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June 26, 2007
To: TRAILER, RV and TRUCK Manufacturers, plus associated Replacement Parts Distributors and Dealers … plus “others” these subjects might concern!
From: Dennis G. Moore, President
Re: Buy, Distribute and Use only “LEGAL”, “CONSPICUOUS” and “RELIABLE” Lighting!
DON’T INCREASE YOUR LIABILITY Everyone involved with OEM or Replacement Lighting for use on Trailers, RV’s and Trucks should realize they are most likely being misinformed by the average Lighting Vendor calling on them. Therefore, those involved in the lighting selection process should be asking these vendors all necessary questions … and they should be hearing the proper answers and assurances … in order to steer their Company away from avoidable Complaints, Recalls and Liability problems.
Furthermore, be aware, when OEMs or Replacement Part Distributors supply their Dealers with any illegal or non-lasting lighting … they are also implicating their customers in unnecessary complaints, Recalls and Liability Problems that everyone concerned would just as soon avoid.
LIABILITY far into the FUTURE Trucking Industry management can (more or less) correct any Non Compliant lighting problem as they become aware of them. However, the typical Cargo, Utility, Horse, Boat Trailer or RV Manufacturer cant’ easily retrieve Non Compliant Lights supplied to their Dealers/Customers, thus leaving themselves and their Distributors, vulnerable to being sued for as long as the Non Compliant (Illegal) lights remain on the Vehicles these lights were initially put on, which can mean many years of liability.
If, (for instance) any of the popular Big Rig, “4 inch Round” … “LED” Brake/Turn/Lane Changing Signal Lights are later found to be below minimal Federal Motor Vehicle Safety Standard #108* “Photometric” “EPLLA” or “Lasting” Standards … or they obviously Fade or warp … and therefore are “Non Compliant to FMVSS #108” … Truck Fleets and/or Independent Truck Owners can simply “pop off” the faulty product from their 4” Rubber Grommet and exchange them for, new, LED or Incandescent Brake Lights that can be proven to be FMVSS #108 Photometric, EPLLA, and Heat Compliant so that these managers and owners can quickly squelch the possibility of being accused of using Non Compliant … therefore … Illegal Lights. *FMVSS #108
When a vehicle manufacturer finds out they’ve been providing the Public with Illegal Lighting … they’ll also find out how the Guarantees and Promises they’ve been given by the supplying lighting vendors are honored or not honored?
Every year, Millions of Autos, RVs, Trailers and Trucks, “Rear End” or “Clip” the rear ends of other Autos, RVs, Trailers and Trucks where each “accident”, “crash”, “wreck” or “multi vehicle pile up” can start one or more intertwined lawsuits entailing damages to vehicles … injuries … and sometimes deaths, which in turn, can involve partial or total blame put on any kind of Vehicle Safety Device that can be shown to be “Non Compliant” … therefore illegal … to Federal Mandated Standards. This blame can result in thousands to millions of dollars in Lawyer, Court and Settlement costs.
THE PLAINTIFF can be TURNED INTO the DEFENDANT The accepted thought process that … “it’s always the fault of the rearward vehicle” when the forward vehicle is “Rear Ended” or “Clipped” – is not valid! Particularly when the forward vehicle can be shown to be using Non-Compliant (Illegal) Brake/Turn/Lane Changing Lights. In this case, the forward vehicle (Plaintiff) can be converted to a partial or wholly responsible Defendant and can be successfully blamed … partially or wholly … for damages, injuries and deaths resulting from a … for instance … Non Compliant to FMVSS #108 or non working Brake/Turn/Lane Changing Signaling System.
You NEVER have enough LIABILITY KNOWLEDGE You can learn a lot from the attached Federal “EPLLA” Letter and other included writings, plus greatly benefit from our always being updated “Technical & Legal Clarifications”* (“TLCs”), four new ones are attached. Additionally, we know you’ll learn even more when you thoroughly … and in detail … question all the companies trying to supply you with Lights or Reflectors destined to be put onto public use.
Since most company manager’s … including me … tend to try and not think about Liability Vulnerability … I’ve attached a pair of still valid Mechanical Engineering and Lawyer’s Articles, which I read every so often to keep in sight what responsibilities my Company and I have to the Public – I hope you consider reading these.
After fully comprehending all this new legal and practical knowledge, we sincerely hope that you’ll inform your Company “Principals” and your Company Lawyers of what you’ve learned.
