June 5, 2006
Attached is a catalog sheet from Truck Lite’s
± recent catalog showing what we believe, to be the only “ECE”
(European Union) Approved Stop/Turn (Tail) Signal Lamp made by an
American Company! This model costs ≈ $120 Retail. You’ll note it
uses 50 LEDs plus incorporates “Cone Reflectors” (we
call them), which if correctly designed, increases the EPLLA by
qualifying the walls of the Cones for EPLLA additions. Several American
and Japanese Auto Manufacturers are now using this same EPLLA increase
approach to achieve the USA and Canadian mandated FMVSS #108 required
7-3/4in˛ EPLLA* necessary for single Brake/Turn Signals used on all
under 80” width SUVs, Pick Ups and Autos. Further, note that they are using
LEDs in conjunction with Incandescents.
*Effective Projected Luminous Lens Area
European Engineers and Designers are very
conscious of what EPLLA “is” and its safety importance and they know
what it takes in their designs to accumulate proper amounts of Effective
Projected Luminous Lens Area so human recognition and responses are
Assuming the entire large end of 50 Truck
Light’s “Cone Reflectors” can be considered as entirely Effective
Projected Luminous Area, the “EPLLA” for this 50 “LED” arrangement is:
“Effective Projected Luminous Lens Area”
for each = Pi (3.14) x (.22)˛* = .152in˛ each.
* “Scaled Radius “estimated” from the
Truck Lite photo attached
For these 50 LEDs and “Cone Reflectors” Areas
altogether … they produce an estimated 50 X .152 = 7.60in˛ of
Total “EPLLA”, which is very close to the U.S.A. required 7-3/4in˛
“EPLLA” that’s mandated for all Under 80” Brake and Turn Signals.
If this Lamp were required to have
11-5/8in˛ of “EPLLA” … which is what’s mandated by FMVSS #108 for
Over 80” width
uses … it would need:
11-5/8 = QTY LEDs?
≈ 77 LEDs used with “Cone Reflectors” similar to shown in the
77 of these Cones would not fit into a ≈standardized 4”
Round* or 6” Oval* used by most Big Rigs today … necessitating
significantly larger Area Lamps than the 4” Round and 6” Oval
represents if 11-5/8in˛ of EPLLA is needed.
are ≈exactly 11-5/8in˛ in lens area only
77 “Unlensed” LEDs are a long, long way
from one to ten, which “Peterson”,
“Optronics”, “Innovation” and other LED Lamp Manufacturers’ of LED
Brake/Turn lamps have been directly or indirectly supplying for public use
while inferring, or actually claiming, their designs are
totally compliant to all the mandates of FMVSS #108. According
to our observations, most 3 and 7 Function LED Lights being used today are
very far from being compliant to the many mandated requirements of
FMVSS #108 … Check it out!
The LED “Cone Reflectors” provided by
the Cadillac as a sort of “Interim Lens” in their 2003/4? Designs, is the
same in concept to the “ECE” Approved Truck Lite discussed above, because
this Cadillac Lamp uses the same approach as Truck Lite to assure that the
inherently limited Output of each LED used is reflected (and/or
refracted in Fresnel Designs) so that most of this limited Conal Output is
corralled and projected rearwards within the required 20° Left to 20°
Right; 10° Up to 10° (5°) Down mandated Test Pattern. This is primarily
accomplished by “lighting up” the walls of the Cones by projecting
this light within this mandated Test Pattern.
Using this approach, nearly all the
“Effective Light Omitting Surface” seen at the end of each “Cone Reflector”,
officially qualifies as “Effective Projected Luminous Lens Area”.
Of course, this area depends on the spread of the “LED” due to added
interim lenses or other arrangements. Within limits, this approach only
allows the Areas at the Cone’s “Ends” to qualify for EPLLA while any
subsequent “Transparent Outer Lenses” … whether positioned near or
far from the Cone’s End …“does not” add any more EPLLA to the Total
because it’s “Transparent”- and therefore doesn’t qualify for EPLLA
addition … a fact conveniently ignored by most LED designers!
If Cadillac used, say, 12 large high powered
LEDs properly matched along with 12 fairly long “Cone Reflectors” that were
say, 3/4” in diameter at the large ends … the EPLLA would be -
“EPLLA” = 12 x
x (3/8)˛ = 5.3in˛ - which is ≈ 1.5in˛ short of the mandated 7-3/4in˛ for
under 80” Wide Vehicles
If Cadillac used say, Ten (10) LEDs, 1”
Diameter “Cone Reflectors” –
“EPLLA” would then be 10 x
x (1/2)˛ = 7.79in˛ … which would give the Designer just enough
“EPLLA” to meet the mandated requirement of 7-3/4in˛ for under 80” width
(auto) type vehicles – but not for over 80” vehicles.
For Over 80” Trailers, RVs and Big Rigs
The Designer would need 11-5/8in˛ /
7-3/4in˛ or 150% as many … or ≈15, one inch Diameter Cones
15 expensive?, high powered LEDs.
Bottom Line – Everyone involved in an
“EPLLA Liability Situation” should be asking any and all “LED” Lamp
Suppliers trying to sell lighting that will be used by the public … “What
proof can you produce to show that your “Effective Projected Luminous Lens
Area” meets the mandated 11-5/8in˛ required by State and Federal FMVSS #108
Law using the FMVSS #108 definition of “Effective Projected Luminous
Lens Area” from FMVSS #108.
§ 571.108 Standard No. 108; Lamps,
devices, and associated
Effective light-emitting surface
that portion of a lamp that directs
light to the photometric test pattern,
and does not include transparent
lenses, mounting hole bosses, reflex
area, beads or rims that may
glow or produce small areas of increased
intensity as a result of uncontrolled
light from an area of 1/2 degree
radius around a test point.
Effective projected luminous lens area
means the area of the orthogonal
of the effective light-emitting
surface of a lamp on a plane
to a defined direction relative
to the axis of reference. Unless
specified, the direction is coincident
with the axis of reference.
S6.3 The term ‘‘functional lighted
lens area’’ in any SAE Standard or
Practice incorporated by
reference or by subreference in this
standard, has the same meaning as the
term ‘‘effective projected luminous lens
SEE WHAT THEY SAY and CHECK THEIR
EXPLANATION WITH NHTSA EMPLOYERS!