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"INCANDESCENT" FEATURES versus "LED" FAULTS

                                                                                            



        Formerly Sierra Products Inc.

From: Dennis G. Moore

November 2010

One of a Kind Product
We've recently started Dealer Sales Tests that, so far, resulted in "Coast" Distribution (in the West) and "Waterland"
(in the Southeast), agreeing to carry our unique
"SEE THRU/CHROME" SPIFF UP (SPLL) Pair KITAt this year's SEMA
Show, we hope to find additional quality Warehouse Distributors
for representation all over the U.S. and Canada.
Despite this discouraging economy, we know there are still
several million existing Trailer Owners that will show
interest in spiffing-up their Trailer’s and Specialty* Vehicles
, particularly if they believe they will be gaining grief-
saving and reliability  features that would make their Driver duties
less stressful, safer, and, less of a maintenance burden.
                                   *Our "3rd Brake/Turns" for Customs/Hot Rods/Classics 


Here are a couple recent emails showing how our older and new "SPLL" Lights are being appreciated:


from: Richard Nxxx (Pensacola, Florida)
comments: “I bought a pair of the 701's from Boaters World while they were going out of business.  Didn't need them right away but I knew I would sooner or later.  I tried to put them on today and I have two right side lights.  Is there any retail outlet selling your lights in Pensacola FL. 
PS you guys do make the best lights.  The ones I'm replacing are LED and are only 3 years old and some of the LEDs stopped working after
one year
.  I've had yours on other trailers and had no issues”.


From: Don xxxxx (Green Bay, Wisconsin) Subject: SPLL
“Hi!  I just wanted to say thanks for the
SPLL replacement lights, they are fantastic looking and super bright, I could see the quality immediately. It took 30 minutes to replace both and I tested them rigorously the next three days on a very fast moving Fox River in Green Bay, WI, walleye fishing of course. The location of the bulb and the splash guard worked great. On a side note, I participate in many fishing tournaments during the year and I try to support American manufacturers in any way I can. If Dry Launch has any sort of large truck decals or stickers in any way I would be happy to display them with pride on my boat and several vehicles.   Thanks for making a great American product”.

These endorsements … along with many others we have received over the years proves that Trailer Owners are impressed with our quality, performance, new looks and grief-reducing features.  There's a couple Million + Drivers already using our products and cheapened Copies of our products.

 "LEDs" are not that Special!

Take the time to look around … at any Parking Lot or Traffic Light, and note … the Newest/Coolest Tail Light Designs that may appear to be "LED Illuminated", are actually "Incandescent Illuminated".  It's a fact that 3 out of 4 U.S., Japanese, and European Designers and Engineers now prefer using the new … State of the Art … precision, Wedge Base, Long life, Rustproof #3157 type Incandescents because they know they’ll produce the most intriguing, mesmerizing, brightest, “sparkling”, effectsthat LEDs simply, can "Not" offer.




While you're at it … note that not only 3 out of 4 of all New Tail Lights use the "New Age" Incandescents … and further notice that  4 out of 4 use the "New Age" Incandescents for "all" of their Amber “Turn Signals” and for "all" of their  White “Back Up” Lights.

In step with these very special Auto, SUV, etc. Incandescent designs, we’ve Tooled and begun Manufacturing a revolutionary, “See Thru”/Chrome, 7/8 Function, Trailer Tail Lightwe’ve named “SPLL … where the "LL" stands for "Liquid Look®".  This unique design adds modern, “Auto Like”, styling and "Rustproof" performance to our “Old Reliable” Standard “SP” original Product Lines.

 ABOUT US!
Over the past 30 years, we have … here in the U.S.A. … Manufactured a wide selection of Vehicle “Presence” and “Signal” Lighting.  Our products are currently in use on quality Trailers, "Caps", and Motor Homes such as ShoreLand'r®, E-Z Loader®, Road King®, WaterLand® and even Airstream®.

Our products have been completely developed* at our facilities next to the Lawrence Livermore National Lab in Livermore, California** and in the Sierra foothills … near "Yosemite" … in Sonora, California**. 
            *I'm a BSME Graduate of Bradley University, Peoria, IL
            **Regardless of California's "crazies" … California is still a good place to visit! … particularly in the Ocean and Mountain Areas.

