TLC #112 B – “ILLEGAL DECEPTIONS” everywhere! … NHTSA says “Go Ahead” … “HANG YOURSELF”!
By pretentiously molding in “Phony” and/or “Non-
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 EPLLA usable area. *Imagine “Rays” of LightLamp 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-
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-
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-
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-
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! -
FOR INSTANCE: Here’s a noteworthy example that NHTSA could effectively use to demonstrate the point that “MANY LEDs are NEEDED” to meet the “EPLLA” requirements for 3rd 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) 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-