July 28, 2006

 

The Chief Counsel

National Highway Traffic Safety Administration, NCC-01

400 7th Street, SW

Washington, D.C.  20590

 

“REQUEST for LEGAL INTERPRETATIONS” on FMVSS #108 Subjects

 

Receiver Receipt Requested

 

INTERNAL LENS and REFLECTOR DEGRADATION from SUBMERSION APPLICATIONS

 

For the past 20+ years, most American Boat Trailer Manufacturers have used either “Hermetic Sealing”
or the “Air Trapping Principle” to keep oily, silty, (grimy) and salty? launch water from wetting and coating all the internal un-cleanable optical surfaces when their lights were submerged at a launch ramp.  Before these two methods were used … Boat Trailers Lights were commonly allowed to fill with water and then drain after the trailer was pulled from the launch area water – thus, “Fill and Drain”.

 

Both the Sealing and Air Trapping methods protect the Light Sources* from Thermal Shock and most
Corrosion Degradation, while also protecting most of the complex inside optical, refractive, reflective surfaces … from accumulating layer after layer of grime, salt, etc. each time the lamp is submerged.        

*Bulbs or LEDs

 

Today, “Fill and Drain” Multi-Function Tail Light Assembly designs are again being used on Boat Trailers while being unchallenged by NHTSA in spite of seeable and measurable dimming of the lenses and reflectors.

 

Further, physics tells us wetting the Reflex Pins of a Reflector changes the “index of refraction” of the supporting media (from air to water) and to a great degree, can negate Reflex Pins effectiveness until dried.  Also, oil, silt (“grime”) and salt residues that are deposited on the inside optical surfaces of a typical “Fill and Drain” 6/7 Function Boat Trailer Lamp when immersed in average U.S.A. “launch ramp water” … produces seeable degradation of the reflector reflex pins and also seeable depletion of the output from the Brake/Turn/Tail, Clearance and Side Marker Lamps.

 

“Launch Ramp” water is normally very stirred up … therefore very silty … and somewhat oily from the many boat engines and outdrives being submerged and run in such a small area.  To promote submersible Trailer Lights to actually fill up with silty, oily and salty? Water, is really a violation of the main objective of the 1966 Vehicle Safety Act, not to mention a violation of common sense and SAE J1398:

 

SAEJ1398 MAY1985

6.2.3 Performance of lamps may deteriorate significantly as a result of dirt, grime, and/or snow accumulation on the optical surfaces.  Installation of lamps on vehicles should be considered to minimize the effect of these facts.

 

6.2.4 Where it is expected that lamps must perform in severe environments, for example, be totally immersed in water periodically, the user should specify lamps designed for such use.

 

1113 Greenville Road    Livermore, California  94550      Tel:  (925) 443-3140  Fax:  (925) 443-0384

 

INTERNAL LENS and REFLECTOR DEGRADATION from SUBMERSION APPLICATIONS

 

After just a few launchings in today’s typical launch ramp water, we can measure degradation of the photometrics in all the 6 or 7 functions of any currently used “Fill and Drain” Submersible Trailer Lamp Assembly, which worsens proportionally to the number of launches and retrievals.

 

Further, realize that “clinging water droplets” on the inside optical surfaces, can also further deplete photometric outputs during the boat trailer’s “return trip home”, in the evening or night time, after a day of Boating or Fishing.

 

“Fill and Drain” lights are easily distinguishable at local launch ramps because of the inherent “dribbling” of water coming from them as they’re extracted from lake, river or sea water.

 

Of course, actually seeing an emerging filled with water lamp and the subsequent dribbling of dirty launch water … the average boat trailer owner (and/or observer) has to wonder how the trailer manufacturer that provided these lights can actually call them “Submersible” or “Waterproof”* … because not only can everyone see water streaming out the bottom, but also after draining.  The insides remain seeably wet and as launchings and retrievals add up, the inside lenses and reflector faceting become noticeably dimmed and grimy looking.

*And they may also begin to ask “Who in government is allowing this to go on!”