We can also brag that! … We're the only bona fide U.S.A. Vehicle Lighting and Reflector Manufacturer in 20 Western States that still performs their own “in house” … Designing*, Tooling, Injection Molding and Photometric, Weather, as well as long term Road Testing to all Federal Mandated Requirements.  We closely monitor all quality** and production procedures - allowing us to be able to guarantee our product's Compliancy to "Federal Motor Vehicle Safety Standard #108” (FMVSS #108) … conveniently “Linked” thru our Website. 
                   *We do not use the Copy and Cheapen” Designing Process … used by the typical Chinese Importer
                 **Our Vehicle Lighting Testing Facilities were approved by the California Highway Patrol Engineering Division
                             in the 1980's and have been maintained and regularly used ever since

Further - we believe we are the only small Lighting Manufacturer in the U.S.A. that Injection Molds its’ Lights and
Reflectors out of “authentic” Fade Proof … Hi/Low Temp Tolerant*… Lens Grade … LEXAN® that is, provable
compliant
to all Federally Mandated 3 Year, Outdoor, Weather, Sun, Heat/Cold* and Vibration Test
Requirements
… and not made from untested … foreign-made, Non-Compliant (Illegal) materials
that notoriously Fade, Warp and Crack!  
                         *Also, great for Snowmobile and other cold weather usage

Our Livermore facility houses our Sales and R & D operations plus a variety of “CNC” and “EDM” Mold Making and Injection Molding equipment.  We maintain twelve, 100 Ton to 500 Ton* Plastic Injection Molding Machines along with all required complementary equipment.  Our facilities provide us with the entire spectrum of capabilities and equipment for all Manufacturing Services … including Custom Designsfor any kind of Trailer, RV or Truck Light or Reflector need … except Headlights.                  *“Clamping Force” capability

There aren't many “true” Trailer, RV or Truck Lighting Manufacturers left in the U.S.A., because … along with many other categories of products … Americans have foolishly permitted many of our small manufacturer’s products to be “stolen”, or “outsourced” to other Countries … many times … for just a small percentage of $ savings

Since our recent … more complex productsrequire American “know how” for the inventing, prototyping, designing, engineering, and tooling stages … we’ve concluded that these kinds of products should “not” be manufactured offshore, even when our total costs will be somewhat higher than the inevitable Patent Infringing* - - Foreign Copier* "Thieves" that we have always been targets of … while they enjoy saving costs for Engineering … Product and Tooling Development … and Initial Marketing.
                  *We have sued Patent Infringers in Federal Court … and won!

We believe the "Made in the USA" approach results in much more reliable, better quality products, which benefits Distributors and Jobbers in that they will face less complaints and returns plus enjoy much quicker factory responses to problems. 

And … as a Super Bonus! … we keep some needed Tooling, Production, and other related Jobs in the U.S.                                 

 

Our New “SPLL” REPLACES a WIDE VARIETY of Featureless Competitors' Models
The "SPLL” provides an easy "Tit for Tat" Replacement* and Update opportunity for millions of current Trailer
Owners/Drivers
that are currently using competitor's "Same Ol's" and "Plain Jane's" that also use the Industry Standard,
2” bolt spacing.  Further … consider the fact that "SPLLs" can Update the Million+ of Trailers still using our popular
"SP"* Series Multi Functions including ShoreLand'r® and E-Z Loader® owners. 
                        *Can also replace and update another million or so of cheapened
Chinese and Mexican made copies” and
                        “Look a Likes”  of our
20+ year old “SP” Product Lines

LOOK AROUND! … NOTE the “NEW AGE” - "SEE THRU INCANDESCENT" DESIGNS
By visiting any large parking lot … it becomes apparent that at least 3 out of 4 of the coolest, most attractive, and most mesmerizing new Tail Light Designs are using PrecisionNo RustLong lifefind anywhere, #3157 type Incandescents … for the illumination of their newest “See Thru/Chrome”* Designs.  Each of these creative incandescent designs has been specifically designed to “dazzle” prospective buyers into the purchasing of that particular Vehicle.                *It’s not really “Chrome” Plating … Its “Aluminum Vapor Plating”!

Notice! how Auto TV Ads now flaunt all their, Cool, new Tail Light Designs? where … in the past … TV Ads seldom highlighted the Tail Light areas of new Autos, SUVs and Pick Ups.  This highlighting is used because Auto Marketing Managers have been made aware of the fact that … fascinating! “See Thru” Tail Lights … are very influential in contributing to a Vehicle sale.

Marketing experts have learned that for the little more $ spent over the cost of “Plain Jane and “Same Ol” Tail Light Designs … complex, creative, Incandescent Tail Lights can often be the “Tipping Point” to clinching a $40,000+ Auto, SUV or Pick Up Sale.  Of course, this successful Marketing technique would also apply to the sale of Trailers, RVs and Trucks … and perhaps at higher prices?

NEW AGE "INCANDESCENT" ADVANTAGES versus “LED” LIMITATIONS
For many years we have tried to warn Trailer, RV and “Cap” Manufacturers about the many “LED” Technical and Legal issues that must be addressed to assure themselves that the low cost* "LED" Brake, Turn and Lane Change Signaling Lights they provide to the Public are FMVSS #108 Compliant and, therefore, "Legal".
           *
“Low cost” when compared to the very costly, high quality, LEDs and first class Heat and Moisture protective surroundings
               provided in the average …
10 to 40 times more expensive … Auto, SUV and Pick Up "LED" Tail Light Designs

Therefore … to avoid costly returns, and possible Legal*, Recall and associated Lawsuit* problems … that are inherently tied to cheapened, Imported, “LED” Multi Function Trailer, RV and Truck lights … we have chosen to use the Auto Industries' newest Sylvania® Long life #3157 "Rustproof" Wedge Base Incandescentas the Illumination source for our new SPLL.  This State of the Art Bulb … when used with our SPLLs unique "Refraction/Reflecting, Parabolic Wing Reflector” … yields a lit and unlit impression that many mistake for LEDs.

