| Author | Message | ||
| Tim Brandt (Timb)
Registered Member Username: Timb Post Number: 242 Registered: 10-2003 Posted From: 66.165.176.60  Rating: N/A |
I have not tried these yet but found the idea pretty interesting. They are LED's that are designed to replace an existing OEM bulb so no need to change the housing. Thought some might find it useful or interesting. If I pick a couple up I will report back on their effectiveness http://superbrightleds.com/tail-brake-turn.html (Message edited by timb on December 23, 2008) | ||
| Sean Welsh (Sean)
Registered Member Username: Sean Post Number: 737 Registered: 1-2003 Posted From: 67.142.130.37 Rating: N/A |
Not street legal. FYI, FWIW, YMMV, etc. -Sean http://OurOdyssey.BlogSpot.com | ||
| John MC9 (John_mc9)
Registered Member Username: John_mc9 Post Number: 729 Registered: 7-2006 Posted From: 68.18.14.133  Rating: N/A |
Tim - You may have to change the flasher if it's the older type, since the LEDs don't provide enough load. That same company sells flashers.... A local truck shop sells the LED replacement bulbs. Although initially expensive, they last a lot longer since there's no filament to vibrate and break. I don't know of any "laws" regulating the technology of the bulb's ability to provide light... Halogen, LED, incandescent.. They all have been (and are), used extensively.. | ||
| Jack Conrad (Jackconrad)
Registered Member Username: Jackconrad Post Number: 912 Registered: 12-2000 Posted From: 71.54.29.215 Rating: N/A |
"Not street legal. FYI, FWIW, YMMV, etc" Just curious, why are the replacement bulbs not legal? Jack | ||
| Austin Scott Davis (Zimtok)
Registered Member Username: Zimtok Post Number: 302 Registered: 9-2006 Posted From: 216.37.73.226 Rating: N/A |
I've already purchased bulbs from this supplier and they have a great selection and are prompt on their deliveries. I use them in my truck and they look great but are not quite as bright as a standard bulb. The brightness may be what is not DOT approved. . | ||
| Tim Brandt (Timb)
Registered Member Username: Timb Post Number: 243 Registered: 10-2003 Posted From: 66.165.176.60 Rating: N/A |
My thought was to put them in my clearance lights | ||
| Sean Welsh (Sean)
Registered Member Username: Sean Post Number: 739 Registered: 1-2003 Posted From: 67.142.130.24 Rating: N/A |
John, Jack, et. al. First off, Merry Christmas! The reason why the LED replacements are not street legal is somewhat complex. There are a couple of really good web pages that go into full detail, and, if you really need it, I can dig them up. The basics, though, are as follows: When a manufacturer of a light fixture, such as a stop lamp, tail lamp, turn signal, etc., submits the lamp for testing to DOT and SAE standards for luminosity, visibility, etc. the lamp is equipped with a certain type of bulb. If you look at most lamps, a reflector is part of the design, which contributes to not only the intensity of the emitted light, but also the diffusion or how the light is dispersed in various directions. The lens also contributes to this. The correct functioning of the assembly thus depends on being equipped with the type of bulb for which it is designed, right down to where the filament is placed. Any lamp which is DOT approved maintains that approval only so long as it is equipped with the type of bulb for which it was designed. These aftermarket "plug-in" replacement LED lamps do not send light in all the same directions as an incandescent bulb, and it's impossible to control the directionality, diffusion, and luminosity of these bulbs with the same reflectors and lenses used for incandescent bulbs. Using one in an otherwise SAE/DOT fixture invalidates the approval of the fixture. Many who sell these bulbs state on the package "Off-road Use Only" or some such, to cover their legal butts. The web site quoted above uses somewhat less clear weasel-language:
