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TLC #230-1 – What VEHICLE LIGHTING SAFETY DANGERS are being IGNORED by NHTSA?

September 10, 2008
To: Whom It May Concern
From:  Dennis G. Moore, President

Re: "TECHNICAL & LEGAL CLARIFICATIONS" - 2009 Additions to SierraDesignMfgInc.com Writings

What VEHICLE LΙGHTΙNG SAFETY DANGERS are being IGNORED by NHTSA?
Widespread Trailer, RV and Truck Lighting inadequacies  and premature failures that are currently being allowed by NHTSA represent costly, avoidable dangers on our Highways, which are not obvious to the general Public.

These writings are for the benefit of Public safety and to educate those unknowingly propagating these dangers … and most importantly, for the benefit of Company Managers, Lawyers, and Engineers involved in the safety and liability aspects of these subjects.

I’ve dedicated a lot of effort to summarize and make all these subjects reasonably easy to understand.  Considering I’m an Engineer … I find it a real chore to summarize Technical explanations in easily understood layman’s language.  However, I have provided my best effort.

When I could … I’ve referenced the areas I’ve gathered my information from*. For those wanting to take the time to check out my sources and perhaps gather additional information on the subjects covered … direct your questions to our Website … SierraDesignMfgInc.com, and if our more detailed NHTSA criticisms and "Technical and Legal Clarifications” writings don’t answer your questions … I will personally answer them … or you can always try and check for answers on NHTSAs confusing website, www.nhtsa.gov.
           *other than from Common Sense & 30 years of lighting design & vehicle  lighting safety observations

While reading this material, please keep in mind that NHTSA’s continuing allowance of “quickly failing, "unserviceable" and basically "Illegal” Trailer, RV, and Truck Lighting Products … is resulting in not only widespread road safety and public expense losses, but also in significant American job losses, as the importing of unchecked, cheapened and outright illegal Taiwan/Chinese Lighting Imports are resulting in the dooming of most U.S. Trailer, RV and Truck Lighting Manufacturers.


