Auto Service World
Feature   May 1, 2008   by Andrew Ross

Trouble Lights

Non-Compliant Lighting and Why You're On Your Own

Despite a decade of lobbying and considerable effort by reps in the field to educate the market, the proliferation of non-compliant lighting in the heavy truck market is greater than ever. For those on the front lines, it is an exasperating situation.

According to Canadian field reps for major lighting suppliers such as Peterson Manufacturing, Truck-Lite, and Grote, it is not a case of if they will come across non-compliant lighting, but how much of it.

“We see it every day,” says one rep, who asked not to be identified. “You want names? Numbers? It’s everywhere.” He says that it’s disturbing how many lighting assemblies he sees that may look the part, but don’t perform in

accordance with accepted safety standards as defined by U. S. or Canadian original equipment regulations. It’s not just a battle over pricing; it’s about educating customers why substandard products are unsafe, he adds,

and why compliant products cost more. “Do people think we charge more just for our name? Do they think we are that stupid?”

Grote product manager Troy Bart says that he has noticed a trend in particular towards mislabelled lighting. “Reading the codes [on the lens], you can sometimes see lights that don’t meet those standards,” he says. “[Some suppliers] are not really testing the lamps to find out if the lighting works properly.”

What is increasingly found on substandard lighting, he says, is a string of certifications moulded into the lens, with little regard to whether the assembly actually meets those certifications.

Specifically, he offers an example of P2 lights, designed to be used as side marker lamps, having PC identification on them. This normally means they are acceptable for use at a 45-degree angle (on a corner position), but the ones in question didn’t have the lighting characteristics for that position. If such a light were installed on an angle, it would be virtually invisible unless viewed nearly head-on.

“That’s a big thing we are seeing in marker lights. We all want to make sure that the industry stays as it should. We don’t want substandard products coming into the country.”

Adam Crisp is president of the heavy-duty division of Grant Brothers Sales, which represents Peterson Manufacturing Co. in the Canadian market.

“It happens in every product category,” he says. “We run across a lot of it. We have a lot of people who will only put in Grote, Peterson, or Truck-Lite, too,” he adds.

It is, he says, an ongoing problem, one that requires constant education and re-education of the customer base. “You have a light failure, especially in the waste equipment side, and there is some major liability,” he offers as one point to consider. “That’s where you really have to be careful.” Suppliers seem to agree that the problem of non-compliant lighting has been exacerbated by the increasing use

of LED lighting.

This is true both for suppliers who might not test the units to spec and inadvertently build poorly performing lights

that look right but don’t perform, and others that purposely manufacture products designed to masquerade as highquality items in one way or another.

“What we have seen with the advent of high-brightness LED technology is that a lot of electronics manufacturers who could handle these components, but didn’t know the optics, were entering the market. They just didn’t know the requirements,” says Brad Van Riper, senior vice-president and chief technology officer, Truck-Lite.

Van Riper is generally regarded as one of the most active individuals on the issue, with a history of working with the U. S. National Highway and Traffic Safety Administration (NHTSA), the Society of Automotive Engineers, and the industry-specific Transportation Safety Equipment Institute.

“LEDs come in a variety of packages, and based on the selection criteria and sometimes based on the cost, you can have two discrete LEDs that look identical, but their output varies widely and their cost varies widely. So it is conceivable that you can hand-select some high-output LED and get your device qualified through one independent lab test, and then–for an unscrupulous person who is trying to skirt the regulatory side–take lower-output LEDs and insert them at a significant cost savings.

“Those operating the fleet are not able to see the difference unless it is compared to the other [compliant] device. And they think they are getting the same light for a much lower cost.”

This contrasts markedly with incandescent bulb use, where the outputs tend to be more standard and discernable.

Van Riper says that while it is important to realize that not every offshore supplier is delivering substandard, non-compliant products into the Canadian or North American market, the preponderance of these products seems to be coming from Asian sources.

“The old adage that if it sounds too good to be true, it likely is, continues to ring true as it relates to parts,” he says.

The argument for LED use, despite the product issues to which it might have contributed, are undeniable. The performance of LED technology is, simply put, far superior to incandescent lighting in virtually every category, with longevity being a big selling point.

“People don’t want to get up on the roof to change them,” says Mark Assenmacher of Peterson Manufacturing. “So there is still an opportunity, despite the pricing of about four times the cost of incandescent, because they have six times the life.”

Plus their real-world life may be even greater, as they are less susceptible to damage from road shock and impact.

“And they have about 1/10th the amp draw,” adds fellow Peterson staffer Mack Gregory. “The load on the alternator with all LED [lights] on a trailer is less than having one tail light in incandescent.”

Even so, the sheer creativity behind non-compliant “solutions” is startling. One example might be the LED in an 1157 socket package that yields little real effective light; LEDs by nature are highly directional light sources and cannot simply be dropped into a reflector and lens combination designed for a highly non-directional incandescent light source. The former require a scattering lens reflector assembly, the latter a focusing one.

And that is just one particular facet of the issue. “We have a real problem with transit authorities,” he says, adding that there are new examples every day of fleet managers and purchasing agents unwittingly making decisions to install non-compliant products to meet budgetary imperatives.

Gregory admits the issue is complicated, but reduces the decision down to a simple point.