I think the phrase "for aftermarket use" is particularly annoying -- what the heck is that supposed to mean? But the intent of this statement is clear: to absolve the company of any liability attaching to use of their products on the street. I have a couple of these bulbs, by the way -- the "best" replacements that SuperBright offers. I use them for auxilliary (translation: not legally required) marker and turn signals on my scooter. I can personally attest that they are not as bright, nor can they be clearly seen from as many angles, as incandescent bulbs. Now, I think it's unlikely you will get pulled over for using these. But consider this: if you get into an accident, a sharp attorney for the other side can use this against you: "My client could not see that the bus was turning (or stopping), because the turn signals (or brake lights) were not working. Upon examination, it was discovered that the lamps had been retrofitted with non-compliant bulbs, thus preventing my client from seeing the signal in time to avoid the accident. We seek (insert ridiculous multi-million dollar claim here) in damages from defendant John Q. Busnut, the owner and operator of the subject vehicle." By the way, the exact same set of arguments regarding reflectors, lenses, etc. apply to retrofitting headlamp assemblies with bulbs not made for them, which happens all the time with aftermarket HID retrofit kits. There is a ton of case law on those now -- they are illegal in all states, and several successful lawsuits have been prosecuted against people who installed the kits by drivers who got into accidents after allegedly being "blinded" by the illegal conversions. FWIW. -Sean http://OurOdyssey.BlogSpot.com | ||
| John MC9 (John_mc9)
Registered Member Username: John_mc9 Post Number: 732 Registered: 7-2006 Posted From: 68.18.14.151 Rating: N/A |
Oh gosh, on Christmas morn, too! Upon examination, it was discovered that the commercial bus had been retrofitted with non-commercially compliant recreational vehicle items, thus preventing my client from knowing that the driver did not have the experience and training of any driver normally assigned to drive a large bus; special training and knowledge of air systems and other safety issues, are not required for a driver of a recreational vehicle. We seek (insert understandable multi-million dollar claim here) in damages from defendant John Q. Busnut, the owner and operator of the subject vehicle. I seriously wouldn't worry about using LED replacement bulbs, provided the type used emits the same (or nearly the same) light as the incandescent type. With all the other modifications in various stages of completion (and aside from driver inexperience), there are more things to worry about if/when you are involved in an accident, than the types of bulbs used. An attorney wouldn't bother taking the case, if he had to weigh it all on "bulb type". In fact, I doubt any attorney would be bothered going further than the insurance payoff, if he wasn't dealing with a bus company. Happy Holidays, Sean ! (and everyone else, too!!) HEY.... I got a piece of coal again! I let the fat *&^%% park the sleigh on the roof, and that's the thanks I get... | ||
| H3-40 (Ace)
Registered Member Username: Ace Post Number: 916 Registered: 10-2004 Posted From: 75.203.235.73  Rating: N/A |
I used Bargman upgrade LED's which is basically the same as what the poster was wanting to use except that it has it's own light housing. The plug simply replaces the incandescent bulb. The warning information I received on mine was as follows: WARNING: All Bargman #84/85/86 Tail Lights and #86 Wrap-Around Marker/ Clearance lights meet FMVSS/CMVSS 108 requirements. WHEN UPGRADING EXISTING LIGHTS FROM INCANDESCENT TO LED, TO RETAIN FMVSS/ CMVSS 108 REQUIREMENTS, SPECIAL CARE MUST BE GIVEN TO REPLACE EXISTING LENS (OR TO ASSEMBLE MODULE) WITH A LED MODULE THAT WILL PERFORM THE EXACT SAME FUNCTION. NOTE: Amber modules and amber turn lights meet FMVSS/CMVSS 108 Ace | ||
| Sean Welsh (Sean)
Registered Member Username: Sean Post Number: 740 Registered: 1-2003 Posted From: 67.142.130.45 Rating: N/A |
Ace -- you did it the right way. To have lights that are photometrically compliant, you need to get the whole assembly. John -- what I am telling you is that none of these LED replacements comes anywhere close to the amount of light output that an incandescent with a proper reflector will put out. At best, it will be close to compliant in the immediate rear (or front, as the case may be) direction, but will fall far, far short in any other direction. I'm sure, some day, there will be drop-in LED replacements that can meet the DOT photometric requirements in a housing/reflector assembly made for incandescents. But they do not exist today. And I can say with 100% certainty, from personal experience, that the products sold by SuperBright are not compliant. The notion, BTW, that lawyers have better things to do than go after bus owners for improper lights, therefore it's OK to use sub-legal ones, is a slippery slope. Perhaps we can extend that argument to the brakes, or the steering -- where does it end? I support your right to "do things your way" (as many people here often write), right up until it affects me -- and when I'm sharing the road with ~20-ton vehicles, I want their safety equipment (steering, brakes, and yes, even lights) to be up to the standards my tax dollars paid to develop. As you've heard me say here many times, safety codes and standards, generally, have been paid for in blood. I don't think any of us here on the boards should be advocating that they can be ignored for the sake of saving a few bucks, or because following them is inconvenient. -Sean http://OurOdyssey.BlogSpot.com | ||
