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By pretentiously molding in “Phony” and/or
“Non-Qualifying” Refractive Fresnel Rings, or other obvious Inactive and
Ineffective Faceting on the inside or outside of a Lamp’s Lens
Surface does not mean that the entire lens area qualifies for “EPLLA”
compliance.
To meet “EPLLA” compliancy using LEDs … all qualifying Effective,
Light Emitting Faceting will likely receive “LED” “Light Rays”* at no
more than a ≈10° angle and then the Rays must then be properly
redirected (Refracted/Reflected) so as to project all to following
traffic “within” the limits of the Test Pattern angles … meaning
that “Rays” directed beyond 20° Left/Right and 10° Up/Down don’t
qualify as EPLLA usable area.
*Imagine “Rays” of Light
Lamp
Manufacturers that leave out needed LEDs*, or produce
fake holes* where “LEDs” should be … but aren’t …
represents serious illegal practices* and the resultant
consequential Public Safety Hazards must be recognized and dealt with by
NHTSA.
*Obvious
and seeable, Illegal, practices currently used by many short-lived, “fly by
night” “LED” Lamp Manufacturers are
blatantly violating “Mandated Federal Law”
while being essentially unchallenged by NHTSA’s Compliance Department
– Why is this?
“EPLLA, Non-Compliances”
are currently being marketed by most (if not all) Manufacturers
of “LED”, 7-Function and 3-Function Lamps. Combine these obvious
Non-Compliances with other ongoing LED problems, such as
Heat Degradation, Moisture Sensitivity and Color Fading cause Longevity
and Serviceability problems and you’ll begin to see the many
serious quality, safety and liability problems that
many Vehicle Manufacturers and Lighting Distributors are unknowingly
becoming involved in.
If
you have the time, you should read about the latest? Optronics
Federal Recall for their 4 inch round LED Lights sold in 2002. Their
extreme Non-Compliances can be partially blamed on the inherent confusion
and ambiguous and erroneous wordings of current FMVSS #108 Regulations
as to what exactly is a double or triple sectioned lamp using common sense
logic.
I
find it very troubling that NHTSA seems to be continually following
an “uninformed” and “who cares” attitude towards the many
FMVSS #108 safety degrading non-compliances that are now absolutely
obvious all over the U.S. thereby encouraging U.S. Vehicle Lighting
Manufacturers as well as “OEM” users into thinking they can (with
Legal and Liability immunity) Import and supply the public illegal,
cheapened and unreliable Vehicle Lighting Products with no consequences.
This “head in the sand” attitude is simply fanning safety compromises
and promoting “Liability Suicide” for all concerned … except
NHTSA … who can’t be sued for their part in this mess; however, check
it out with your Lawyer - everyone
can be sued for any and all lighting non compliancy “Crash Claims” that they
can become involved in.
Further, it’s absolutely nonsensical and totally
irresponsible that NHTSA doesn’t even try to effectively inform
Lighting and Vehicle Manufacturers about the millions of Non-compliances
already “everyday obvious” to them.
NHTSA could easily warn the few Vehicle OEM Trade Organizations
of what non compliances their members should be “looking out for”.
They should also be routinely providing everyone in all related
industries with thought out, easily understood “warning and policy
writings” plus thought out “Legal Interpretations” while also
providing accurate, effective, to the point, “visual aids” to
show everyone concerned “what is FMVSS #108 compliant and what will
last” versus what represents proven and/or obvious quality and
longevity problems. This kind of information should immediately be
distributed by NHTSA to help all concerned recognize and address all
vehicle lighting problems before OEMs and Distributors become
unknowingly involved in Liability problems they would have just as soon
avoided.
NHTSA’s current practice
of simply “letting the unaware and uninformed … hang themselves”
is unacceptable. This represents an absurd and inept attitude
that I intend on complaining about … in writing … as well as in person
… to several influential Senators and Congressional personnel, while also
“reporting” these incompetence’s to any interested Congressional
Committees or “Watchdog Groups”… that shows a desire to eliminate
waste, increase road safety and improve efficiency in government.
A
few years ago, I gave a “Congressional Record” talk before a DOT
Congressional Committee (in Washington, D.C.) on the subject of how to save
money while more effectively administering FMVSS #108. I was surprised to
find out that this Committee of both Republicans and Democrats were not
particularly interested in saving money, but I did get some “temporary”
satisfaction because my paper was printed in the “Congressional Record” and
some improvements were made.
We
have in our archive files; several official “Legal Interpretations”
issued by NHTSA authorities over the past ≈30 years where for instance …
NHTSA reiterates the importance of adequate “Effective Projected
Luminous Lens Area” coupled with emphasizing the importance of adequate and
specifically aimed Photometric outputs.
Problem is! - this kind of information is not distributed to
Vehicle Trade Groups who really need to be aware of the associated
facts. Just a copy of the Question sent in* with NHTSA's reply
outlining a Real-Life example and sent out to but a few Vehicle
Manufacturers Trade Organizations (and also put on the web*) is all that’s
necessary.
*Questions
asked NHTSA are not put on the web – just NHTSA’s answers
FOR INSTANCE:
Here’s a noteworthy example that NHTSA could effectively use to demonstrate
the point that “MANY LEDs are NEEDED” to meet the “EPLLA”
requirements for 3rd Brake (CHMSL) and conventional
Brake/Turn Signal Lights …
The
popular General Motors “LED” … “Center High Mounted Stop Light”
(CHMSL) used since 1995 and installed on millions of GM® Van
and SUV Roof Tops, use a total of 40 (forty)
high quality “LEDs” arranged in a straight line array*
that provides just over 4.5 in² of, “official qualifying” “EPLLA” area,
which fulfills the 4.5 in² “Effective Projected Luminous Lens
Area” requirement of FMVSS #108 mandated by NHTSA for CHMSLs.
*each illuminating source is represented by … no more than a 3/8” Diameter
Set of Fresnel Rings providing Pi(3/16)²X40 ≈ 4.5in² of
“Effective Projected Luminous Lens Area” (EPLLA)
Comparably
– it would take 40 = ?_ or ≈ 70
(seventy) and 40 = ? or ≈ 100
(one hundred) of comparable size and
4.5 7.75
4.5 11.75
quality “LEDs” to meet FMVSS #108 Compliancy for the, 7-3/4 in² “EPLLA”
(70 LEDs) and the 11-5/8 in² “EPLLA” (100
LEDs) covering under 80” and Over 80” (respectfully) requirements
for a Brake or Turn Lamp to officially comply to FMVSS #108 for
mandated “EPLLA” requirements.
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