  1. When American Trailer, RV and Truck Lighting Manufacturers are still mandated to comply to 40 year old FMVSS #108* Safety Laws that Importing Competitors are allowed to “ignore”.  *Federal Motor Vehicle Safety Standard #108
  2. When “LED” Trailer, RV and Truck lighting manufacturers are allowed to keep secret the fact that up to 50% of their Output when Brake Light “LEDs” heat up from normal use on a hot day, in bumper to bumper traffic, where and when they’re needed the most!
  3. When ignoring the fact “LEDs” have dramatically shortened Lives when subjected to moisture and heat.
  4. When the inability Of “LEDs” to  melt snow is allowed to generate a real life safety problem involving CHMSLs and mandated Trailer, RV and Big Rig Lighting used in snow areas where drivers have always relied on the heat generated by Incandescent bulb filaments to melt the snow covering their “Presence” and “Signal” Lighting. *LEDs also  put out less Candela when cold!
  5. When most “LED” Trailer, RV and Truck Lighting has Non Complying “Effective Projected Luminous Lens     Area” (EPLLA*), which means just a few (below 60?), Projects “too small” of a seeable projected “Test Pattern” area when compared to what is mandated by FMVSS #108, thus causing a dangerous conspicuity Non Compliance.
  6. When considering the lack of … anywhere, anytime, replacement capability associated with “LEDs”. … Check my other writings on this subject!
  7. When considering the narrow “Conal Output” problem associated with Standard LEDs … Check my other writings on this subject!
  8. When considering the lack of … anywhere, anytime, replacement capability associated with “LEDs”
  9. When the high cost and throwaway requirements of expensive “LED” Arrays used in  CHMSLs and standard Vehicle Lights generate un-warranted economic demands on the Public, while also generating “doesn’t get  fixed” safety problems; which are expense and safety problems seldom associated with Incandescent lighting when using standardized, find anywhere, and affordable Bulbs.
  10.  When the misleading claim that Long-Life hours bragged about by LED manufacturers are based  only on “Room Temperature” and "indoors" test conditions, which represents nowhere near real-life road, weather and submerging* conditions.        *For Boat Trailers
  11. When Trailer, RV, and Truck Tail Light Assembly illumination sources* … for the most part … are allowed to remain “non standardized” by NHTSA, and therefore, are not readily available at affordable costs to the American Public.         *Whether  this source is "LED" or "Incandescent"
  12. When it’s realized that approximately 35% of all crashes in the U.S. are “Rear Enders”  … including undocumented “Rear Clippings”? and many of these crashes result from ineffective or prematurely failed Brake/Turn and Lane  Changing Signal Lighting.
  13. When unqualified, easily faded  Foreign (Illegal) Lighting Materials are not challenged by NHTSA or Border Crossing Inspectors. When the degradation of output associated with leaking “Sealed Bulb Modules" or “Fill and  Drain” type Boat Trailer Lights* …  results in "disabling oil and grime", "fogging" of internal Lens and Reflection faceting  that's being ignored by NHTSA in spite of SAE’s "severe environment" requirement 6.2.4.    *See attached and web site information, DryLaunch.Com SAE J586  Where it is expected that lamps must perform in severe environments, for example, be totally immersed in water periodically, the user should specify lamps designed for such use.
  14. When NHTSA’s Lawyers make no attempt to warn Trailer, RV and Truck Manufacturers of the possible Federal and Public Liability consequences associated … directly … and indirectly … with the providing of non-compliant, ineffective or quickly failing Lighting to the American Public.
  15. When year after year the anything is OK attitude is endorsed by NHTSA as to the cost, reliability, findability … and serviceability of “LED”Lighting being force fed to the American Public.
  16. When Vehicle Lighting and their illumination sources* being supplied to the American Public are allowed by NHTSA to be claimed byImporters and others as “Legal” and … therefore claiming they comply to “all” FMVSS #108 Physical, Electrical and Photometric mandated specs … while in reality … they’re not compliant to but a small percent of the simpler to comply to requirements; so therefore, they are actually illegal for use on American highways.  *Either  "LED" orIncandescent"
  17. When NHTSA … and apparently all other Washington, D.C. Bureaucrats … are oblivious to the “foreign take over” of … in this case … the American Trailer, RV and Truck Lighting Manufacturing Industries. These "do nothing bureaucrats" allow foreign Countries to encourage these kinds of "take overs", and in some cases, with the help of their Government, subsidize the Importer's distribution* of cheaper, substandard and outright Illegal* vehicle lighting products in America so yet another category of American Manufacturers are by design, systematically wiped out.     *Called “Dumping”
  18. When no significant attempts are made by NHTSA to educate American Trailer, RV and Trucking Manufacturers of … at the least … the most important safety mandates of FMVSS #108.
  19. When an occasional NHTSA Recall of a Trailer, RV or Truck Light Assembly does nothing to stop or correct the ever growing violations of FMVSS #108 mandates, because a Recall threat is now considered a “laughable and inconsequential obstacle” to all conniving foreign manufacturers that sell non-compliant, poorly-made, quickly-fading, and therefore, outright Illegal Trailer, RV and Truck Lighting to the unwary American Public.
  20. When it’s obvious that NHTSAs entire yearly Vehicle Lighting Testing Budget is wasted on but a very few “exact” Photometric laboratory tests* when only “ballpark tests” … using a simple Spot Meter and common sense observations … would be adequate to provide public exposure that would force by accusations and embarrassment … the correcting of millions of the most obvious and blatant non compliances of FMVSS #108 law - and all this for a fraction of the cost of the few official, exact Lab Tests.        *Yielding “exact tests” that would be admissible in Court … but, in reality, lighting non-compliances have never gone to Court, and therefore this wasted expense provides absolutely no public safety  enhancing results for the money foolishly spent.
  21. When NHTSA Administrators routinely do not review the original intentions of the 1966 Vehicle Safety Act and compare the current cost of each NHTSA mandated safety device to the current benefits to the Public … to see if the public is getting at least equal safety improvement savings for the money we’re all, only way or another … paying for our Vehicle Safety Devices.
  22. When NHTSA is oblivious to the importance of requiring and Policing the most effective and most conspicuous locations and orientation for Side and Rear Lights (and Reflectors) on Trailers, RVs, and Trucks.
  23. When the past 10 years of Carte Blanc acceptance of Foreign and U.S. made junk “LED Lighting" has been permitted by NHTSA without consideration of cost, quality, output and durability.  Also, NHTSA continues to totally ignore the inherent ease of LED heat and moisture destruction resulting in additional safety decreases and cost increases put directly on the shoulders of the American Public.
  24. When the claim “NOT FOR STREET USE” is still allowed by NHTSA when everyone of importance knows this statement does nothing to stop illegal street and highway use.  Particularly dangerous is (for example) the current allowance of several LEDs collaged on (for example) a common #1157 type Bulb Base and advertised or inferred as an equivalent #1157 Replacement when Photometric Tests show as low as 15% output compared to ordinary #1157 Bulbs.  More on this on our web site.  

IMAGINE the NEGATIVE RESULTS