| Cullen Newsom (Cullennewsom)
Registered Member Username: Cullennewsom Post Number: 6 Registered: 2-2009 Posted From: 98.201.161.214 Rating: N/A |
Ok, I know I am late to the party here, but sometimes I can't keep my mouth shut. I'll start with the most egregious piece of FUD* first. > I'm sure, some day, there will be drop-in LED replacements that can meet the DOT photometric requirements in a housing/reflector assembly made for incandescents. But they do not exist today. That's a pretty bold and all-encompassing statement to make and I defy anyone to actually prove it. To say that a particular type doesn't meet spec. is one thing. But to broadly dismiss a particular technology is quite another. Shenanigans, I say. -Cullen * FUD http://en.wikipedia.org/wiki/Fear,_uncertainty_and_doubt http://catb.org/jargon/html/F/FUD.html | ||
| Sean Welsh (Sean)
Registered Member Username: Sean Post Number: 755 Registered: 1-2003 Posted From: 67.142.130.12 Rating: N/A |
Well, as you know, it is difficult to "prove" a negative. But I can't find a single item on the market which claims DOT compliance in incandescent reflectors. So I will turn this around: Show me even one off-the-shelf general-use (as opposed to custom-built for a specific make, model, or application) drop-in LED replacement that meets the standard. In the meantime, I stand behind my statement. -Sean http://OurOdyssey.BlogSpot.com | ||
| R.C.Bishop (Chuckllb)
Registered Member Username: Chuckllb Post Number: 519 Registered: 7-2006 Posted From: 75.209.73.211 Rating: N/A |
Not positive...but in a Flying J a few days ago, I had in my hands an LED Rear Stop Light that I thought said "DOT"...don't know if "approved", "recommended", "sanctioned","specs", "endorsed" or whatever...don't recall the word " compliance", but who knows....could be. ...next stop there, I'll make an effort to confirm what I think I saw...  Meantime....I'm considering adding 4 LED round lights to my rear ( ...uh, the coach's). Quality "looks" is the thing for me... As Fast Fred says...do it your way! FWIW | ||
| Sean Welsh (Sean)
Registered Member Username: Sean Post Number: 756 Registered: 1-2003 Posted From: 72.171.0.143 Rating: N/A |
Chuck, Just to be clear: Yes, there are many, many DOT-approved LED fixtures. Note that these are complete assemblies -- they include the entire fixture, LED modules, and lens. In some cases they are completely sealed. There are also DOT-approved retrofit kits for specific models of vehicle or incandescent fixture. These include LED modules, sometimes replacement reflectors, and often replacement lenses. In order to achieve the DOT approval and meet the photometric specifications, you must install the entire kit. What we've been talking about here are "1157-type" drop-in replacement "bulbs," widely sold on-line and at auto parts stores. Merely putting one of these LED "bulbs" in an incandescent fixture is not a DOT-approved method and will usually not meet the photometric requirements. This is why you will see, in fine print, on most packages of these "bulbs," wording like "Not DOT approved," "For off-road use only," "For show use only," etc. -Sean http://OurOdyssey.BlogSpot.com | ||
| R.C.Bishop (Chuckllb)
Registered Member Username: Chuckllb Post Number: 526 Registered: 7-2006 Posted From: 70.210.161.109 Rating: N/A |
" Show me even one off-the-shelf general-use (as opposed to custom-built for a specific make, model, or application) drop-in LED replacement that meets the standard. " Your words, Sean....just reportin' what I saw. And I appreciate your bringing me in the context of things...guess they got lost in the rhetoric. RCB | ||
| Cullen Newsom (Cullennewsom)
Registered Member Username: Cullennewsom Post Number: 16 Registered: 2-2009 Posted From: 129.7.52.253 Rating: N/A |
Yes, but you're the one that's making the claim.
