Truck-Lite 7" LED HEADLIGHT

[-Virgil-]

Cal Sense is an independent testing facility working under ISO17025 and approved by the SAE.

There is no such thing as "SAE approval". SAE is not a regulatory body and does not have the authority to approve anything or anyone. I'm not sure who Cal Sense is -- are you possibly talking about CalCoast Labs?

When they release an approval for a product according to a certain SAE standard one can be sure it was tested properly and "with no corners rounded".

There is no such thing as an approval for a product according to an SAE standard. In the first place, SAE standards do not carry the weight of law. In the USA, all regulated vehicle lighting devices must conform to Federal Motor Vehicle Safety Standard 108. In Canada, the applicable standards are Canada Motor Vehicle Safety Standards 108 and 108.1. These standards incorporate provisions from various current and obsolete SAE standards, as well as provisions from other sources. Compliance is on a self-certification basis, not a type-approval basis; the manufacturer or importer of a vehicle or item of regulated vehicle equipment certifies that the product complies with all applicable provisions of all applicable regulations. Headlamps must be marked "DOT" to signify such compliance; many other lighting devices do not require any marking. If there arises reason to suspect a regulated product does not in fact comply, the US Department of Transportation (or Transport Canada) may purchase and test samples of the item. If it does not comply, the manufacturer or importer will be notified, at which point they have the option to petition for the noncompliance to be considered inconsequential to safety. If this petition is denied, the manufacturer is obligated to recall the noncomplying items and replace or refund them, and may be subject to civil penalties.

It is up to the manufacturer or importer to decide what homework to do prior to marketing the item. There is certainly a list of tests their equipment _should_ pass before they decide to market it, but there is nothing stopping anyone marking "DOT" on an untested headlamp and selling it, gambing that they won't get caught. It's usually a pretty good gamble. Again, test labs (such as CalCoast) do not issue certifications or approvals.

Test labs are in a very tough position. If they adhere strictly to the law requirements and interpret the regulatory language narrowly, more submitted devices will be found noncompliant...and more manufacturers will say "Hmph...fine, we'll take our business elsewhere", because there are plenty of other test labs who'll be happy (as long as the customer's check clears!) to take a broader, less stringent approach to interpreting the regulations and the test results.

There is a similar situation with the European type-approval system; the tech authorities and their accredited labs in some countries have reputations as rubber-stamp outfits who'll issue a type approval for any piece of junk. It's why so many cheap aftermarket lamps have an E13 E-mark, for example.

So what keeps Truck Lite from getting such an approval for this headlamp? $3000 which is the cost of testing it?

There is no approval to get. You seem to misunderstand the North American system rather completely. I hope this post has helped you to understand it better.

Back to the headlamp in question: its performance is pathetic, but so is the performance of the 24v sealed beam it supplants. The fact that the military buys a lot of them does not imply that it's a good headlamp. All it implies is that the military spends a lot of money with Truck-Lite.

 

[Alaric Darconville]

As there are several things quoted and I don't know on which one you need clarification, I will try to explain my point

Actually, I needed no clarification; I simply had a part of quote from you (in #17 of this thread) outside the bounds of the [QUOTE] tag pair. I have since fixed that.

Hopefully, between my and Scheinwerfermann's replies in this thread, you have a better understanding of the North American system.

 

[Emanuel]

I'm not sure who Cal Sense is -- are you possibly talking about CalCoast Labs?

CalCoast-ITL indeed - I was stuck with calsense for some reason (age problems, you know)

 

[Emanuel]

In this case I am really confused:

I had the impression that FMVSS108 explains what should be installed and where in a vehicle and some general parameters while the SAE standards explain testing procedures for each part in detail.

I must say that while the ECE standards are very simple to understand this is not the case with the DOT, while SAE is a little easier to understand.

So, if we are talking about a military product, and we split the environmental tests from the photometry, if I have a lamp that passed all the MIL-STDs from the mechanical, electrical, environmental and EMI compliance, the company has all the optical testing equipment including goniophotometer, and is ISO9001:2008 approved I can place the DOT mark with no fear on my product?

I wish our DOT knew that, we are forced to show SAE approvals made in US. Some time ago they requested SAE J887 for school bus lamps and failure to present this document resulted in import denial.

 

[Alaric Darconville]

So, if we are talking about a military product, and we split the environmental tests from the photometry, if I have a lamp that passed all the MIL-STDs from the mechanical, electrical, environmental and EMI compliance, the company has all the optical testing equipment including goniophotometer, and is ISO9001:2008 approved I can place the DOT mark with no fear on my product?

