looking “straight in” on the Test Lamp with your head located ≈ 10
feet “straight out” from the center of the Brake/Turn Signal Light being Tested. The Areas that you initially see “light up” can
officially be added to the “EPLLA Area Tally”, plus you can also add in all the areas that you see distinctly light up during the
lateral and up and down movements of your head – anywhere within a rectangular area* of ≈ 10 inches to Left, ≈ 10 inches to
Right, ≈ 5 inches Up*, ≈ 5 inches Down*, which is referred to by NHTSA and SAE as the “Test Pattern” projection area”, which at 10
feet the 10 and 5 inch borders represent the 20° Left – 20° Right, 10° Up – 10° Down “Test Pattern”.
If … in the case of the attached Optronics® example … all you see light up during the entire Test Pattern area observations is the entire
fourteen, ¾” diameter Fresnel … the maximum “EPLLA Area Tally” is 14 X ∏ X (R²) or 14 X 3.14 X (3/8)² = 6.19 in². Therefore, to get to the
mandated 11-5/8in² … Optronics must provide 11-5/8 divided by 6.19, which means they need at least a total of 26+ … 3/4" diameter
Fresnels … therefore, at least another 12 must be added, thereby nearly doubling the cost of their LED array
If you’ll take the time to look straight in*… 10 feet away… on any of the new, very “Cool Looking” … now, seeable everywhere … New
Car, “See Thru/Chrome” Incandescent Designs, you’ll see a bunch of faceted areas light up when you’re looking straight in. Then,
as you move your head within the Test Pattern … you’ll see adjoining … yet different … facet areas light up while the initial (straight in)
areas “shut down”. All the Areas that light up during the entire Test Pattern Observations can be Tallied for EPLLA Compliance. *at a
traffic light will do
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Small unlit areas between lit areas tallied during this Test are also
addable to the EPLLA Tally as long as they’re not bigger than
about 1/8”, which NHTSA and SAE has historically allowed. However, only ≈ 1/8” areas between seeably Lit areas can be tallied, whereas
all transparent and all unlit areas between the 3/4” Fresnels and the outer rim of the cover lens do not qualify for EPLLA tallying.
Try personally Testing the shown 14 “LED” Optronics® Light … you won’t see any additional areas light up when moving your head within
the Test Pattern. Therefore, there is nothing more in area that can be added to the Effective Projected Luminous Lens Area tally, except for the
area the fourteen LEDs actually light up.
Since Auto Tail Light Assemblies are now always massive compared to FMVSS #108 minimal size, and can average ≈ $100 and up for
their direct cost … and factory replacements will be sold to replace broken ones at an average price of ≈ $250 and up … Auto Designers
have a lot of financial backing and extra area to meet the 7-3/4in² “EPLLA” mandate while attempting to make a massive, intriguing,
attractive design at the same time. However, making a decent quality, lasting and economical ($5 to $10) 6/7/8 Function OEM Trailer
Tail Light Assembly that has 11-5/8in² of EPLLA, is a real economical and engineering challenge when dealing with an
Incandescent Design and it is an impossible achievement using just a few “inexpensive” LEDs.
*These popular “See Thru” Tail Light designs are proving to be very instrumental in selling expensive Cars, SUVs and Trucks!
They’re “intriguing and attractive” to the Public and can greatly influence a $30,000 to $50,000 purchase just as our “See Thru/Chrome”
designs can influence Trailer sales as well.
The Federal “Effective Projected Luminous Lens Area” mandates exist to assure that adequately large areas light up and will still
be effectively visible even when dirty, thus having a good chance at being consciously and subconsciously recognized by
following and to the sides drivers and pedestrians … a few Red LED Dots will not do these jobs.
Adequate “Effective Projected Luminous Lens Area” for Brake, Turn and Lane Changing Signals assures adequate conspicuity in
up-close conditions when rain or snow (or dust) refracts light coming from the plentiful number of “Effective Projected Luminous Lens
Area Facets” so drivers … following and to the side … are more apt to see and react to this large, lit up, spread out, area of
properly projected light.
Imagine if there was no “EPLLA” Requirements … a single, small powerful “Dot” of LED or Incandescent, Red or Amber Light
could, theoretically, qualify Photometrically for FMVSS #108 Brake/Turn Compliancy, but would not be effective when it comes to
“subconscious stimulation” *, and could easily be covered by mud or snow. Further, consider that a single, high intensity, Dot
approach would also, produce unwanted glare and confusion, not to mention, providing a “styling no-no” that would never be
considered by any Auto, SUV or Truck Designer.
*Human Tests substantiated
The minimal safety mandates for Effective Projected Luminous Lens Areas are spelled out in Federal Law! and violating these Laws
may not get you into immediate trouble with Federal or State authorities, but ignoring these Laws will eventually cost you one way or
another … in Recalls … in unhappy customers … or in damage, injury, or death Liability Lawsuits … that, I’m sure, you’d just as soon avoid.
Email or Fax us any Questions - We’ll try to answer them directly or address them in our next “Tech & Legal Clarification”
updates
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