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 TLC #127A  IT’S THE LAW                        

All Lighting used on our roadways is mandated to comply to specific Federal Regulations.  In the case of Vehicle Lighting, everyone involved with the process of supplying the Public with mandated Vehicle Lighting … either used on new Vehicles or Replacements for mandated lighting, must comply to all facets Federal Motor Vehicle Safety Standard #108.  FMVSS #108 can be studied in detail on the Web under www.nhtsa.gov … or we can send you one of our “Consolidated (with comments) Copies” at your request.

The mandated regulations spelled out in FMVSS #108 are based upon original NHTSA and SAE human traffic reaction tests that resulted in NHTSA establishing minimal “Candela Outputs and Directions”, plus minimal “Effective Projected Luminous Lens Area” to assure adequate levels of “Conspicuity”* for all “Presence” and “Signaling” lighting.  Furthermore, FMVSS #108 also established mandates for the Testing of materials used in lighting and reflective devices to assure LongevityThis includes testing to see how lighting devices perform under normal outdoor physical circumstances so as to assure the Public a reasonable product Lifespan
*”Conspicuity” is the Main Objective Goal for all Lighting Laws

If a Vehicle Manufacturer or Distributor/Dealer or Installer has anything to do with mounting Non Compliant Lighting Products on a “suspect vehicle” involved in a crash … they can be named as Defendants in any resultant traffic collision lawsuits … making them liable (wholly or partially) for any damages, injuries and/or deaths involving Non Compliant Lighting that they supplied the public, either directly or indirectly.

The attached “National Association of Trailer Manufacturers” (NATM) Articles show that trailer manufacturer trade groups as well as Liability Insurance Companies are now warning their members and clients of avoidable “Liabilities, but so far, these warnings are generally being ignored.

When Federal Law mandates that minimal Photometric Outputs* must be maintained and also mandates the specific directions and Effective Projected Luminous Lens Area for these minimal outputsthis represents enforceable Law that any Civil Lawyer expert can use against your Company to point out in Court Non Compliances to FMVSS #108 that any number of Defendants supplied the public, which could have partially or wholly caused Damage, Injury, or Death, resulting in being required to give the Plaintiff’s as much money as the Lawyer and his client can get approved by an almost always sympathetic Judge or Jury.        *measured in “Candelas”

Of course, we are all aware that pleading to a Judge or Jury you were unaware of the law being cited has always proven to be a futile defense, so this way of trying to rationalize any Non Compliancy associated with Vehicle Lighting in question 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 over 80 inches in width …7-3/4in² of “EPLLA” is mandated for vehicles under 80 inches in width.
*See attached definitions and attached recent letter from NHTSA to me pertaining to EPLLA

2.       UNTESTED LENS/REFLECTOR MATERIALS:
We know that practically all Lenses and Reflector materials used in Imported Lights (and associated components) are not backed with credible proof showing compliance with the FMVSS #108 mandated 3-Year Outdoor Fading, Heat, and Warping Testing.   Ask Lighting Vendors for this proof!and see what you get!

3.       LOW PHOTOMETRICS for Brake and Turn Signals!
Seven out of Ten
recently Federally tested “LED” Brake/Turn Lights grossly failed FMVSS #108 Photometric Testing … therefore, requiring Recalls, while at the same time, implicating all persons and companies involved with the installation and use of these Recalled Lights, and making everyone involved liable for any current or future adverse results.

Realize that since Recalls typically retrieve very few of the targeted Non Compliant Lights or Reflectors … where the remaining non Recalled Lighting extends Liability to all involved for the life of these “Illegal” Lights.

Several FMVSS #108 mandates are currently being violated all over the U.S. and are causing long term Liability for all involved this Liability cannot be wished away.   Also, we all know … violations of any 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 by NHTSA … to be ignored by practically all Importers and recently, by some American Lighting Manufacturers as well.

Sierra Design Mfg.  Inc.        1113 Greenville Road         Livermore, CA  94550         Tel (925) 443-3140

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