“If it is federal law, why would you buy a light from someone beyond the reach of the law? That, in my opinion, is the bottom line.”

However, industry players are not prepared to rely solely on good intentions.

“Truck-Lite, Grote, and Peterson are all members of TSEI, and we work with both NHTSA and Transport Canada in terms of communicating our concerns relative to products coming into the market.”

In fact, there are 23 member companies of TSEI, plus a handful of associate members, who supply components.

“As a group of competitors we are monitoring the market. I would say that about eight to 10 years ago we started to see this influx, particularly from Asian markets, of grossly noncompliant product. When we made the NHTSA aware of this they didn’t have the staff to do the investigations necessary to begin action”–NHTSA has a staff of only about a dozen– “and so we were a bit frustrated.”

Extensive lobbying and supporting documentation has had an effect though.

“NHTSA has heard our cry and they do regulate both OE and aftermarket products. And they have hired two more engineers in response to our efforts to make them aware of this safety issue.”

He adds that it is important to think of the non-compliant lighting issue as a safety issue, and that has been the underlying impetus behind recalls and other actions taken by N
HTSA to inform suppliers of the importance of compliance.

However, a similar response has been lacking in Canada.

“In Canada we have made Transport Canada aware of our concerns, but one difference is that while Transport Canada, like NHTSA, regulates the OEM installation of products and does a pretty good job of that, they don’t regulate the aftermarket, in contrast to the NHTSA.”

The lack of a mechanism to regulate it has, at least in part, caused a shift in focus for suppliers of non-compliant lighting.

“Where there seems to be a big influx of non-compliant, low-cost lamps coming into Canada, they are not very well regulated.

“Some of the people we have seen in the U. S. are migrating into Canada to sell their wares.”

Marcin Gorzkowski, senior regulatory development engineer for Transport Canada, confirms that there is no equivalent to NHTSA’s dual aftermarket/OE role handling practice in Canada.

“The official position on it is that the federal government regulates only the original equipment and we actually do not deal with the component manufacturers on lighting. And if something is wrong with the lighting on the equipment, we deal with the OE.”

He says, however, that in his days in the enforcement department he often dealt with lamp manufacturers who would tip him off to potential problems, which he would then investigate. The next step would be to go to the vehicle manufacturer. It was a system that worked well, and gave him a solid understanding of the issue, but that is not the same as having jurisdiction over non-compliant products in the aftermarket, which he insists are firmly in the provincial arena.

“We are trying to find a way to get to those people [at the OE level]. Recently, with a more and more open market, we are getting more and more components from countries where they read the regulation, but they didn’t really understand it. We have some components that may cause problems.

“But a lot of the stuff goes straight to the aftermarket and it is the provinces who are responsible for the aftermarket. The problem with the provinces is that they do not have regulations for the components.

“We hope that whatever is on the market does comply. Most of the product is acceptable, but the problem we have is with some novelties,” he adds. Some items that may never be allowed as OE are available in the aftermarket and sold freely, even by major retailers.

“There is no real test for that. We don’t have jurisdiction.” And, he adds, the provinces have precious few resources to enforce often broadly worded regulations.

In de facto terms this translates into a need for the aftermarket to regulate itself in Canada.

So, without a robust regulatory mechanism, what is left for distributors, wholesalers, retailers, and their customers is some due diligence.

And, while there is some evidence of outright counterfeit products and other unscrupulous behaviour, Van Riper suggests that there are some common practices that can tip off a buyer to potential quality problems.

• Check for identification on the product itself, not just the packaging. Often substandard lighting assemblies are devoid of branding, making it impossible to trace their origin if there is a problem. (This is, incidentally, not restricted to lighting.)

• Check for certifications on the product itself, denoting where and how it can be used, as well as standard DOT and SAE codes.

• Check for “Due Care Documentation,” which reveals an ongoing pattern of testing and inspection to ensure that products meet the standards. A single test report is not necessarily evidence that the products being supplied today are in compliance.

Considering the focus of the TSEI’s activities, it might also be useful to check for membership in that organization as an assurance of quality and compliance, though a lack of membership shouldn’t be taken as sure evidence of noncompliance.

Gorzkowski adds that looking for participation in SAE committees is another place to look for assurance.

“Ask SAE for the roster of lighting companies. If you see that the company is not represented anywhere at TSEI, SAE, ISO, or anywhere else, you might want to look somewhere else for a supplier.

“The ones who are members are listening to the problems, and are testing.” Members of those organizations conduct blind testing of products continually.

“It is anonymous testing and if they find a problem, we talk about the problems. Those are the good guys.”

“I’d also like to suggest that they look for SAE standard J759, which is the SAE lighting identification code,” says Van Riper. While voluntary, it remains a clear identification that the manufacturer is testing to an accepted standard. “We are trying to encourage the voluntary inclusion of this lighting identification on the product.” And, he adds, the number and letter combinations denoting the positions in which lights are certified for use should be noted carefully. “No marking typically means they are trying to get away with something.”

Van Riper acknowledges that distributors might find the whole issue difficult to deal with, particularly when customers push aggressively for lower pricing.

“There is a lot of pressure on distributors to help their customers out and they think they’re doing the right thing, but being an educated consumer is extremely important, whether you are a distributor or a fleet.”

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