Nor is it prohibited. The lack of wording on a retail package to indicate DOT conformance does not imply non-conformance. Note that many incandescent bulb's retail packaging is also missing this language. Will anyone propose that incandescents that come in a package without "DOT APPROVED!" written on it are off-spec, and therefore illegal? -Cullen | ||
| Sean Welsh (Sean)
Registered Member Username: Sean Post Number: 766 Registered: 1-2003 Posted From: 67.142.130.30 Rating: N/A |
Yes, it is. I refer you to Federal Motor Vehicle Safety Standard 108, also known as 49CFR571.108 (and it's Canadian counterpart, CMVSS 108) which says, in part, that required lamps must conform to certain SAE specifications. For Stop lamps, that would be SAE J586c, and for Turn Signals, SAE J588d. Both of those reference SAE J573d, "Lamp Bulbs and Sealed Units" which requires the filament of the bulb to be within 0.01" of the position specified by the manufacturer when the lamp was designed. Filament positions are specified in section 5.1.1.17 LED "drop-in" replacements do not meet the specified filament positioning, therefore they do not meet SAE J573d, thus making the installed fixture in violation of SAE J586c or J588d, thus violating 49CFR571.108 making it UNLAWFUL. I don't know how much clearer I can be on this, and you making blanket statements like "Nor is it prohibited" without, apparently, even a cursory attempt to research the law is irresponsible. We could debate until the cows come home about whether an aftermarket lamp could conceivably be inserted into a fixture and meet the photometric standards (and, if they could, then a manufacturer could, conceivably, certify the resulting combination of specific fixture and specific LED as compliant). But as the law is written today, it simply is not lawful to do so. Nor is it lawful to, for example, retrofit an HID lamp envelope into a headlight system designed for an incandescent lamp. That does not stop hundreds of companies from selling retrofit kits (most of which have "off road only" weasel language on the package) -- the presence in the marketplace of these items does not make it legal to use them on the highway. FMVSS 108 and the SAE standards are actually quite particular about what you can put on a highway-legal motor vehicle. -Sean http://OurOdyssey.BlogSpot.com | ||
| R.C.Bishop (Chuckllb)
Registered Member Username: Chuckllb Post Number: 544 Registered: 7-2006 Posted From: 75.211.63.169 Rating: N/A |
I wonder how much of this is pertains to Commercial....as opposed to NON Commercial vehicles. Over the years I have seen a lot of moot points on the difference....in various subjects on the boards. When one puts an RV tag on the vehicle...it is usually a different ballgame. FWIW RCB | ||
| Sean Welsh (Sean)
Registered Member Username: Sean Post Number: 767 Registered: 1-2003 Posted From: 67.142.130.16 Rating: N/A |
Chuck, The lighting standards apply equally to all vehicles, regardless of commercial vs. private. That said, most cops, even on the traffic detail, don't pay attention to the nitty gritty details of these sorts of things -- few would even know how many lights are required, for example, on the side of a 35' coach. By contrast, the guys on the commercial enforcement detail, including those at inspection (weigh) stations, tend to be well versed in this sort of stuff. So, in that sense, you are much more likely to get a citation for, say, an inoperative marker light as a commercial vehicle than as a private one. -Sean http://OurOdyssey.BlogSpot.com | ||
| Kyle Brandt (Kyle4501)
Registered Member Username: Kyle4501 Post Number: 460 Registered: 9-2004 Posted From: 65.23.106.193 Rating: N/A |
I was behind someone with those LED's that replaced an existing OEM bulb in a ford pickup. All I can say is you could barely see them at dusk & I was right behind him (they seem to be directionally focused too since the right side was noticeably darker than the left until I changed lanes.) I doubt you'd be able to see them at all on a sunny day. | ||
| Cullen Newsom (Cullennewsom)
Registered Member Username: Cullennewsom Post Number: 30 Registered: 2-2009 Posted From: 98.201.161.214 Rating: N/A |
Good luck finding a lamp assembly (or anything constructed with pot-metal and plastic) that actually complies with that absurd requirement. If you think you have one, remove the bulb, and put it back; then see if it still complies. 0.010" is less than the thickness of a fingernail. In every lamp assembly I've seen, you could wiggle the bulb by much more than that. Especially true with Bayonet-type sockets. They don't mention the filament's position relative to the reflector, which is what matters in such an assembly. But, they can't since a reflector isn't a requirement. Has NHTSA ever enforced this positional accuracy? I think the answer to that question is directly proportional to how much NHTSA cares. In the end, what matters is light output, as measured according to the SAE testing procedure.
