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July 14, 2006
The Chief Counsel National Highway Traffic Safety Administration, NCC-01 400 7th Street, SW Washington, D.C. 20590
Docket Section: Receiver Receipt Requested
“REQUEST for LEGAL INTERPRETATIONS” on FMVSS #108 Subjects
HEAT DEGRADATION & OUTRIGHT FAILURES of “LEDs” in AFTERMARKET LAMPS
With all the obvious failures of “LED” High Mounted Stop Lights (CHMSLs) that all Americans can see daily on our roadways, we must ask: “Who at NHTSA is guarding us from these kinds of safety degradations”? Also, we must ask: “If NHTSA does not comprehend or investigate such obvious problems, how can we rely on them for questioning and exposing not so obvious Vehicle Lighting Safety Problems?”
Without doubt, any seeable lens fading, warping or premature LED dimming or outright failures represent serious safety violations of the main objective of FMVSS #108*, as well as the Vehicle Safety Act. These violations are unnecessarily compromising our road safety and can not be allowed to continue any longer. *Federal Motor Vehicle Safety Standard #108.
Anyone traveling our roads can see the high percentage of warping, fading, dimming, and non-working “LED” Center Mounted Stop Lamps … especially prevalent on “Caps”*. *Also called Toppers, Camper Shells, etc.
Of course, the lens fading and lens warping failures are more prevalent in the Sunshine States; however, outright LED failures can now be seen in great numbers “everywhere”. Whether these dimming and failure safety degradations are caused from LED heat or moisture failings or from heat/moisture failings of the LED Circuitry … or from physical failures in other support components … are still to be determined. But nevertheless, we can conclude our road safety is continually being depleted from poorly designed LED Lighting Products.
Considering the obvious lack of attention by NHTSA* on these seeable and widespread safety issues – we must also ask: “Are the failures of mandated Center Mounted Stop Lights (CHMSLs) an indication of what’s to come for all the new “LED” Lamps now being sold to the Public and used by Vehicle Manufacturers”? *and the Society of Automotive Engineers (SAE)
Further, we ask: “Is NHTSA actually allowing the public (us) to be supplied unproven, untested, and expensive* LED Lamps that can not be economically or quickly (anytime, anywhere) repaired when they dim or fail in Real Life use?” *compared to Incandescents
After personally seeing hundreds of failed, faded and flooded* LED Brake Lights in Northern California, it’s clear to anyone in this area that Aftermarket LED Stop and Turn Lamp failures are producing safety problems that are, indeed, increasing “Up Close”, “Rear Ender” and “Lane Changing” type Crashes**. *Water infiltration is also a contributing factor to LED failures **Not to mention possible “catastrophic, multi vehicle wrecks”
Yes! … State and local laws require the owner of any Vehicle to assume responsibility for immediately fixing any of their mandated fading or failed lighting; however … in the case of the millions? of failed “LED” Center Mounted Stop Lights … this “fixing” is not happening* because LED Lighting is not “Bulb Fixable” and
1113 Greenville Road Livermore, California 94550 Tel: (925) 443-3140 Fax: (925) 443-0384
HEAT DEGRADATION & OUTRIGHT FAILURES in “LED” AFTERMARKET LAMPS
it costs at least $50 to $150 to have the average failed LED CHMSL exchanged … that is, if the owner can find the specific replacement as well as someone to install and rewire the new one. Also, “fixing” assumes the driver can afford? and is willing to pay? the $50 to $150 for the replacement. And of course, the first step in fixing these kinds of safety problems … require the driver to be “told” that his/her Lighting has indeed, dimmed or quit working … which practically never occurs. In fact, the average Police Officer now avoids pulling over anyone with non-working lights, as this act is often perceived as a harassment tactic that most prefer not to be accused of. *and many other LED and Sealed Aftermarket Lamps as well!