WARNINGS are currently being GENERATED As the attached five Trade Articles outline, the “National Association of Trailer Manufacturers” (NATM) and their Legal Council, plus associated Vehicle Liability Insurance Companies and their Lawyers … as well as Safety and Consumer Protection “Watch Dog Groups” … are finally becoming aware of the hidden liabilities I outline in the attached writings. Some of these kinds of organizations have begun warning Trailer, RV and Truck Manufacturers … as well as the Public … about poorly Engineered, poorly made, and outright Illegal Trailer, RV and Truck Lighting* that is currently being permitted by NHTSA to be put into use in our roadways. *particularly “Brake Lights”
Also, I’ve attached a recent NHTSA Legal Counsel letter personally sent to me from the most current “Chief Counsel” at NHTSA emphasizing the importance of recognizing and correcting any “Effective Projective Luminous Lens Area” (EPLLA) non compliances. Note where the NHTSA Lawyer actually uses the word “Illegal” in the second paragraph.
JUNK DEMEANOR Inadequate or dimmed Photometrics, as well as prematurely Failed Brake/Turn and Lane Changing Signal Lighting is obvious to the public … as are Faded and Warped Lens and Reflector Plastics … all of which visually degrades the Vehicle they’re attached to. When the Public sees junk! … the Vehicle’s reputation is then tied to a junk demeanor.
WHEN THERE’S A WRECK – YOU CAN BE MADE LIABLE! Have you heard of the recent “Non Compliance Lawsuit” in Florida that was propagated from the practice where some Florida Trailer Manufacturers had been offering Brakes on their Trailers over 3,500# Gross, only on an “optional basis” rather than honoring Florida’s (and NHTSA’s?) mandates to supply “all” Trailers over 3,500# with Brakes. This Law doesn’t say that “Brakes are Optional” … the law says … “Brakes are Mandated”!
Then, all of a sudden – a Trailer Manufacturer got sued because an injured Plaintiff’s Lawyer found out about this ignoring of mandated law and was able to successfully blame some (or all) of the Injuries and damages that occurred to his/her Client due to the omission of Brakes … that should have been on the Trailer … but weren’t!
Now the cat is out of the bag and all the “Plaintiff Attorney Organizations” … overnight … are made aware of this case from the Web. This means that… from now on … all Plaintiff Lawyers made aware of this Illegal “Non Compliance” will be seeing to it that they’ll take full advantage of every damage, injury and death case that involves Trailers without mandated brakes.
This example clearly demonstrates the fact that even though this mandated Brake Law wasn’t being enforced by the assigned Federal and/or State authorities … never the less … this law was ultimately enforced using Civil Penalties. Also, realize that the worldwide exposure of this situation on the Internet has started what’s just the beginning of many costly Lawsuits that will go “on and on” over the years … as long as crash-involved Trailers without mandated brakes still remain in operation. Also, realize Federal and State authorities do not have to assume any of the blame as they are sufficiently isolated using existing bureaucratic protection laws that they can (and will) always use to totally separate themselves from any liabilities … “you’re left holding the liability bag”.
Bottom Line … Don’t get involved in
NON COMPLIANT practices whether or not they are being Federally or State
enforced! WANT SOMETHING with NEW LOOKS? … yet LEGAL? … yet AFFORDABLE?
By totally understanding the facts and common sense rational we’ve tried to
convey in these writings … those hunting affordable, legal, and lasting
Lighting will soon realize they are going to have a hard (or
impossible) time finding any inexpensive, legal and lasting 6/7 Function
“LED” Brake/Turn/Lane Changing Signal Light Assemblies particularly
in
There are a couple 6” Oval* and 4” Round* Big Rig (3 Function) “LED” type Lights currently on the market that appear to have adequate “Effective Projected Luminous Lens Area” (EPLLA). However, as to their actual Photometric Outputs being aimed in the required directions and the Longevity of the materials used, not to mention not knowing the real-life, LED Candela Heat Losses and failure points … non compliant, legal and, therefore, liability problems still exist. *Used by the millions mainly on trucks
HERE’S the NEW “DETROIT LOOK” We believe you will agree that our revolutionary new, See Thru/Chrome, “Detroit Look” is truly modern and unmistakably “up to date” when compared to all the new Autos, SUVs and Pick Up Trucks Tail Light Designs coming from Detroit, Japan and Europe. I’ve attached a couple unfinished (still drafts) of New Product Announcements, which outlines some of the truly unique features in our latest 3-1/2 x 6 … and our (soon to be) 3 x 8 sizes of 6/7 Function designs. Our unique design approaches can give your Trailer, RV, or Truck a LED resembling look at 1/2 the price of LEDs, while providing twice the output with no questions as to Legality, Longevity, or Serviceability.
