MoparDaddy
Damn Right I Carry!
Spahetti! Show some love for us late 7+'4 cordoba owners with some LED's
New LED tail lights 69 Cuda
- Thread starter Bakaruda
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airwoofer
Drivetrain limit explorer
I say based on those pics that Spagetti is qualified to be a MOPAR guy. Question I have is how do the LED lights get into the tail light housings? Maybe I need to look deeper but I think there is only a hole for the bulbs, not a way to get a whole circuit card in.
SebastianSpaghetti
Member
We design our light panels to the meet the standards of DOT and SAE for lighting. The same standards the government recognizes. Again we are not replacing the lens or reflector.
slantsixdan
=..=
That's a good start, but do you test and certify, as you are required by law to do, that your lights meet the applicable provisions of FMVSS 108? Whether or not you replace the lens or reflector doesn't change your obligation; in fact, your retaining the original lens and/or reflector subjects you to additional requirements that your product not "render inoperative" a regulated item, system, or feature. That phrase "render inoperative" is in quotes because it means more than it looks like it means. It's not enough that your product retain all the same functions as the bulb it replaces. It must also maintain the compliant performance of the device. If any function (e.g., taillamp function, stop lamp function, etc.) does not meet all applicable requirements, then you have "rendered inoperative" that function.
This is a direct question and I would like a direct answer, please, because automotive lighting technical standards development and assessment is a major part of what I do for a living, and it looks to me as if your Barracuda lamps might not meet the applicable requirements. I'm not involved in enforcement of the Federal regulations, so I have no power or desire to smack you with the exceedingly stiff civil penalties of $6K per violation (1 lamp = 1 violation) NHTSA can assess and collect from manufacturers or importers of noncompliant lamps. It's just that if I'm going to buy these — and I am considering buying some of your lights for at least one of my cars — I need to know whether or not they are manufacturer-certified as complying with all applicable provisions of FMVSS 108, because that is what determines their legality and the adequacy of their safety performance. Practically speaking, it matters. Maybe not today or tomorrow or next week, but it will Matter with an uppercase M (and uppercase dollar signs) in the event a crash happens and the nonstandard lights are discovered.
These aren't toys or Xmas tree lights we're talking about, they're regulated items of vehicle safety equipment. Sure, yours look cool. You say you design them to conform to the applicable standards. Can you prove it? Will you?
caferacerx
BAND MEMBER
SebastianSpaghetti
Member
Double post
pauly v.100
Well-Known Member
sorry Dan, I gotta go with Spaghetti on this one. I respect your knowledge of lighting and laws but after weighing the options and reading through pretty much all you had to contribute to the LED topic, I converted my tail lights using a 6" truck light with it's own reflector mounted inside my existing housing. I don't regret it at all, it's SO much better than the previous lights that its hard to describe.
Just yesterday I watched a 69 Valiant go down my street and I watched as he got to the bottom of the hill and hit his brakes... I almost couldn't see his brake lights at all, they were THAT bad.
All these standards that you continually use to justify your argument sound like guidelines for current manufacturers, I could be wrong, but theres no denying the improvement that current technology lighting has on our 40+ year old cars when it's done properly. that's my 2 cents!
Just yesterday I watched a 69 Valiant go down my street and I watched as he got to the bottom of the hill and hit his brakes... I almost couldn't see his brake lights at all, they were THAT bad.
All these standards that you continually use to justify your argument sound like guidelines for current manufacturers, I could be wrong, but theres no denying the improvement that current technology lighting has on our 40+ year old cars when it's done properly. that's my 2 cents!
slantsixdan
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That is not correct. Federal Motor Vehicle Safety Standard 108 is a Federal law, which contains mandatory design, construction, performance and durability requirements for all regulated lamps and reflective devices, including stop lamps, tail lamps, reversing lamps, etc.
Some aspects of current and past SAE standards are incorporated in FMVSS 108 requirements. However, SAE standards themselves do not carry force of law. Compliance with SAE standards by itself is not sufficient to demonstrate legal compliance of the product; for that you must certify compliance with FMVSS 108.
That is not correct; the responsibility and the liability is yours as the manufacturer. Under Federal law, each and any regulated item of vehicle equipment must be certified by its manufacturer or importer as fully complying with all applicable provisions of all applicable Federal Motor Vehicle Safety Standards if it is physically capable of being installed on a vehicle certified by its manufacturer as compliant with all applicable Federal Motor Vehicle Safety Standards. All vehicles made on or after 1/1/68 for sale in the United States market are so certified; prior to that date no Federal Motor Vehicle Safety Standards existed.
That would be interesting, but the responsibility to do (and pay for) those tests is yours, not mine.
Nonsense. You seem not to understand your responsibilities and obligations as a manufacturer of regulated vehicle safety equipment. Federal Motor Vehicle Safety Standards are promulgated and administered by the National Highway Traffic Safety Administration, an agency under the Federal Department of Transportation. I provided a link to NHTSA's information sheet on the responsibilities and obligations of importers and manufacturers of regulated vehicle equipment. Did you read it?
I asked you a simple question: Do you certify your product as compliant with all applicable provisions of Federal Motor Vehicle Safety Standard 108? So far you haven't answered; I have to asssume, then, that the answer is "No".