All these realities; that is … high cost … no available replacement … and no one qualified to do the exchange even when the failure is ultimately realized … apply to CHMSLs using LEDs, as well as all 6/7 Function Aftermarket LED and Sealed* Incandescent Lamps. *Not Bulb changeable
So who’s responsible for this kind of safety degradation and resultant crashes* – the Driver? … the Vehicle Manufacturer? … or NHTSA? Ask the Public and ask the Trial Lawyers … “Who’s responsible?” … and see what answers you get! *not considered “Accidents” anymore by NHTSA because … “crashes” can be avoided … accidents can’t!
Initially, it appeared the (attached) NHTSA Office Investigation that was sent out in 2004 was an attempt? to establish how many untested, non effective and non compliant* “LED” Stop, Turn and other? Lights were being sold to the public … but apparently, this investigation resulted in the gathering of no objective information. *to Federal Motor Vehicle Safety Standard #108 mandates
When our company was sent this questionnaire, we thought that NHTSA was about to find out how many of the LED Aftermarket Lamps already sold and being offered for sale in the U.S.A. for use as mandated Vehicle Lighting were indeed, manufactured to all FMVSS #108 Standards … if any!. We also expected NHTSA to find out which LED Lamps were actually being longevity-tested to Real Life Road and Weather Conditions … if any!
Apparently, the results of these initial and subsequent “Office Inquiries” only questioned one, two or a few? Importers of their Aftermarket LED product’s Photometric Outputs* while physical capabilities and any guaranteed longevity data was not asked for. *which didn’t include the loss of output (dimming) due to heat degradation of the LEDs
Therefore, aside from the three Recalls of “Optronics” Multi-Function LED Light Assemblies, due to gross photometric failures** … NHTSA’s inquiries learned nothing else for all the money, time and effort spent. **see at http://dms.dot.gov/ - Docket No. 2005 23419 Notice 6 – Dec 12, 2005
Further, as far as we can determine … absolutely no questions were asked in the inquiries as to what steps had been taken by the Lamp Manufacturer or Importer to assure the public of safe, reliable, lasting, and repairable (anytime, anywhere) vehicle lighting. In other words … lighting that could always be counted on to do its job when needed.
Therefore, since NHTSA continues to shirk their assigned responsibilities … we all must wonder if the millions of LED Lamps flooding our roadways … “actually comply” to any of the physical, photometric and mental requirements of FMVSS #108 and common sense so as to assure us of Long-Lived, Safe Lighting; particularly in cases of “non-serviceable”, ≈“non-findable”, and “expensive light source” lamps.
For 12 long years* NHTSA has been, very obviously, procrastinating on regulating “LED” heat and moisture sensitivity issues and after 12 years of NHTSA knowing about these safety problems … they continue to look the other way on obvious, “street seeable”, failures of LED driven Stop, Turn and Tail Lights that are, without any doubt, causing safety problems, which must not be ignored any longer. *See the two NPRMs and their two cancellations listed in Question 7
HEAT DEGRADATION & OUTRIGHT FAILURES in “LED” AFTERMARKET LAMPS
Seeable examples of “LED” Heat Vulnerability:
“LED” TRAFFIC LIGHT FAILURES: Have you ever pulled up to a “LED” Traffic Light on a hot sunny day and noticed the Red Light has significantly dimmed? I have! and so have my friends. This dimming was so profound, the red light looses most of its human influence.
These dimming traffic lights are now being returned to the manufacturer because they were guaranteed to have long lives, as well as provide, more or less, “straight out” photometrics, which are both very desirable features to have for Traffic Lights. However, these lights were not guaranteed against dimming on a hot day because no one thought about asking for a guarantee against heat!? Here’s the result!
Can you imagine what will be the “fix it” cost to the respective Traffic Light Manufacturers and Cities or Counties that bought these unsafe, unreliable LED Traffic Lights?