If you have a lamp that you are willing to certify passes the tests, you can place the DOT mark on your product. You don't need any ISO xxxx:yyyy anythings for that.

Certification to an ISO 9001 standard does not guarantee any quality of end products and services; rather, it certifies that formalized business processes are being applied.

I wish our DOT knew that, we are forced to show SAE approvals made in US. Some time ago they requested SAE J887 for school bus lamps and failure to present this document resulted in import denial.

If by "your DOT", you mean the Ministry of Transport and Road Safety, they have the right to not take a manufacturer at their word that their product conforms to particular standards, by virtue of a) that's their right and b) self-certification can lead to junk, non-conforming products.

SAE J887 is not available for purchase at this time. Take it up with them.

 

[tino_ale]

Interresting info here.

I see two scenarios :
1. Truck-lite headlamp's "DOT" mark is legit, in that case I don't know if it is that important to know if it is self certified or not because this mark obviously means nothing, looking at the beam
2. Truck-lite would in fact not pass DOT tests

In both case the result is the same. Such a crappy beam get's on the road and I find it quite unbelievable.

 

[Emanuel]

ISO standard, at least when updated and controlled, is at least a way to make sure the equipment is calibrated, procedures are followed and standards (such as SAE for example) are kept updated.

Anyway, now I undertand better the method, I am going to issue a meeting with the local Dept. of Transportation and see why they insist on SAE approvals.

Is there any documentation explaining in plain words the self-creditation method in the US, or the fact that a manufacturer/importer is allowed to use the DOT mark as explained?

It can help me a lot when I meet these people.

 

[-Virgil-]

Emmanuel, what country do you live in?

Any government is free to set whatever standards they want for automotive lighting, assuming there's no preemptive greater framework in place (for example, American states and Canadian provinces are not permitted to enact or enforce lighting equipment standards that are more stringent than the respective national standards, and EU member states are not permitted to enact nationally-specific standards that are more stringent than the applicable ECE regulations).

FMVSS 108 and CMVSS 108 make reference to various provisions of various current and obsolete SAE documents, but this does not imbue the SAE documents with force of law, nor are those SAE documents the totality of the regulatory requirements (which, again, are in F/CMVSS 108).

ISO standards have nothing to do with vehicle lighting engineering or compliance testing.

Military standards are wholly separate from civilian vehicle lighting equipment standards.

There is still no such thing as an "SAE approval".

 

[Emanuel]

Emmanuel, what country do you live in?

As you see near my user details in Israel.
The majority of standard requirements related to vehicular lamps here are based on both US and European standards, as the cars imported are Japanese, European or American.
There are very few specific local regulations.

ISO standards have nothing to do with vehicle lighting engineering or compliance testing.

I know, I just mentioned the ISO as a recognized quality assurance system specially where a manufacturer is doing self-certification. For example, ISO is a first requirement when you apply for ECE approval.

Military standards are wholly separate from civilian vehicle lighting equipment standards.?

Absolutely right, but often they are more severe than the civilian equivalent. I mentioned that when asking about self-certification. My question was, if I have for example a product that was subjected and passed military standards (all but photometry) then I can be sure the same product will pass the civilian equivalents with no problem.

There is still no such thing as an "SAE approval".

OK, of course, I got the point - and this is why I asked if someone could provide some links to where all we discussed here is officialy documented.

The reason is, I want to issue a meeting with the Dept. of Transportation here.
They do insist that manufacturers/importers will provide "SAE approval" which in fact doesn't exists.
For example, if we speak about emergency waning lamps, if somebody wants to import them, the requirement is one of the two: E65 or SAE J595 (or J845).
Everything here is based on "SAE approvals" including official tenders where products are requested to have these "approvals".

As strange as it sounds, it seems there is a missunderstanding of the fact there are no "SAE approvals" as you both explained here and I would like to see if the situation can be changed by our Dept. of Transportation.

 

[-Virgil-]

Israel.
The majority of standard requirements related to vehicular lamps here are based on both US and European standards

FWIU, the Israeli vehicle lighting code is an arbitrary mess. European headlamps are required except that US headlamps accepting 9005 and 9006 bulbs and marked as such are permitted, and other US headlamps are accepted on an arbitrary case-by-case basis.

ISO is a first requirement when you apply for ECE approval.

Incorrect.

if I have for example a product that was subjected and passed military standards (all but photometry) then I can be sure the same product will pass the civilian equivalents with no problem.

Probably, but not definitely. In some cases the requirements are simply different.