Our unique modern designs are offered in direct contrast to the “Same Ol, Same Ol, Plain-Jane” Incandescent 35+ year old, Multi Function, designs … but, they are also official at 1/2 the cost of LEDs.
Note that no other Incandescent 6/7 Function Trailer Lighting … except ours … offer this revolutionary, “See-Thru/Plated” Styling … which most Detroit, Japan and European Auto, SUV and Pick Up Truck lighting designers are now using, where the Fresnel Rings and Pillow Shaped, Refractive/Reflective faceting have been done away with. You now actually see the Bulb over a background of glistening plated Reflector Faceting …very Cool looking! … Check it out! … Get other’s opinions!
Auto Designers and Marketing people can be confident this kind of Incandescent styling passes all FMVSS #108 mandates, plus looks great on the highway, as well as on any showroom floor … Unlit as well as Lit. These people also know they are paying slightly more, for the expensive Plating, etc., however, they also know this approach still only requires but 1/2 to 1/3 the cost of adequate and Legal LED Designs. They also know they’ll be selling more $30,000 to $60,000 Autos, SUVs and Pick Ups using these unique, intriguing, See Thru Looks similar to what we’re offering.
LEGAL and LASTING “LED” Lighting from “Sierra” We have begun telling our current customers that we’ll be offering “LED” versions of our newest 6/7 Function SP-LL Designs, as soon as the “Effective Projected Luminous Lens Area” and the very important “LED Heat Loss” issues are formally addressed by NHTSAs Crash Avoidance and Compliance Departments.
I’m sure the ultimate solution for these Brake/Turn “EPLLA” and “HEAT LOSS” Non Compliance subjects will require the addition of many more, and/or higher quality, “more scope” LEDs to the many existing, obvious Non Compliant to FMVSS #108 designs, which of course, will result in a significant price quote increases!
MORE LEDS AND LARGER EPLLA As to the subject of adding more LEDs, you’ll note from the attached photos … the “Work Truck” Industry has started to recognize the need for more LEDs in order to assure compliancy to FMVSS #108 Effective Projected Luminous Lens Area and to compensate for the real life LED Heat Loss circumstances. We’re also seeing the typical Big Rig, 3 Function, LED Brake/Turn designs that were using only 7 to 12 LEDs, being converted to 40+ Versions … observe the transformation all over the U.S.
At the “WORK TRUCK CONVENTION”, we saw LARGE “LED” ADDITIONS I recently attended the “Work Truck Show” in Indianapolis. I saw several Work Trucks where Manufacturers are obviously starting to use much larger in area LED arrays … now, using between 60 and 120 “LEDs” in their Brake/Turn/Lane Changing Signals. This indicates that Work Truck Manufacturers see the importance of complying to the Federal “Effective Projected Luminous Lens Area” mandate of 11-5/8in² as well as the need to assure their customers and NHTSA that they have adequately compensated for real life LED Heat induced Photometric Losses and other contingencies that Auto, SUV and Pick Up designers and Engineers routinely take into consideration so as to always be able to insure Public Safety … during the entire long-life* of their provided Brake and Turn Signals. *minimum of 10 to 20 years? Further, I just found out that WESBAR® (CEQUENT®) recently started marketing a New LED 6/7 Function Trailer Light that does satisfy the 11-5/8 in² Federal EPLLA mandate. They’re $100 a pair Retail … probably $40 to $60 per pair OEM. However, they’re Sealed where Expansion/Contraction cycles usually results in water leakage and “suck in” degradation of the LEDs and/or LED Circuitry. Also, we don’t know if they can stand a 50% Decrease in photometrics due to Ambient and built up internal LED “Junction Heat” … we’ll see!