The Society of Automotive Engineers’ (SAE) current LED “HEAT UP” TEST: SAE’s Qualifying Heat Test for LEDs applied to their auto lamp assemblies, are performed at only “room temperature”* at unknown voltage for 30 minutes or less. This kind of heat test is supposed to be showing up real life heat degradation in the LEDs and determining what the loss of output is for elevated temperatures … as well as the total LED failure point. *23°C = 72°F
This SAE Test is ignoring the facts that ambient outdoor temperatures can reach 100+°F and radiant energy from the Sun and Hot Road Pavement can significantly add to internal LED temperatures resulting in significant dimming and, perhaps, outright failure.
We have read that LEDs in general lose 10% of their output for each 10°C increase in temperature – which is quite drastic and makes it easy to imagine losing ½ the photometric output when even moderately heated from constant use and Sun/Pavement Radiation. I’ve read that a closed car in the Sun can get over 200°F inside in a short period of time … LED Manufacturers warn users not to exceed 185°F.
As a result … we find that on a hot, sunny day when LED Stop/Turn Lights are used for long periods of time … as in a traffic jam … and exposed to Direct Sun and Hot Pavement Radiation … temperatures in a compact* 3 or 7-function Aftermarket “LED” Lamp … can easily climb to 150°F and above, which is enough to degrade half the Photometric output and perhaps even destroy the LEDs entirely? *Compared to the massive size of the typical Auto Tail Light Assembly
So, we must ask … “How realistic is SAE’s “Room Temperature” heat testing compared to real life use?” … particularly under conditions where bright and comprehensible Stop and Turn Signals are needed the most … that is … in “up close, slow moving, traffic situations” … on hot, sunny days!
MORE “SEEABLE” LED FAILURES: Last year at the annual “SEMA” (Specialty Equipment Manufacturers Association) Show (our 19th year) … a Taiwan “LED” manufacturer directly across the isle from our booth in the Restyling Section, was displaying many large and small “Lit” LED lights.
After a while, we noticed their larger LED Lights (that were being claimed to be FMVSS #108 compliant for use as mandated Stop and Turn Signals) left on continuously (in the air conditioned Hilton Convention Center), had soon become very dim. On the second day of the Show, the Taiwan exhibitors started “blinking” these Lamps. On the third day … they turned them off completely.
Because of this
“10% drop for each 10°C increase, no one we know of that displays LEDs at
Trade Shows … leave them on continually because of this embarrassing problem.
Of course, this isn’t a problem with Incandescent Lamps. HEAT DEGRADATION & OUTRIGHT FAILURES in “LED” AFTERMARKET LAMPS
In summary, NHTSA has apparently taken the “anything goes” position as to where and how LEDs can be used in mandated vehicle lamp designs and still makes no practical demands as to how mandated LED Vehicle Lamps must be “real life” Heat, Moisture and Longevity Tested. Further, NHTSA has also apparently given up about caring how much the photometric outputs will drop as LEDs heat up under real life circumstances, which, of course, represents an unacceptable attitude that must be corrected.
Since “LED Dimming and Failures” are so obvious and widespread – we must ask:
*which includes both … declining output from Heated LEDs as well as warping of the LED Circuit Card … which also greatly depletes photometric output!
“Why, after 12 years of knowing about obvious LED safety problems … hasn’t real life heat and moisture Testing been mandated by NHTSA so that sealed, expensive and un-repairable Aftermarket Lamps assure the public of a productive Life Span of at least … 10 years?, while at the same time, allowing qualifying “Accelerated Testing” using standards that GM, Ford, Chrysler, etc. minimally require of all their current Front, Side and Rear lighting? a. April 8, 1994 – Docket No. 94-23; Notice 1 – RIN 2127-AE97 (NPRM) b. June 19, 1995 – Docket No. 95-47; Notice 1 – RIN 2127-AF65 (Cancellation) c. June 24, 1998 – Docket No. 96-3967; Notice 1 – RIN 2127-AG88 (NPRM) d September 15, 2004 – Docket No. 98-3967; Notice 2 – RIN 2127-AG88 (Cancellation)
I believe a rapid answer to these questions is required by Federal Law.
Yours truly,
Dennis G. Moore, President
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