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C #102 B – “RECALLS” are neither Pleasant nor Inexpensive

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 Marineby 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 yearsthis 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.orgNHTSA “recognizes” AMECA’s listings so that those using or selling products made from questionable plastics” … that are not on AMECA’s listmust 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 ignoringAnd 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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