Another interesting trend I observed at the Work Truck Show that relates to “LED New Looks! versus Incandescent New Looks”. Toyota’s Truck Division is the first (we know of) that has totally circumvented the idea of using LEDs in their new Brake/Turn Lights and have instead adopted very intriguing, modern looking “Incandescents” that provide their Trucks with the very cool “See Thru/Chrome Look” similar to ours and what we have been seeing coming out of Detroit, Japan and Europe for the past 5+ years, while only costing ≈½ the price of “Legal* LED” Brake/Turn/Lane Changing Signal Assemblies. *assuming an affordable and Legal and lasting 6/7 function “LED” Light Assembly can be found!? … I haven’t seen one yet!
NHTSA MUST ENFORCE their PHOTOMETRIC, “EPLLA” and PHYSICAL TESTING MANDATES It shouldn’t be long before the new employees at NHTSA realize what they’ve inherited in the way of “LED” related “Effective Projected Luminous Lens Area” (EPLLA) and Outdoor moisture and heat “Lasting” compliance problems. It’ll be interesting to see how NHTSA’s Legal Counsel Lawyer’s rationalize the millions of … now in use … LED Brake/Turn Lighting that has been allowed by NHTSA to outright ignore FMVSS #108 “EPLLA” and Physical Testing Mandates.
To get the enforcement of Federal Motor Vehicle Safety Standard #108 back on a legal and practical track … NHTSA can’t simply continue to ignore the 39 year old Brake and Turn “Effective Area” (EPLLA) mandates that are currently being violated by far too many LED Brake Light manufacturers, because these “EPLLA” minimums were established using irrefutable human response tests, while at the same time, making an area provision for road dirt and splash obscuring problems. Furthermore, NHTSA, also, cannot reduce the 7-3/4in² or 11-5/8in² EPLLA area mandates just because violations are rampant.
NON COMPLIANT … Non Lasting … LENS and REFLECTOR MATERIALS We can show that most … if not all? … Imported Lighting components, including Lenses and Reflectors are using unknown?, unqualified? materials* that can prematurely lose their Color and Warp, which promotes cracking** and water entry, resulting in disabling rust and the destruction of the LEDs and the LED circuitry, while also resulting in Lenses and Reflectors losing their projection and reflection qualities …– see CHMSL failure photos attached. *Particularly note the millions of non working LED “CHMSLs” (Center High Mount Stop Lights) and their turned white Plastics … seeable on Pick Up Truck Caps/Shells/Toppers all over the U.S. **Ask about “Innovative’s” 6/7 Function LED “Cracking Problem” on Boat Trailers
30% to 50% SUMMERTIME “HEAT LOSSES” in LED BRAKE/TURN/LANE CHANGING LIGHTING It’s about time NHTSA’s “Crash Avoidance Department” faces the fact that there can be as much as a 50% loss in LED Candela output when fully exposed “LED” Brake/Turn/Lane Changing Signal Lights heat up from normal, Sun and hot pavement exposed use in slow moving, close up traffic … on a hot day, which represents common summer conditions found all over the U.S.A. This type of traffic represents conditions where full strength Brake, Turn, and Lane Changing Signals are needed the most. Here’s a vital road safety reality NHTSA’s past and present personnel have totally neglected for more than 10 long years. Checkout the reasoning “Rulemaking” gave for not addressing this subject in 1994 and 1998 and up to 2007 (attached).
Also, check out the Federal website addressing Heated LEDs from OEM Letter – where a 70°F “Junction Temp” increase actually halves the typical LED’s output … it’s true!
AUTOS, SUVs and PICK UPS are “ALWAYS” FMVSS #108 COMPLIANT On the other hand, try and find any Auto, SUV or Pick Up manufacturer in the U.S.A., Japan or Europe that is violating the minimal Photometrics or minimal “EPLLA” or minimal Outdoor Longevity Testing Federal Mandates. Simple Common Sense … Economic Sense, and their Corporate Lawyers will not allow them to violate, FMVSS #108 and SAE Mandates.
It’s a fact that Detroit, Japan and European SAE type Engineers and Management always see to it that all FMVSS #108 Mandates are totally complied with in every one of their Incandescent and LED Multi Function Tail Light designs, while also providing additional outputs to compensate for the predictable “LED” heat losses in their specific LED designs while being sure to always provide proper materials that will hold up under all adverse road, heat and bad weather conditions. Unfortunately, this cannot be said for the typical Trailer, RV or Truck Brake/Turn Signal Lighting System. THE LAWYERS are COMING While NHTSA (hopefully) updates their “Crash Avoidance”, “Rulemaking” and “Compliance Department’s Contributions” … realize that all Trailer, RV and Truck manufacturers that continue to put Non Compliant (illegal) Lights on their vehicles … are greatly increasing their chances for any astute “Plaintiff, Civil Case, Lawyer” … sooner or later … factually accusing them of supplying “Non Compliant” (Illegal) Lighting to an Accident, Crash, Wreck or Multi Vehicle Pile Up being litigated.