The fact that we disagree doesn't mean that I haven't spent some time with FMVSS-108. I suspect that you've spent more, but that doesn't make me wrong, or irresponsible. I know that when I read this stuff, I have a tendency to latch onto the parts that reinforce my own ideas (confirmation bias). I believe that I am not very different from yourself or most others in that respect. I think that you take a more conservative, risk-averse approach to the interpretation of rules such as FMVSS than I do. I tend toward a more liberal interpretation, and where there's ambiguity I try to look for the intent of the rule. I think most of us can imagine a situation where one might follow the rules to the letter, yet completely violate the intent. I did find this tidbit:
Which to me says that one can measure the light output at the source, at the surface of the lamp assembly, and compare results to the chart they provide. If your measurements are taken properly, and the values you measure fall within range, then you are in compliance. I haven't seen anything in FMVSS that says one cannot manufacture their own lamps, or that otherwise places any restrictions upon who can manufacture them. I also haven't seen anything to indicate that there is any authority other than NHTSA and the manufacturer (using the appropriate SAE specs) of what is DOT compliant. And NHTSA doesn't do compliance testing, but rather enforces the rules after they've been made aware that rules were broken. As far as I can tell, anyone can stamp their products with "DOT" and, even if they're not compliant, get away with that until they're called on it. I wouldn't disagree that there are some junky products for sale. But I do disagree that one must make an identical replica of an incandescent bulb for it to qualify as compliant, or for it to actually be a safe, functional equivalent. -Cullen | ||
| Sean Welsh (Sean)
Registered Member Username: Sean Post Number: 777 Registered: 1-2003 Posted From: 67.142.130.20 Rating: N/A |
All of that is true. And if you (or anyone else here) intend to "manufacture" a "replacement" stop or turn signal lamp, and then take the time to measure the photometric values as specified in the standard, and self-certify as to compliance, I have no problem with that whatsoever. Where this discussion started, and what I wrote way back before you joined in here, was with aftermarket "drop in" replacement "lamps" such as 1157 bayonet base models, wherein the manufacturer implies that they can be installed in any fixture that will fit them and be safe. Without making the photometric measurements (and few of us have the equipment to do so) after installing such a bulb in a specific fixture, you have not "manufactured" a "replacement lamp" -- you've only stuck an aftermarket part in a fixture not designed for it. I further stated that I had direct experience with the specific products that started the thread, and that I found them to be photometrically non-compliant in at least the fixtures I tried. I very seriously doubt, based on experience, that these or any of the other so-called 1157 replacements, would meet the photometric requirements in virtually any fixture. That said, it is certainly possible that some of these drop-ins will meet the standard in some fixtures. The problem is that you'd have to do the measurements to know. And the manufacturers do not tell you that -- instead, they strongly imply that the bulbs can just be used in any fixture as-is, while at the same time they weasel out of any responsibility or liability for it with language like that which I quoted from the subject website back in my post on 12/25. I continue to maintain that it is irresponsible to lead people to believe that these things are safe to use without additional testing, which is what their manufacturers are doing, and what several posters here have also advocated. Your blanket statement "Nor is it prohibited" merely reinforces that position. As I wrote and demonstrated, it is in fact prohibited -- whether or not NHTSA, FMCSA, the DOT, or any law enforcement agency enforces that prohibition or not is another matter. It is also prohibited, for instance, to replace the muffler on your Harley Davidson with a glass-pack, but that seems rarely enforced. Cullen, we are not making hot-rods here to go to the Concours. These are enormous vehicles capable of causing great physical harm when operated upon a highway. In many cases, they will be operated by