(Formerly Sierra Products, Inc.)
July 10, 2008
To Whom It May Concern:
What SAFETY LΙGHTΙNG DETAILS are being IGNORED by NHTSA?
Widespread Trailer, RV and Truck Lighting inadequacies and premature failures that are currently being allowed by NHTSA represent costly dangers on our Highways, which are not obvious to the general Public.
These writings are for the sake of those being subjected to these avoidable dangers and for those unknowingly propagating these dangers … as well as for the benefit of the unaware employees at NHTSA … and most importantly … to “Whom it may concern” Company Managers, Lawyers and Engineers “involved” in the safety and liability aspects of these subjects.
I’ve dedicated a lot of effort to try to make all these subjects reasonably easy to understand by anyone reading these writings. However, I’m an Engineer and I find it a real chore to write out Technical explanations in basic, easily understood layman’s language. However, I have given this my best efforts.
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, which contains numerous of our unique “Technical and Legal Clarifications. Or anyone can check on NHTSA website, www.nhtsa.gov.
*other than from Common Sense and 30 years of lighting design and vehicle lighting safety observations
While reading this material, please keep in mind that NHTSA’s continuing allowance of “Illegal” … “quickly failing” … and “unserviceable” 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. Additionally, this in turn, is additionally leading to the dooming of, yet another, American Manufacturing Industry.
These COSTLY DANGERS Result …
When American Trailer, RV and Truck Lighting Manufacturers are still mandated to comply to 40 year old (established) FMVSS #108* Safety Laws that Importing Competitors are now simply allowed to “ignore”. *Federal Motor Vehicle Safety Standard #108
When “LED” Trailer, RV and Truck lighting manufacturers are allowed to ignore …
A. The up to 50% Loss of Output when Brake Light LEDs heat up from normal use on a hot day.
B. “LEDs” have dramatically shortened Lives when subjected to Moisture or hot day Heat.
C. The inability Of “LEDs” to melt snow … a particularly acute safety problem with CHMSLs and Trailer, RV and Big Rig Lighting used in snow areas. Drivers in these areas have always relied on the heat generated by Incandescent bulb filaments to melt snow covering their “Presence” and “Signal” Lighting. *LEDs also put out less candela when cold!
D. When commonly found Lighting with inadequate, non-complying “Effective Projected Luminous Lens Area” (meaning the minimal, seeable “Test Pattern” area mandated by FMVSS #108 is being violated) are causing dangerous “recognition problems” and are not corrected.
E. The narrow “Conal Output” problems associated with LEDs … Check my other Writings!
F. The lack of … anywhere, anytime replacement capability associated with “LEDs”.
G. When the high cost and “Throwaway Requirements” of expensive LED Arrays used in Vehicle Lights generate serious economic demands on the Public and therefore, generate, “doesn’t get fixed” safety problems; problems never associated with Incandescent lighting using standardized, find anywhere … inexpensive Bulbs.
H. The misleading claim that Long-Life hours bragged about by LED manufacturers are mostly based on Room Temperature, indoors, testing conditions, which, of course, represents no where near real-life road and submerging conditions.
Trailer, RV and Truck Tail Light Assembly illumination sources are allowed to remain “non standardized” by NHTSA, and therefore, are not readily available at affordable costs to the American Public.
Approximately 35% of all crashes in the U.S. are “Rear Enders” … including undocumented “Rear Clippings” ? Many of these can result from ineffective or prematurely failed Brake/Turn and Lane Changing Signal Lighting as well as from poorly-positioned or non-existing Clearance Lights
When Unqualified, sun fadable Foreign (junk) Lighting Materials are not challenged by NHTSA nor Border Crossing Inspectors.
When the degradation associated with “Bulb Module” and “Fill and Drain” type Boat Trailer Lights … that is, the resultant internal destruction of Lens and Reflection faceting as well as disabling corrosion is ignored by NHTSA in spite of SAE warnings.
SAE J586 FEB84
6.2.4 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.
When NHTSA’s Lawyers make absolutely no attempt to warn Trailer, RV and Truck Manufacturers of the Federal and Public Liability consequences associated with … directly … or indirectly … the providing of Non-Compliant, ineffective and quickly failing Lighting to the American Public.
When the “anything is OK” attitude is continually endorsed by NHTSA as to the affordable … the lack of findability … and the lack of serviceability of LED Lighting being “force fed” to the American Public.
When Lighting being sold and/or supplied to the American Public (and their Illumination sources) are deceptively claimed to be “Legal” and therefore inferred to be made to “all” FMVSS #108 Physical, Electrical and Photometric mandated specs … while in reality … they’re not compliant to but a small percent of requirements and are therefore illegal for use on American highways.
The claim “NOT FOR STREET USE” is still allowed by NHTSA when everyone knows their statement does nothing to stop street and highway use.
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.
When it’s obvious that NHTSA’s entire yearly Vehicle Lighting Testing Budget is spent on but a very few “exact” Photometric laboratory tests* when only “ballpark tests” … using a simple common 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 obvious and blatant non compliances of FMVSS #108 law for much less than the existing official Lab test costs.
*So that they can be officially admissible in Court … which never happens and provides no results whatsoever because of unpoliced FMVSS #108 Mandates.
When NHTSA Administrators do not occasionally review the original intentions of the 1966 Vehicle Safety Act and compare the “intent” with the actual current costs to the Public.
When NHTSA is oblivious to the importance of requiring the most effective and most conspicuous locations for Side and Rear Lights (and Reflectors) on Trailers, RVs, and Trucks.
When the past 10 years of Carte Blanc acceptance of Foreign junk “LED” Lighting has been permitted by NHTSA without considering LEDs “adverse cost”, “quality”, “size”, or “serviceability”, as well ignoring the inherent ease of “heat and moisture destruction” resulting in safety decreases and cost increases put on the shoulders of the American Public.
Because D.O.T. and NHTSA and apparently White House Administrators are oblivious to the foreign “take over” of … in this case … the American Trailer, RV and Truck Lighting Manufacturing Industries, they are actually subsidizing the distribution* of substandard, dangerous*, and outright Illegal* vehicle lighting products in America. *“Dumping”
An occasional (very rare) NHTSA “Recall” of a Trailer, RV or Truck Lighting does nothing to stop or correct the ever growing violations of FMVSS #108 mandates as they are “now” considered a “laughable and inconsequential obstacle” to all foreign manufacturers selling non-compliant, poorly-made, quickly-fading, and outright Illegal Trailer, RV and Truck Lighting to the unwary American Public.