Even if you claim you’re innocent … the related Lawyers Fees, lost time, and related grief will likely cost you more for only one Rear Ender, or Clipping entanglement than you could possibly save by gambling on buying and using Non Compliant Brake/Turn/Lane Changing Lights.
When a “Non Compliant to FMVSS #108” accusation is brought up in Civil Court – and the Defendant is not able to effectively refute the charge … this is all any Judge or Jury needs to blame any involved persons or companies for the damages, injuries and/or deaths that their Non Compliant Vehicle Lighting partially or totally caused. Also know that “Non Compliancy” is easily provable in Court using already available Federal writings. It’s irrelevant whether or not NHTSA is actively enforcing written Compliancy Mandates.
7 OUT OF 10 “LED” BRAKE/TURN Federally Tested “FAILURES” The National Association of Trailer Manufacturers (www.NATM.com) points out in one of their “Warning Articles” that a recent series of official Federal Tests performed on randomly gathered “LED” Brake/Turn/Lane Changing Signal Lights … found that 7 out of 10 “LED” Brake/Turn Lights being currently offered and sold to Trailer, RV and Truck Manufacturers … significantly failed the Federally mandated minimal Photometric Test Pattern output requirements of FMVSS #108 and therefore, required Recall.
Of course, since very few Illegal lighting products are actually returned in a typical Recall … anyone involved with selling or using these 7 out of 10 failures … are now facing a lifetime of Civil Liability attached to all the vehicles that continue to use these Non Compliant … therefore, Illegal Lights.
INCAPACITATED REAR FACING REFLECTORS and LENSES also INCREASES LAWSUIT VULNERABILITY Realize too, that …any rear projecting Reflector or Lens that deteriorates below FMVSS #108 mandated minimal during its’ lifetime … can be considered a public danger and represent an act of neglect by those involved in letting this happen, not to mention being in direct violation of SAE J1398, Sections 6.2.3 and 6.2.4 which can put more unwanted Liabilities onto the OEMs and Distributors providing the Public with these kinds of failing products.
6.2.3 Performance of lamps may deteriorate significantly as a result of dirt, grime, and/or snow accumulation on their optical surfaces. Installation of lamps on vehicles should be considered to minimize the effect of these factors. 6.2.4 Where it is expected that lamps must perform an extremely severe environments, such as off-highway, mining, or fuel haulage, or where it is expected that they will be totally immersed in water, the user should specify lamps specifically designed for such use.
This is a subject not specifically addressed by FMVSS #108 … however, if neglected, it will put the Vehicle Manufacturer (plus any associated Distributors and Dealers) in a position of violating road safety common sense, as well as violating the 1966 Vehicle Safety Act … that is! … not providing the public with “Lasting*, Conspicuous, Presence and Intentions Lights and Reflectors”. *”Lasting” … is estimated to be, at least, 10 to 20 years by most SAE Engineers
“TRAPPED AIR” … GRIME DEGRADATION Even when using the “Trapped Air Concept” for Boat Trailer Submersible Lights … which “Sierra” was the first to market 25+ years ago … the “Compression Column” of water will cover most … if not all … of any bottom-located, Rear Pointing Reflector’s “Reflex Faceting”, therefore allowing Oily, Silty, Launch Area “Grime” to accumulate and destroy the typical bottom-located Reflector’s effectiveness.
Note that “Optronics®” … and other Import Copiers have been selling 3 ½ x 6 so called, “Knock-Offs” of our popular “SP” Submersible Designs using unprotected bottom-located Rear Reflectors which will soon result in hundreds of thousands of Boat Trailers being without effective Rear Reflectors, and therefore the Trailers using them will be very vulnerable to being run into in a “Parked” situation at night such as when sitting on the shoulder of a road* with the lights off, which causes a very dangerous safety hazard adding more catastrophic liability to those involved with providing such products to the Public. *with a Flat Tire or when pulled onto the Road’s Shoulder for whatever reason Be aware that all of our 20 year old, “Old Reliable” 3 ½ x 6 “SP”* Designs have always had bottom positioned Rear Reflectors; however, they have “always” been protected from launch and road dust and splash wettings. Be aware that Grime and even “hanging water droplets” cancel Reflex effectiveness … prove this to yourself using a flashlight and a grimy wetted Reflector.