 

For the past 20+ years, common sense pretty much prevailed and practically all Boat Trailer lights that were to be submerged during launchings and retrievals used either “Hermetically Sealed” (throwaway) 6” Oval (3 function) type lamps or they used “Air Trapping” (serviceable) 6/7/8 Function type lamp assemblies, which, for the most part, adequately kept out most oily, grime and salt water residues so that left over water plus accumulated grime* degradation … was minimized.   

*Which significantly depletes the output of all the Rear Side Pointing and ?Rear Pointing Reflectors as well as the ?Brake, ?Turn, ?Tail and ?Rear Side Marker Lamp functions.

 

For a long time, “Fill and Drain” designs were not used by most Boat Trailer Manufacturers for obvious reasons; however, since the advent of LEDs, we have seen a comeback of “Fill and Drain” designs     mainly because the threat of “Thermal Shocking” of the bulbs has been eliminated in LED Designs; and, of course, unsealed lights are cheaper to manufacture plus the fact that virtually no Trailer Owner knows about … therefore, don’t object to … the degradation of their Lenses and Reflectors.

 

Unfortunately, NHTSA has shown no objection to these obvious violations of common sense and the 1966 Vehicle Safety Act’s main objective … so “Fill and Drain” designs are again propagating.

 

In reality, the small savings recognized in “Fill and Drain” designs actually save the lamp manufacturer very little when compared to the tremendous loss of effectiveness of 5 or 6 very important safety lighting functions typically taking place in a Fill and Drain Boat Trailer Light, which in the long run, significantly depletes everyone’s overall road safety for only a few pennies saved at the manufacturing level.

 

Lately, even some “Air Trapping” designs are being cheapened so that they allow grimy launch ramp water to enter far into “Compression Chamber” before the trapped “air bubble” takes affect, therefore allowing grime build up on any rear, bottom located reflex pins or lens areas.


 

INTERNAL LENS and REFLECTOR DEGRADATION from SUBMERSION APPLICATIONS

 

Over the years, at extra expenses to us  … we have “protected” our bottom located Rear Pointing Reflectors in our 6/7/8 Function Air Trapping designs by providing a secondary transparent protective window*, which kept launch ramp water from depositing grime on the Reflex Pins.  When it is impossible to protect a low positioned Reflector, we supply an Augment Sealed Reflector to “back up” the Rear Facing Reflector that we know will get depleted in a submersible application.    *Check it out!

 

Years ago, I was in the Emergency Room at our local hospital (for a chemical burn) when a whole family was brought in on stretchers.  They had pulled off the Interstate because one of the kids had to take a pee and they ran smack into an abandoned boat trailer that had a flat tire and this Trailer had either no or ineffective rear reflectors.  The father claimed he didn’t see the trailer until it was too late.  Think about it!  These reflectors are indeed important!

 

Today, most Air Trapping Boat Trailer light assembly designs don’t even try to protect the effectiveness of rear facing reflectors.  

 

Therefore, considering the seeable losses in photometric output and therefore, loss in road safety by allowing “so called” Submersible Lamps to fill with launch ramp water … then drain and dry! …

we must ask:

 

  1. Has anyone at NHTSA analyzed “What’s the estimated projected cost to public road safety measured in increased crash damage plus projected injuries and deaths … compared to what Lamp Manufacturers are saving by using unsealed “Fill and Drain” design?”

 

  1. Why doesn’t NHTSA derive a simple “Standardized Submersion Test” for FMVSS #108 that would use an “average mixture” of water and impurities found at “average” boat launching areas? 

 

This Test should require several ≈2’ deep submersions and drying periods in the sun while performing photometric testing to measure degradation with internally wet as well as internally dry optical surfaces before and after several submersions.

 

  1. Isn’t it obvious to anyone at NHTSA that has been “trained in the state of the art” of road safety … to see the need for a Submersion Test like outlined above while admitting this kind of safety test is not a hard or expensive test to standardize and enforce, especially when considering what’s at stake in overall road safety to the American public.         

*selected by consensus

 

I believe a rapid answer to these questions is required by Federal Law.

 

Yours truly,

 

Dennis G. Moore

President

dba Dry Launch Light Company