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FEDERAL  #108 SUMMARY

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TLC #112 B – “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 EPLLA usable area.                         *Imagine “Rays” of LightLamp Manufacturers that leave out needed LEDs*, or produce fake holes* where “LEDs” should be … but aren’trepresents 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?

“EPLLA, Non-Compliances” are currently being marketed by most (if not all) Manufacturers of “LED”, 7-Function and 3-Function 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 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, 7-3/4 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.

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