*Road Proven for 20 years on quality
boat trailers like:
Unlike the cheapened Optronics’®, Wesbar®, etc., 3-1/2 x 6 “Plain Jane” Incandescent, Fresnel using, Knock Offs of our “SP” Designs … we have always protected our very important Rear Pointing Reflector by specifically using a waterproof … separately sealed … Lexan®, inside located, transparent window, which represents to us a significant increase in expense for tooling and materials because more costly “Slide Type” Injection Molds and extra Lexan® (Polycarbonate) are needed. Of course omitting this protection … as Optronics® and Wesbar® (Sequent®) have done … saves them money but causes yet another liable situation put on the OEM’s and Distributors using and selling these kinds of cheapened products.
Note, our Trapped Air Designs* work well for not only Submersible applications, but they perform just as well on all kinds of Trailer, RV and Truck applications where our (no tools) Snap-Out … Serviceable … anytime, anywhere all Lexan® features are also, greatly appreciated by all OEMs, Dealers, and Trailer owners familiar with these unique features. *They’re permanently sealed … except for the bottom “Compression Chamber”
“FILL and DRAIN” … DESTROYS ALL REFLECTORS and LENSES In the “Fill and Drain” designs made by Peterson®, Wesbar® (Cequent®), Optronics® and others … since the entire light is allowed to “fill” with grimy water during submersions … accumulated grime and dust deposits cover “all” the internal reflective, refractive faceting … therefore, destroying the effectiveness of the Reflectors, while the grime deposits also destroys much of the Lenses’ Photometric outputs as well.
“Sierra” has actually provided a solution* to this safety grime and dust degradation problem rather than totally ignoring the situation, which Optronics® and Wesbar® (Cequent®) and other “Cheapening Copiers” making 3 ½ x 6 Copies, continue to do … unchallenged by NHTSA Compliance and Crash Avoidance authorities … and resulting in unavoidable long term Liabilities that don’t go away! *Our newest SP-RE “Air Trapping” designs will have the Rear Reflector “top mounted” so internal, lower grime and road splash deposits don’t represent a significant safety problem
“DUAL COLOR” Streamlined, 5 FUNCTION “WING TIPS®” save $ and energy In spite of the several cheapened Taiwan Patent Infringing “Wingtip® Copies” haunting us … we are still pointing out our bonus built-in features incorporated into our 2 Color, 360° visible, WingTip® designs which simultaneously points Red light to the Rear and Amber to the Front, so that just a single Wing Tip photometrically complies with both the forward and rearward pointing FMVSS #108 Clearance Lights mandates, while additionally providing a legal Side Marker … plus a bonus “Back Up, Location Light” … and, also, provides augment Tail (Presence) Lighting. This means up to 5 Safety Functions can be added to each side of any Trailer, RV, or Truck while using only one #168 bulb that draws a tiny (1/4 amp) amount of energy.
WingTips® can be mounted on the sides or rear of any vehicle providing super “Conspicuous, Presence Lighting”. They can be pointed up or out and are most “conspicuous” when used sticking out somewhat beyond the width of any Trailer, RV or Truck … which is allowed … and even encouraged by NHTSA and SAE, as well as the Federal Highway Administration (FHWA).
Wing Tips® (for sure!) comply to … “Representing the Extreme Width” … mandate of FMVSS #108. Furthermore, be aware that Wing Tips … and our unique, All Lexan®, “Crossover Wire Protectors” … can be stepped on (or not!*) while also acting as an optional “Foot Friction Pad” for those wanting (if allowed) to climb on the fenders*. *We have a “NO STEP” model as well
Further, realize that NHTSA, SAE and FHWA have “always” allowed any Light or Mirror to “stick out” beyond the maximum 102” Vehicle width limit. Ask them!