*For further Legal and Liability infocheck our Website for a wide variety of “writings” issued by
“NATM”®
… “National Association of Trailer Manufacturers” and from “SEMA”® … “Specialty Equipment Manufacturer's     Association” … along with a variety of Attorneys and Insurance Representatives that
have extensive experience with legalities and lawsuits associated with the Trailer, RV and Trucking Trades

Our BOLD STYLING and GRIEF-SAVING Features Sell themselves
We provide all our lighting products with distinguishable* Styling and Packaging, plus, we always add Safety and Grief-Reducing Innovations not to be found anywhere else.  The new “SPLL” is designed to not only complement any Tow Vehicle’s Tail Light Styling, but it also dazzles and impresses”** in its Packaging and when seen on the road - Lit or Unlit
                 
*Patents pending                     **See Page 1 Email "Testimonials"

"SPLLs" will sell well in the AFTERMARKET

Our "SPLL" Pair Update Kit sales success should be all but certain for most Auto Parts, RV, Marine, and Trailer Supply type Jobbers … and in any other Outlets, where owners of Trailers, RV's and Trucks visit.  We are willing to Guarantee our new Packaged “SPLL” Pair Kits will sell well at these kinds of Outlets … and, we’re willing to back-up this confidence with “In Store" Testing, if necessary!

Add Up all the SPLLs UNIQUE FEATURES
Start with our SPLLs NO STEEL – NO RUSTfeature, and add our Bold and Intriguing, Liquid Look® … then, give us credit for our SNAP Out/In “NO TOOL'S”, Bulb Slide plus the new Sylvania® “LONG LIFE”, “NO RUST” Wedge Base Bulb that comes with a reliable Phosphorous Bronze, Contact System and don’t forget our handy “Pavement Light-Up”, Signal Checking Feature

Then top off all these Credits with our “all” Lexan®, construction and the Stainless Steel Mounting Bolts/Nuts … and finalizing the feature list with our 10 YEAR “RUST FREE, KEEPS WORKING” GUARANTEE.

POWERFUL and EFFECTIVE "SPLL" warns Behind … as well as … to the Side Drivers
All experienced Trailer, RV and Truck Drivers are aware of the need for bright, effective and always working Brake/Turn and Lane Change Signal Lighting.  All would like to be assured that their Brake/Turn/Lane Change Signals are always working and will be effective on "all" behind traffic including adjoining lane traffic. 
Current Federal Photometric Mandates require a minimal Candela output for Brake/Turn and Lane Change Signals … of
80 Candela* (straight back) and at least 11-5/8in²* of "Effective Projected Luminous Lens Area" ("EPLLA") projecting within the official NHTSA “Test Pattern”** of 20° Left/Right; 10° Up/Down, which is being grossly violated by most Trailer, RV and Big Rig "LED" Brake/Turn Signal Light Manufacturers and Importers
       … including the latest ones
sold by Wal-Mart®*** shown here 
                        *for over 80" wide vehicles
                      **Federal Interpretation and Specs for official
“Test Pattern” can be substantiated using our “Link” to "Federal
                         Motor Vehicle Safety Standard #108" (FMVSS #108)
                   ***See Page 5 and our Website for "EPLLA" Violations and "Recall" facts

Incandescents project light in “all” directions making it possible for Engineers and Designers to gather and redirect this extensive light output in many directions while still complying to NHTSA's Effective Projected Luminous Lens Area (EPLLA) and Photometric Mandates, while also having "left overs" that can be used for projecting extra Warning Brake/Turn and Lane Change Signals to Adjoining Lanes.

On the other hand, LEDs are only capable of producing very narrow Conal Projections of  Red Dots whereas it takes many to produce
11-5/8 in²* of EPLLA Area
* that's truly projecting EPLLA Compliant light within the "Test Pattern" with nothing left for Side Lane warnings.                  *Minimal Mandated EPLLA for Vehicles over 80" in Width

LEXAN® POLYCARBONATE is not INDESTRUCTIBLE, but it definitely BEATS ACRYLICS
When a Brake/Turn/Lane Change Signal quits working … the Driver (and the Police) want to be able to quickly and economically correct the situation, which isn't easy when Sealed or Capsulated Bulb  illumination systems need fixing … and outright impossible when LEDs fail … and they do fail!

Exposed Trailer 7/8 Function Tail Light Assemblies can … and do …  get smashed on a fairly regular basis whereas, our "all Lexan® construction limits breakage and stops shattering, and also helps with “cold brittleness” vulnerability for Snowmobile use plus limits “melt-down risk” in high heat applications.