folks with minimal training in the handling and operation of 20-ton, 40' vehicles with complex braking systems. Advocating that we play fast and loose with the regulations for required safety systems does seem, to me, to be irresponsible. There are, indeed, people here qualified to re-engineer their air brakes, and re-design the steering system, and I am sure there are people here like yourself who can download and read the SAE standards and construct a safe and compliant home-built brake light. But the average reader of this forum is looking for guidance on best practice. And for most of us, the safe thing to do is to stick to approved methods and materials. That means lighting assemblies that are certified by their manufacturers to be DOT-compliant. The companies marketing these untested and therefore non-compliant replacement bulbs are capitalizing on market demand and a lax enforcement environment to make a quick buck -- they are not in it to enhance the safety of the driving public. But here's the thing: it is trivially simple to be safe and legal. You can easily find fully DOT-compliant LED assemblies to replace most heavy-duty light fixtures. To be sure, they are more expensive than just sticking a "drop-in" into an incandescent fixture, but they are much safer. And if cost is the chief concern, I will point out that the cost of replacing incandescent bulbs (with identical incandescent bulbs) every time they burn out over the entire time we will own our buses will be far less than the cost of replacing them all one time with aftermarket "drop-in" LED replacements. My advice is and has always been that if you want to save money, stick with the OEM incandescents. If you want the benefits of LED lighting, including reduced current consumption, extended replacement intervals, and a more modern or high-end appearance, then spring for the DOT-approved fixtures. -Sean http://OurOdyssey.BlogSpot.com | ||
| H3-40 (Ace)
Registered Member Username: Ace Post Number: 956 Registered: 10-2004 Posted From: 206.53.153.124 Rating: N/A |
Wow, now I'm re-thinking my project that was very costly! Everyone sure comments on it though! Ah the price you have to pay! Ace | ||
| Kasse Weikel (More_s_than_as)
Registered Member Username: More_s_than_as Post Number: 17 Registered: 4-2009 Posted From: 71.84.122.200 Rating: N/A |
LOL there are soooo many contradictory laws involving vehicles, especially when you are trying to register and insure your conversion I agree with Sean on the part about lawyers, we have a few in my family, dont for a second think they wont bring up the fact that your lighting isnt up to code, especially if, as mentioned above, the person involved seriously couldnt see your lights and they specifically tell that to the lawyer. im not trying to start any hard feelings, i love you guys, but i have one disagreement with you as well sean...LED technology is coming a long way, they are almost ten times efficent in lumen to wattage ratios (almost all christmas lights are now LED). however it is correct that they would be inneficent for an upgrade unless yes, they entire unit was replaced for the reflector would definetly need to be a different design for most LED clusters are round in shape. Please dont discount LED as being insuperior to incandescent because LEDs are known to last longer and be much more efficient, it just takes a lot more of the little bulbs to add up to the lumens of one single incandescent. Ultimately Sean is Correct (in my opinion). i have a favorite Jan Irvin qoute - "your freedom ends where my nose begins" (he actually says he qouted that from some one else but i cant remember who). PLEASE keep it safe and visible out there if you cant afford the entire LED upgrade, just stick with the incandescants because the efficiency isnt an issue when running off an alternator heres the edit: OOPS im SORRY SEAN - i didnt fully read your last post, i guess im not disagreeing with you. LOL i pretty much just repeated you, so i guess we are in complete agreeance. BTW i scoped your ODYSSEY through a link somewhere else on the board. thanks for the really well done videos, the music adds the professional touch. so that must be one of the million dollar rigs i hear people murmuring about on this post. my dream is to one day have such conveniences, i love the "penthouse" and the deck. for now though, i gotta stick with KISS cause ima poor boy ;-p (Message edited by More_s_than_as on April 14, 2009) |