MONEY SAVED On Trailers, RVs and Trucks over 80” in width that are mandated to have front as well as rear pointing “Extreme Width”* Clearance Lights … we estimate … the average OEM must spend ≈ $2.00 for each Amber and Red Light, or ≈ $4.00 for each side plus the required extra installation and extra wiring costs. Our, all Lexan®, 2 Color WingTip® designs save half of this cost by requiring just one light and installation and wiring on each side, while, at the same time, also providing a bonus … and always appreciated “Backing-Up, Location, Safety Light”, plus providing a 360°visual scope … which makes our Wing Tips® clearly conspicuous and FMVSS #108 compliant at all angles to all nearby drivers and pedestrians. These are not features that are Federally or SAE mandated … but certainly will be appreciated by old and new “Trailer Pilots” who will always be thankful to anyone who helps to eliminate some of the grief's and safety problems that most of us have experienced in the “Trailer Towing Process”. *Sometimes “Overall Width” is used … meaning the same thing as “Extreme Width”
TAIWAN TAKE OVERS Our 2 Color, Red/Amber, Wing Tip®, 360º visible, lens design (that we also pioneered), has also been duplicated by the “always copying and cheapening” Taiwan Importers using already inferior and FMVSS #108 unqualified materials in contrast to our exclusive use of cold/hot tolerant … tough and fade proof, all Lexan® construction. Furthermore, Optronics® and two other Copiers have actually shown the nerve to infringe upon our Design Patents – a practice that represents typical “Taiwan Morals” and will result in another set of legal problems for “any involved” using these Patent Infringing Products.
It still amazes me how foreign manufacturers can simply disregard American Laws and Patents, while, also, using “Ιllegal Pirating Government Subsidies”? that are used to wipe out … one at a time … selected American Industries. And it also amazes … plus infuriates me … that our Government and Congress personnel stand by and do nothing about these situations!
GSA DOESN’T WANT NON COMPLIANT LIGHTING on their Vehicles The “Government Service Administration” (GSA) is (I believe) becoming aware of the Non Compliant Lighting being put on Vehicles they buy for Federal Government Agencies. The people manning the GSA’s booth at the last “Work Truck” Show in Indianapolis said to me “GSA has always counted on NHTSA policing the Lighting being put on the Vehicles we buy!” However, GSA officials are now finding out this isn’t happening and are dismayed (to say the least) when they find that any Non Compliant, Fading, Short-Lived, Unserviceable “Junk” Lighting is being allowed to be supplied to them … and then passed on to other Federal Government Agencies* … without GSA personnel (and many others) being made aware of what’s happening! *Same thing is happening on a State level as well
WE KNOW LIGHTING LAW and WE CAN PROVE IT … IN COURT! For 30+ years, we have used Calibrated Photometric Equipment that is directly traceable to the U.S. Bureau of Standards so therefore, we can prove complete compliancy for all our products to all FMVSS #108 “Photometric”, as well as to “Effective Projected Luminous Lens Area” (EPLLA) and “Longevity Assuring” mandates. We can also perform all FMVSS #108 mandated Dust, Moisture, Heat and Vibration Tests. Plus, we’re able to show absolute proof of using never fading, heat/cold tolerant, lasting and tough, FMVSS #108 compliant* GE® Lexan® (Polycarbonate) used in all our Lenses and Reflectors. *Including the FMVSS #108 mandated 3 Year Outdoor, Ozone, Ultraviolet and Heat Tests in Nevada and Florida
As a matter of fact, at one time, we were officially approved as a “Certified Vehicle Lighting Testing Lab” by the California Highway Patrol Engineering Department. However, now the CHP Engineering Division* relies on NHTSA to police FMVSS #108 mandates*, which … we all, now, know … isn’t happening! *as do most (all?) State Governments
Additionally, be aware that “Sierra” has already been Plaintiffs in two long Federal Trials in Milwaukee and Chicago directly involving FMVSS #108 Law, which included Defendant’s Company Record Subpoenas plus … “Involved” Company Personnel Depositions … plus trial testimony from California Highway Patrol Lab and East Coast Vehicle Lighting Testing Lab personnel. One of these Federal cases went all the way to the U.S. Supreme Court.
This background should indicate … we know FMVSS #108 Law in detail! … and therefore, our experience should also indicate … we can effectively help our customers avoid Lawsuits and Recalls that we know! they would just as soon avoid.
PASS IT ON Please “pass on” all you learn from these writings, in addition to what you learn from questioning your current lighting suppliers. We know your “Principals” and your Liability Lawyers will appreciate being furnished this valuable information.
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