Our HANDY “PAVEMENT LIGHT UP” SAFETY CHECK! FEATURE

Pulling a Trailer is always a nerve-racking experience … particularly, for those who don’t pull Trailers frequently.  Trailer Drivers always feel more relaxed and confident when they know there are no Wiring or Connection problems that may be keeping their Brake, Turn, and Lane Changing Signals from working effectively.  They also want to be assured their Signals are “bright” so they are seen by all Drivers directly rearward and in adjoining lanes as well. 

 To be sure that the Brake/Turn/Lane Change Signals are working and bright … a Driver generally uses a “helper” (if available) to stand in the rear of the vehicle and verify that the Turn and Brake Signals are working properly.  At night … our SP Series Pavement Light Up" Feature eliminates the need for a helper.  The powerful #3157 Brake/Turn Filament projects lots of light in all directions, as well as downwards through our Right and Left, Transparent, Lexan® “Splash Guards”.  This powerful downwards light then reflects off the Pavement … thereby, providing the Driver an easy way to verify that the Left and Right Brake/Turn and Lane Change Signals are working effectively by simply using the Rear View Mirrors!  I can say, from personal experience - "This is a very valuable … worry-reducing … feature”! that none of our competitors can offer.

“SEE THRU" 3rd BRAKE REPLACEMENTS with Turn Signal Option
To Illustrate our Versatility in Vehicle Lighting Invention and Manufacturing, we've recently Tooled "Modularized" versions of all our 15 year old - very popular - Standard "Cap"* "Center High Mount Stop Lights" (CHMSLs)Over a Million of our older #400 and #500 series, Standard CHMSLs are in current use all over the U.S. and Canada along with another Million+ of Cheapened … probably, not working** (or melted) … Chinese Copies of our popular designs.  *"Caps"=Toppers=Canopies     **and for sure Faded and Warped

At the same time, we have Tooled and began manufacturing 10" and 16"* "Modularized" Replacement/Updates" for another Million+ Failed LED Chinese 10" and 16" Imported "Cap" CHMSLS that … because of their huge failure rate …  have degraded "Rear Ender" road safety for all of  us, not to mention degrading the Vehicles' Looks they are used on.
   *Our #910 and #916 Modularized Replacement/Updates.

 These failures "Shouldn't Have Happened", and should be "Recalled" because failed "LEDs" will increase Rear Enders for these Vehicles (along with the Vehicle's Rear Ending them) by at least 40%*, which could have been avoided had not this kind of imported "Junk" been allowed into the U.S. and Canada.
                           *Federal and SAE Tests have shown! 

We believe the six popular size and shaped "Modularized" CHMSLs (shown above) would sell well in any Outlet
where "Rod", "Classics", "Cap" and Specialty Vehicle owners visit
.  See our separate "Feature Sheet" on these
unique products.                                                                                         Totally "Lights Up" - 9in² EPLLA

 Our “Auto Like" STYLING plus our Unique SAFETY FEATURES will be Appreciated!
We're confident … as time passes … and our SPLL and "Modularized" CHMSL Distribution System begins to take hold … our “See Thru/ Liquid Look®” plus our safety-increasing … easy maintenance … and grief-reducing features will prove to be popular* with a large percentage of Owners/Drivers needing Reliable and Legal Brake/turn Lighting.  Further, we're confident we will "eventually" get plenty of praise* for the “SPLL”, as well as for the new "Modularized" 3rd Brakes with Turn Signals products as we have for our "Old Reliable” #701, #702 and 20 Year Old “SP” Product Lines.
          
**See Testimonials

Our "NO RUST, DRIVER SERVICEABLE" and KEEPS WORKING features will be Popular
The development of the #3157 Bulb, resulted from the “Society of Automotive Engineers” (SAE) asking Sylvania® for a Rust-Proof, more precision, Longer-Life “#1157 Replacement” that would continue to provide the  all directions, Hi-Intensity Candela output as the #1157 Bulb has provided Auto and Truck related Industries for 40+ years.   We decided it was time for Trailer, RV and Truck Lights to be converted to New Age types of Incandescents.

Further, to meet our
Goal of ELIMINATING All STEEL in our new SPLL designs … required the elimination of the #1157's all STEEL "Cylindrical Base” and corresponding all STEEL "Grounding Can”

Fact is, Trailer Drivers … particularly Salt Water and Salt Air area Drivers … know that the “Steel Bulb Base" and the "Steel Grounding Can” combination always produces a “rust generating nightmare”, that starts and never ends until all the Steel is eaten away  whenever any significant moisture* gets into the tiny gap between the “Steel Base” and the “Steel Can”.
                        *Less of a problem in fresh water areas, but nevertheless, a frustrating problem on all Lights using Steel Base #1157 type Bulbs

Our adding of the "State of the Art" Sylvania® No Rust, Long life, #3157 Bulb, along with our elimination of all  Steel*, guarantees that “Rust Grief’s” are eliminated.  And … if the Sylvania® Long life Bulb does fail … it can be easily "driver fixed" quickly and economically using our popular "No Tool's" Snap Out Bulb Slide.  Our "NO STEEL" products will significantly reduce complaints, returns, and repair demands commonly directed at Trailer Manufacturers … Aftermarket Distributors … and Dealers. 
                  *We have replaced all internal Steel with Lexan® and "Phosphorous Bronze Contacts"

