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The most recent? Recall … against “Optronics” products … for
over 50,000 “LED” 7-Function Lighting Kits … sold by
“Unified Marine” … NHTSA officially determined that these Optronics’
products failed FMVSS #108 mandated Photometric (“Test Pattern”)
requirements in several ways, which is detailed on the Web
under:
http://dms.dot.gov – Document Number 19792. These particular
7-Function “LED” Lights were supposedly meticulously designed and
FMVSS #108 tested for “Unified Marine” by the “Optronics”
Company of Taiwan. Furthermore, this is the 1st or 2nd
of three recent Recalls for Optronics’ 3- and 7-Function Lights
in just the past two years … this time, at Unified Marine’s
embarrassment and expense.
Unified’s (Optronics’)
plea for “Inconsequential to Public Safety” status on these many
Photometric Non Compliances… was denied by NHTSA, so another
Recall is under way for these ≈ 50,000 “LED”6/7 Function Kits, plus
Recalls for 2 other Optronics 3- and 7-Function “LED” Lights … see
http://dms.dot.gov – Document Number 19792.
*See
http://www-odi.nhtsa.dot.gov/cars/problems/recalls
By
“studying” these numerous, expensive, and precise NHTSA Tests used in these
Recalls … and, at Tax Payer’s (our) expense … anyone can see for
themselves the many and severe Non Compliances that “Optronics”,
recklessly (or ignorantly), designed into their LED Light Designs.
OEMs and Lighting
Distributors
should take the time to look over and discuss this failing data while
addressing the several adverse “LED” problems and “forewarnings” that
become apparent when looking over these standard FMVSS #108 Compliancy Tests
and our “TLC” discussions, which everyone involved, should find very helpful
for the selection of “Legal”, “Safe”, and “Grief Reducing” Lighting for
future customer offerings.
Also, realize that these standardized Photometric Tests did not
include any demands put on Optronics (or
Unified) to supply NHTSA proof that all the Lenses and
Reflectors plus all the Supporting Components of these three Lamp
Designs, had indeed, been tested to the many FMVSS #108 Federally
mandated Outdoor and Physical Tests in order to guarantee everyone
involved … especially the public … against premature
“Ultraviolet”*, “Hot/Cold Weather”, “Thermal Shock”, “Submersion”, “Grime
Buildup” and “Road Vibration” failures. *Lens
Material loosing its color and/or crazing
Of course, along with detailed Photometric Testing, “Real Life Endurance
Tests” should also always be required so as to guarantee the
overall integrity of all components, in the Lamp Design … including any
“LED” circuitry used … because … even though LEDs may “claim” the
capability of lasting a long time … their very vulnerable circuitry
can, at any time, fail due to heat, moisture or UV exposure.
However,
for whatever reasoning, none
of these common sense, quality and safety assuring tests were requested
by NHTSA in these recent Investigations!
Further, these reports showed that there was absolutely no demand
from NHTSA requiring Unified or Optronics to show Compliancy Data for
the always Mandated “3 Years … Facing South … at 45° … into the
Sun … Florida/Arizona Testing”*, which helps to guarantee “Outdoor
Longevity”, which will guarantee all concerned against
premature “Ultra Violet Color Fading” and/or, premature Heat and Cold,
degradation of the Lenses and Seals plus helps to guard against moisture
and/or rust failures of the Electrical and Physical Supporting Components.
*NHTSA still “mandates” that the 3-Year Color Fading, Weather and UV Tests
must be performed “only in the States of Florida or Arizona”
and NHTSA still mandates that “Accelerated 3 Year “UV” Tests” are not
acceptable to them. Detroit Auto Engineers (SAE) or NHTSA?
Engineers dreamt up this ambiguous and impractical test requirement 38+
years ago … which represents what I call, “The Florida and Arizona,
Working Vacation, requirement” … whereas … we all must ask …
what’s wrong with “Real Life” color fading and weather longevity testing
performed in Michigan, or in Texas, or in New York … if simply
interpolated for “Less Sun” circumstances?
The Automotive Manufacturer’s Equipment Compliance Agency Inc.
(AMECA) keeps an updated List of all plastic Lens Materials that
they can verify have been officially tested to the Federally
mandated, 3 Year, (SAE J586) Outdoor Testing requirements. AMECA’s
website is
www.ameca.org. NHTSA “recognizes” AMECA’s listings so
that those using or selling products made from “questionable
plastics” … that are not on AMECA’s list … must be
able to independently “prove compliance” to these Outdoor,
Fading and Heat/Cold Tests for all the Vehicle Lighting and
Reflectors they’re installing, changing, or selling
that end up in public use.
This
3 Year Test … plus several other quality and durability assurance tests,
mandated by FMVSS #108 represent the many Federal and “common sense”
Physical and Photometric Tests that practically all? overseas Vehicle
Lighting Importers and Manufacturers are currently totally ignoring.
And to make matters worse … NHTSA isn’t challenging any of the
most obvious violations of Federal
Law and Common Sense.
Note too! The recent 50,000 Recalled Pairs of 7-Function “LED”
Lights from “Optronics” were also not tested
by NHTSA for real-life “Thermal and Physical Shock” conditions nor
were they tested for “Submersion or Dusty Road Applications”, nor
were they tested for disabling “Thermal Expansion/Contraction/Seal
Failures” as required by Federal Safety Acts and SAE Quality Assurance
Goals. Without question, all of these common sense, necessary
Tests should be absolutely required … whenever thermal, ultraviolet
and/or moisture vulnerability is obvious … so everyone involved is
adequately protected from safety effecting, prematurely failing …
and non-repairable Vehicle Lighting … of any kind.
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