Want to do it right? Get in touch with Calcoast ITL. They're a reputable compliance testing lab, and they'll happily spend time on the phone explaining your obligations under Federal law, even if you choose not to go forward with their testing services.
You're welcome to your opinion of me. The law is the law and your obligations under it are your obligations under it even if you choose to ignore it. If it gets you to bring your product and compliance in line with the law, then you'll probably wind up sooner or later thanking me for saving you from a ruinously expensive liability lawsuit and/or civil penalties from NHTSA.
slantsixdan
=..=
Nothing illegal about that -- the truck light you used is tested and certified by its manufacturer as complying with all applicable provisions of FMVSS 108.
They're not "guidelines". They're mandatory requirements. And they've been that way since 1/1/68. Periodically updated, of course, and replacement equipment for old cars needs to meet only those requirements that applied to the vehicle when it was new.
SebastianSpaghetti
Member
If you were concered with products rather then browbeating, you would have focused on positive effects of these regulations, rather then on making me aware of the fines and penalties. I presume that no matter what someone may say or provide, nothing will be to your satisfaction. I would welcome you to study, learn, and accomplish rather then copy, paste, and condemn.
Sebastian
sb@spaghettiengineering.com
Sebastian
sb@spaghettiengineering.com
Although Dan comes across as gruff and negetive, he really is trying to help you, whether you see it or not .... Take his advice or ignore it but at least you are aware if big brother comes a knockin they might take it seriously .
Steve
Steve
swisswill
Well-Known Member
One of many reasons company's don't do much "Mopar" development... right, wrong, or otherwise.
Judge Mills
1971 Plymouth Duster
I just want to say that product looks AWESOME! I hope by the time I get close to being done on my Duster that Spaghetti has them for it!
SebastianSpaghetti
Member
I am not opposed to insightful information. My main intent is to offer products to fellow car guys.
Most of the DOT requirements apply to the plastic used to make the lenses and such. None of that is effected here.
I posted in another thread about the crap quality in OEM fixtures in newer models.
Ford, Toyota, and eveyone one else can sell clear lenses that turn milky white, fixtures that fill with water, etc..., the DOT has bigger fish to fry.
I posted in another thread about the crap quality in OEM fixtures in newer models.
Ford, Toyota, and eveyone one else can sell clear lenses that turn milky white, fixtures that fill with water, etc..., the DOT has bigger fish to fry.
goldfish65
Well-Known Member
Out of curiosity I googled MVSS 108 -- I read it and I can see the requirements are there for good reason. Also see why there are companies who will do the testing for you because it's very complicated. It could be a great selling point for these lenses if you could say they have been tested to meet government standards. Yes sometimes Dan comes across as abrasive but he knows his stuff, don't get mad at him because you don't like the regulations.
highwaystar
Well-Known Member
I will take at least one set for the 68 Cuda. Let us know when there ready.
I think you guys are missing the point. The factory tested and approved tail light lens is reused. This product replaces the old 1157 bulp with a led board and lights. This is no different than replacing a 1157 with a led 1157, it is just brighter and uses less amps.
Or maybe I am missing the point to the regulations.
caferacerx
BAND MEMBER
there is no downside to making sure any product you make or sell is safe and legal for your customers to install on their cars,
it is your responsibility as the manufacturer to make sure your products are DOT approved
it is simply a part of doing business,
it is your responsibility as the manufacturer to make sure your products are DOT approved
it is simply a part of doing business,
caferacerx
BAND MEMBER
first I would like to say,I am not an expert, that would be Dan, and I am sure he will correct me if I am wrong, but here is what I believe is the problem
the 1157 bulb is only one part of the tail light,
the bulb,the reflector that sits behind the bulb and the lens are the others
and they must all work together in order to have a proper safe tail light
the bulb must be placed in the correct position within the reflector in order to allow the reflector to do it's job of reflecting the light from the bulb through the lens at the proper angles,
the lens and reflector are designed as a single unit, if you move the position of the bulb, or remove the reflector,
as with a flat LED panel, you compromise the lens's ability to work properly
SebastianSpaghetti
Member
The reflector is molding into the lens, so there is never a situation where they are removed.
Again, in all instances of replacing the bulb with our LED panel, we have found that light output in all directions has been improved. Depending on the model, each panel has 40 to 70 LEDs, making sure we fill the lens area with light. We dedicate a lot of time to develop a panel specific for each model, not just in size but in placement of the LEDs to get the best look and maximum output. In any of the many models we offer you can visibly see a difference for the better, add the sequential effect and its like no other light. The incandescent bulb is getting replaced by a brighter long lasting improved solution, The LED.
pauly v.100
Well-Known Member
Understood, thanks!
caferacerx
BAND MEMBER
the reflector is the part of the tail light behind the bulb incorporating the bulb holder
it is not part of the lens, but it is designed to work in conjunction with the lens
an LED panel fits between the reflector and the lens, rendering it inoperable
it is quite possible that your LED system exceeds the OEM 1157 bulb that it replaces, and therefore exceeds DOT requirements
the only way to know for sure is to have them tested as required by law
from a business standpoint being able to say meets or exceeds OEM requirements is worth more than the small cost of having them tested
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