Also, the need to get rid of all Steel is substantiated by our Competitor's Rusty Steel Bulb Holding system whereas they Copied our SP's outward appearance, but used all Steel internally in these Chinese "Knock Offs"

SAE's #1157 replacement goals also included the straightening, and correct positioning of the 32 and 3 Candela Filaments … in contrast to the always crooked and randomly located #1157 Filaments, which have … for 40+ years … been notorious for generating non-repeating “Test Pattern" Candela outputs, which simply can't be tolerated for today's precision “See Thru” Incandescent Designs.  The new #3157 type Bulbs guarantees Light Designing Engineers a uniform, symmetrical, bright, and, reproducible “Test Pattern” output.

Also, take note! that in our new Rust Proof “SPLL” … as well as in all our Rust Proof #203/#205 Clearance/Side Marker and #327 I.D. Lights* … we now route power to the Bulb Filaments using a “Phosphorous Bronze” Bulb Holding and Contact System.  Note, also, that our Wedge Base Support Systems** provide a "road shock” absorbing feature that should help to further extend the life of "Long life" #3157 Bulbs.          *See our website for information      **Patents Pending

Further, we've heard from the "Grapevine" that a #3157 type Incandescent is being developed that will have a very, very, long 50,000 hour life, which would match any LED, "real life" longevity* while costing only a fraction of what an equivalent FMVSS #108 Compliant  "Legal" LED Brake/Turn Array would cost.
                 
*“Claims” of LED Long life and “Actual” Long life for fully exposed Trailer, RV and Truck service are two entirely different matters 

WHAT’S WRONG with LEDs?
Anyone is able to read about several LED Brake/Turn Signal Federal Recalls* in the “Federal Register" and anyone can see actual LED failures on our streets and highways, particularly 3rd Brake failures on "Caps" … we would like to think that those involved in the day to day, buying, selling and using of Trailer, RV and Truck LED Lighting are asking themselves … How are the LEDs I'm involved with holding up in real-life and long term use” … and are they Legal? andare they worth their cost

*"LED" Recalls that I'm aware of includes “three” Multi Function LED designs from Optronics® and 7 out of 10 LED Brake/Turn Signal failures resulting from the Federal Testing of Ten 4” (Round) Diameter LED Big Rig type Lights from various (mostly Chinese) Manufacturers.  The results are on NHTSA's Website and can be accessed using one of our Website "Links".

Further, know that several, very important, LED orientated “Legal Issues"* are still not being addressed by NHTSA nor by the Trailer, RV and Trucking Industries.  Of course, NHTSA can "not" be held responsible, nor can NHTSA be sued, for being incompetent … but it’s an entirely different “Liability situation” for those buying, selling or using "Illegal" Lighting.
        *“Legal Issues” includes LED "Compliances" to Federal “Photometric" and "Effective Projected Luminous Lens Area" and "3 Year  Outdoor
          Weather and Sun Fading and Warping Mandated Survival” Testing - therefore Non Compliances (Illegal) -  situations "Plaintiff Attorney can thrive on"

"Effective Projected Luminous Lens Area" VIOLATIONS ARE EVERYWHERE




Here's Photos I took at the 2007 “Light Truck” Show in Indianapolis which, perhaps, indicates this Industry is finally recognizing the fact that many more "Standard" and/or more of the expensive "Wide Angle" (Lensed) LEDs must be used to comply to Federal Mandated Law* for minimal "Effective Projected Luminous Lens Area" (EPLLA).  These Photos represent big improvements in "EPLLA" (and big expense increases) over what we have seen in the past.  Today, many Big Rig Brake/Turn Lights are beginning to be Illuminated using between 40 and 80 LEDs in their 4" Diameter Lights, which probably assures that the entire Area brightly lights up when viewed within the official Test Pattern.                   *The European Union Countries also Mandate an "Effective Projected Luminous Lens Area" of 11-5/8in²; however, they enforce
theirMandates
!  Perhaps these Trucks are to be sold in the U.S. and in the EU and that's the only reason the EPLLA Mandate is being complied to?

TOYOTA® CHOOSE NEW AGE INCANDESCENT DESIGNS
Also, take note of the photo above showing “Toyota’s” 4” diameterIncandescent”, “See Thru”, Brake/Turn/Lane Changing Signal Light for "Trucks"* that use the latest #3157 Wedge Base type Incandescent Bulb.          *Additionally acts as a FMVSS #108 Compliant Tail Light

If you could see this 3 Function Incandescent when lit, you’d agree … it definitely demands attention of following drivers

This kind of Incandescent design also looks very modern and “Intriguing” when Unlit as well as when Lit! … a hard thing to effectively photograph.  Further, this type of Incandescent design costs only 1/3 to 1/2 of what a “good quality”, comparable (provably Legal), FMVSS #108 “EPLLA Compliant "LED" equivalent would cost … and consider! … it's "Driver Serviceable" where LEDs are not. 

DON'T TILT LIGHTS or REFLECTORS
Unfortunately, as witnessed at the Indianapolis Truck Show and in many other applications, we all can see daily all over the U.S.A. …
Trailer, RV and Truck Manufacturers are
tilting lights and reflectors any which way they choose for Styling Purposes.  Angling of
just a couple degrees can disqualify most Brake and Turn Signals … and all Reflectors … from
"Legal" FMVSS #108 Compliance status.  

All Mandated Lights and Reflectors for Trailers, RV s and Trucks (with very few exceptions), are qualified, tested … to Mandated Specs … “exactly perpendicular” to two of the Vehicle's three AxesAny “angling” of Lights or Reflectors from these “exact” tested directions requires a separate set of qualifying Tests to be put in the involved Companies files in order to prove … in a Court of Law, if necessary … that the Light or Reflector in question … when Tilted or Misaligned … still complies with FMVSS #108.   Be aware that if a sharp Plaintiff Attorney can show Illegality … he/she can greatly change the financial outcome of any "Rear Ender" or "Clipping" related Trial or Settlement.

WAL-MART® has a Legal Problem
NHTSA's EPLLA Mandate is based upon the long term Safety requirement that Following Drivers see a pretty much contiguous ≈12in² "minimal" of Brake/Turn Signal Lit Up Area"not" 6 to 12 Red Dots representing only a fraction of what's mandated by Federal Law.

Here is a 7 Function LED Brake/Turn 7 Function Light made by "Blazer®"and currently being sold at Wal-Mart®. Since it
only lights up twelve 3/4" Diameter Fresnel Areas when viewed at anywhere within the Limits of 20% Left to 20% Right, 10º Up
to 10º Down (Official Test Pattern), its' "Effective Projected Luminous Lens Area" (EPLLA)* is only 12 x π (3/8)² = 5.3in²,
which is less than half the Federal Minimal Mandated Requirement of 11-5/8in² … for use on Vehicles over 80" in Width …
and significantly below 7-3/4in² Mandated for use on below 80" Width Vehicles.
                  *“Effective Projected Luminous Lens Area” … check out our Website for a better understanding of this
                      Mandated Safety Requirement

Be aware, also, that only 7-3/4in² of EPLLA is mandated for under 80” wide Vehicles … which generally consists of all Autos, SUVs, Pick Ups and small Trailers.  No Manufacturer of Trailers, RVs or Trucks (I'm aware of) uses Under 80" Brake and Turn Signal Lights!   Further - be aware that No Auto, SUV, or Pick Up … I know of … violates the 7-3/4in² Mandated EPLLA Requirement.

In order to be able to claim “in Compliance” to Section S6.4.1 of FMVSS #108, the minimal “EPLLA”* must be at least 11-5/8in², which is clearly Mandated for all Over 80" wide Vehicles … which generally includes most Trailers, Motor Homes, Big Rigs etc. that are routinely Fabricated to the maximum 102" Width.

Adequate "Effective Projected Luminous Lens Areas" (EPLLA) represents a very important FMVSS #108 Mandated Safety Requirement that, unfortunately, NHTSA doesn't actively enforce*.  However, “EPLLA” Non-Compliance violations can, nevertheless, generate huge Crash Liability for anyone … or any Company … ignoring these Mandates enforced by NHTSA or not!
                        *They say they don't have enough funding! … where have we heard that excuse before?

This Wal-Mart® Light has a 4" Diameter Cover Lens (excluding Reflector Area) - whereas, if "all" this area lit up when viewed within the NHTSA Mandated "Test Pattern" … and not beyond … the EPLLA would be π R² = 3.14 x (2)² or 12.56in²*.  However, only 5.3in² of this area Lights Up when viewed within the "Test Pattern" confines - making it "Illegal" in any Court
                        *EPLLA used to be 12.0in² until it was made the same as the EU requires - 11-5/8in² so vehicles made here could be sold i
                           n EU and vise versa

Most LED Brake/Turn Light Importers and Manufacturers … try to cover up their Illegal EPLLA condition … by putting Fresnel Rings or simple Ripples over the entire ≈12in² Cover Lens, but in these cases, it's easily seen that most of this deceptive area doesn't light up at all when viewed within the 20° Left/Right; 10° Up/Down Test Pattern, so these areas cannot be tallied as EPLLA Compliant.

LED "REAL LIFE" and LEGAL Limitations for BRAKE/TURN TRAILER USE
The “real-life” survival rate of a totally exposed Trailer and "Cap" "LED" Brake/turn Signal is nowhere near to what’s being advertised by the average LED Importer and Chinese and American Manufacturers.  Compare any “limited Warranty” presently offered for LED Brake/Turn  Trailer Lights to the "Lifetime Guarantees" that, 10 years ago, were being flaunted.  Fact is, most “Long life” claims are based on Laboratory conditions“not” Real Life conditions.

The LED Long life claim has been “Busted”, at least, for fully exposed Trailer use.  It has, also, become obvious … LED failures, returns, and LED Legal and Liability problems will eventually occur and can prove to be very costly to any involved

Refer to our Website and take the time to read our extensive writings regarding "LED" Failing, Legal and Liability problems, where we discuss … among a variety of other Vehicle Lighting subjects … the problem that LEDs can lose up to 50% of their output - - because a LED using Brake/Turn/Lane Changing Signals can significantly heat up from constant use … on a hot day … in uptight traffic, resulting in a significant loss of Candela outputjust when they’re needed the most!

OTHER LED REALITIES
Have you tried a LED Flashlight?  I find it to be quite dim and lacking in providing adequate “white light”, which I, personally insist on.  Yes, LED Flashlights save on batteries; however … "who wants to settle for Dim, Gray/Blue, Inadequate Light when batteries are readily available"?
As pointed out earlier …
LEDs can project light in only one … very limited … "Conal" direction, which results in following Drivers seeing only one limited direction pointing, Red Dots that most Designers and the Public in general find rather boring when compared to the Fantastic "Incandescent" Designs that are apparent on 3 out of 4 New Autos, SUVs and Pick Ups.

Also, know that the new, so-called,
“LED TVs" don’t use LEDs, except for “Back Lighting”, meaning LEDs are "not" generating the TV Image.  These kinds of bogus claims are simply being used to take advantage of the LED "Fad".

Did you know LEDs don't melt snow", a real safety problem for Roof Mounted (Cap) and unsheltered Vehicle Signal and Presence Lights - and last winter, Traffic Lights in the North "froze over" causing havoc!

Also, many times LED Brake/Turn installations require a special "Resistance Circuit" because LEDs won't activate the "Blinker" device. 

In Florida, the normal Oxide formed on Wire "Whiskers" used in Wire Nut Connection can't be pierced by the small current flow needed for LED Illumination - causing "Wire Nut Connection" failure!

Further … disregard the myth that Headlights will soon use LEDs” – not true! … Truck Light® (or Peterson®?) is currently marketing a pair of LED off-road Headlights that cost $700 a Pair!

QUICKLY FAILING and "NOT" FIXABLE LEDs produces Negative Feelings
As the years go by … many Trailer, RV and Truck Owners/Drivers will come to realize they have been supplied with cheaply made Brake/Turn/Lane Change Signals that have minimum capabilities … and are grief producers … plus, they are probably Illegal in the eyes of State and Federal Law and in the eyes of the Courts as well.

When these persons finally realize they were supplied inferior, troublesome products in order for "someone" to save a couple bucksnegative feelings will be generated towards the Vehicle Manufacturer … the Distributor… and/or the Dealer that supplied them.  "Over the years, I have heard many of my friends and acquaintances curse troublesome Trailer Lights and those that furnished them". 

Pointing out our LED Competitor’s deficiencies and possible Legal, Recall and Court problems, doesn’t mean that we claim our designs will cure all Trailer and CHMSL Lighting problems.  However, we can confidently claim that our quality and unique features will certainly help to keep lighting from being such a grief-ridden subject.

The LED “FAD” is waning
Unknown to most … LEDs Trailer Brake/Turn/Lane Change Lights produce only a fraction of the “Lumens”* output that Incandescents produce.  Also … unknown to most … LEDs project most of their output in a “very narrow”, Conal direction and therefore LEDs are unable to produce the “all directions” powerful output that Incandescents always produce.  The disadvantages LEDs suffer are discussed in more detail on our website.
                  *
Lumens represents the Total Light output in "all" directions coming from an Incandescent, LED, or Florescent Light Source  
    

Also, consider the fact that typical “LED” Brake/Turn/Lane Change Signal being used on our Roadways generate only slightly more than 80 Candela in a more or less “straight back” direction at room temperature… where 80 Candela is FMVSS #108’s "minimal" mandated requirement

he large Plated Parabolic Reflector used in our "Liquid Look®" SPLL had to be “tuned down" because  initially it was producing over 300 Candela, straight back, where 300 Candela represents the “Maximum” in this direction allowed by FMVSS #108*. 
                  *Our Website provides an easy to use “Link” to the official "Federal Motor Vehicle Safety Standard #108" (FMVSS #108)

uto Lighting Designers and Engineers are very pleased to have been given the many Hi-Intensity, “all direction” "Rays"* that only Incandescents can produce.  Engineers can collect and direct these all direction “Rays” into “Hi-Intensity", "bold”, "magical”, “intriguing”, “dazzling” and "many directions"** light patterns that not only enhance road safety, but makes the Vehicle’s rear look terrific in a Parking Lot … at a Traffic Light … or on a Showroom floor … Lit! or Unlit!
                    *"Rays" - my term for comparing the quantity of light coming from a light source
                   **Our all Lexan® Injection Molded "SP Series" Bodies - totally Light Up - every time the Brake/Turn/Lane Change Signals are used

BOTTOM LINE:  Respect for “LED” Brake/Turn Signaling is waning … and the new generation of much brighter - longer-lasting - rustproof - all direction - Incandescents are taking back lost ground

LED SIDE MARKERS" VERSUS "CLEARANCE" Education Facts
Not many people that buy, sell and use Side Marker and Clearance Lights know the difference between them whereas, Side Markers main job is to point light to the side … to warn Intersection Vehicles … as well as nearby Pedestrians … that a large mass of Steel is … or is about to … cross in front of them - so - "WATCH OUT"All Vehicles since 1969 are Mandated to have "Side markers"

On the other hand "Clearance Lights" … are Mandated to indicate the absolute "Extreme Width"* … so as to clearly define the Steel
needed to be "cleared"
in order to avoid a “Corner Clipping”, or “Side Swipe”.  Unfortunately, very few Trailer manufacturers (and no one at NHTSA) understands the importance of indicating "Extreme Width" to passing and about to pass Drivers and they also don't seem to understand the importance of having Clearance Lights at average "Traffic Eye Level" and not allowing them to be mounted on the rear "Sides" of Big Rig Trailers where Following Drivers can't possibly see them … nor should "Clearance Lights" be mounted up high (insisted upon by NHTSA) where they do no good at all … DUMB! … DUMB! … DUMB!
                 *Not 6 to 12 inches inside of the "Extreme Width" - Check our various correspondence with NHTSA on this subject on our website

.S.A. ENGINEERED TOOLED and MANUFACTURED reduces Failures and Returns
All our products … including our newest “SPLL”… are guaranteed for Federal Compliancy to FMVSS #108* and have been designed to also address common problems our competitor’s don’t bother to consider.  Our approach assures minimal Technical, Legal, Liability, and Return problemsall of which are much more likely to be encountered when dealing with Cheapened Import Knock Offs that use unqualified materials and “nil to none” Engineering
                        *Federal Motor Vehicle Safety Standard #108 – try our easy to use “Link” on our Website

Let’sRETURN DESIGN, Tooling and Manufacturing JOBS to the U.S.A.

ll Americans should start making concerted efforts to bring back some original U.S.A. products that we have deliberately, or inadvertently … let go to other Countries. 

Many American Products … have been allowed to be "stolen" … or Outsourced … for as little as 10% in overall Savings, resulting in a huge loss of associated Jobs, which no one considered a problem at the time, but "now" the consequences are being realized.

We - as Taxpayers - are providing ongoing "Unemployment Payments" … "Food Stamps" … "Free Medical" … and a number of other spending of Taxpayer's Funds to the Unemployed … that we wouldn’t be paying if these jobs hadn't been stolen or outsourced for just a "small savings" in the product's price.

Why not start studying what "exactly" is being saved on particular products using offshore manufacturing facilities and workers? Then compare this savings to what it's "exactly" costing U.S. Taxpayers to continue to help the unemployed.   We may find out we'll come out ahead if "somehow" our Governments could give Employers and Employees financial help that brings back some jobs and keeps others from being outsourced at the same cost (or below) what the unemployment benefits are costing.  Who knows! … We may even end up collecting State and Federal Income Taxes as a Bonus.  All Governments should do Studies on this way of thinking.  They now do costly studies on less worthy subjects.

rom now on, we must not only begin to Tool and Manufacture more of our new products in the U.S. but … but we should, also be adamantly increasing our efforts for Exporting gains

hese kinds of efforts can help to put unemployed Americans back to work with "permanent" jobs while also helping to better our disgraceful "Balance of Trade" situation. 

Those who think the jobs we've lost will come back without generating these kinds of efforts are “dreamers”

Further … those that think there will soon be enough Hi-Tech, Wind and Solar work to fill our Job needs are also “dreamers”

SO WHAT'S LEFT?more Government Work? … which only puts us further in the “overspending hole”

Bottom Line:  If we don't bolster our Manufacturing Base and increase our Exports … where “exactly” are the needed Jobs to come from? 

Best regards,                                             


Dennis G. Moore
President

Sierra Design Manufacturing, Inc … Home of Dry Launch® and Convoy® Vehicle Lighting Products 
1113 Greenville Road, Livermore, CA  94550           (925) 443-3140      SierraDesignMfg.Com
We are continually devoting many hours each month to the updating and betterment of our Website …

SierraDesignMfg.com, DryLaunch.com and CopBox.comWe ask those interested in our types of subjects … from time to time … check for our latest products and product updates, plus check out our latest additions to our “Technical & Legal Clarifications”!
NOTE:  Our 33 year old Sierra Products, Inc. Corporate name was recentlychanged toSierra Design Manufacturing, Inc” We changed names to emphasize that we are, indeed, a true U.S.A. Manufacturer and “not” just another Warehouse Distributor of Foreign made products … as, we believe, our old name inferred. however know that our ownership and management has been the same for our 33 year history

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