They do insist that manufacturers/importers will provide "SAE approval" which in fact doesn't exists

I think probably what you have here is nothing more than a minor language issue. You are saying "SAE approval", and perhaps so is your DOT, when in fact what is meant is proof of compliance with a particular SAE standard. That's not an approval (the approval, or we might be better to say the "acceptance" of whatever form, is granted by your DOT), it's just proof of compliance, but "SAE approval" is likely to be used as convenient if technically incorrect shorthand.

As strange as it sounds, it seems there is a missunderstanding of the fact there are no "SAE approvals" as you both explained here and I would like to see if the situation can be changed by our Dept. of Transportation.

You may want to send an e-mail to Daniel Stern before you set up that meeting -- I recall his mentioning some other points that need addressing and correcting in Israel's vehicle lighting code.

 

[Emanuel]

My interest in undersanding these procedures is divided in 2:

Regarding the local mess and interpretation of US or EC regulations I am strictly intersted in strobes/beacons for emergency vehicles. We are the only manufacturer of these products while all the competitors are importers. From one point of view, requirement of some kind of compliance proof such as a test made by an independent lab based on an SAE standard is a good idea. The fact that as local manufacturers we need to send products aboard for testing while we can self-certify is making life hard. But as mentioned in of the replies a government can decide on anything.
The problem I see is that while such a requirement can eliminate all the Chinese products (and for good reasons) it absolutely discriminates legal manufacturers.
The thing is, they are not checking what is presented to them:
This is an SAE J595 test certificate presented for a Chinese made product imported by a local company.

The test was made on 6/2009 based on 1/2005 version of the J595 (not only that this shows how serious this lab is) but the 2005 SAE was not yet adopted to LED, they had to use at least the 12/2007 update.

But pay attention to the lower half of the page - non of the environmental tests were performed. (not to mention high temp. flash rate)

And this product is legally imported, while I need to send my products aboard for approval.

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Regarding headlights, the story is different:
What we make is strictly used on tanks and armored vehicles.
The self-certification possibility is of great help and thanks to CPF and you guys I became aware of this. (For the US market of course)

For the local market we don't need this as tanks are not required to drive on roads and for other military vehicles the army is an independent regulatory authority.

The problem is in Europe - there it seems tanks can be driven on roads !!!
They need all illumination system of a vehicle and all according to ECE regulations.
Same with armored vehicles, all the 6x6 or 8x8 they go even on highways.

Here comes the stupid part - the installation in some of these vehicles is at 180cm height (almost 71") much above the 120cm European maximum height or the 54" in the US.

So why having an approved lamp at this height which is not authorized.... maybe if we were in the EC I could understand.

Another thing is leveling mechanism which is required for lamps and not allowed by the users.

It seems like mess is everywhere when regulations is what we are talking about.

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I think you are right about the "SAE approval" being a kind of a language missinterpretation to a basic proof of compliance made by an independent lab, or confused with the EC approvals where the testing is a must.

 

[Alaric Darconville]

1245x1754 is too large.
Please resize.

 

[Emanuel]

1245x1754 is too large.
Please resize.

rsized, if still not there here is the direct link

http://www.nova-light.com/images/sae.jpg

 

[-Virgil-]

The fact that as local manufacturers we need to send products aboard for testing while we can self-certify is making life hard.

I'm not sure I follow you here. Self-certification is how the American and Canadian regulatory regimes work. It sounds as if the Israeli government does not take manufacturer self-certifications at face value the way the US and Canadian governments do.

The problem I see is that while such a requirement can eliminate all the Chinese products

No, it can't! I have seen lots of obviously phony "test reports" out of China and Taiwan, and I've seen some out of other places, too -- even Japan. Remember, just because there's a document that says a device passed a test, doesn't mean the device passed the test...in fact, it doesn't even mean the test was done properly, or that the test was done at all. Same goes for lens markings; in theory they indicate the functions a device produces and the particulars of its compliance, but here again, anyone can put any mark on anything. They're not supposed to, and eventually they might get caught, but baseless self-certification or type-approval marks are very common.

The thing is, they are not checking what is presented to them:
This is an SAE J595 test certificate presented for a Chinese made product imported by a local company. The test was made on 6/2009 based on 1/2005 version of the J595 (not only that this shows how serious this lab is) but the 2005 SAE was not yet adopted to LED, they had to use at least the 12/2007 update. But pay attention to the lower half of the page - non of the environmental tests were performed. (not to mention high temp. flash rate)

There are problems with your comprehension. In the first place, SAE standards are not updated every year. The rough schedule for document review and revision is every five years, though some go much longer than that and some are updated more often than that, as warranted by changes in technology or other factors. The latest version of J595 is 2008/11, but even so, the fact that they tested to J595_2005 does not necessarily mean they are out of compliance. It's possible Israeli regulations specifically call for compliance with that version of J595, or that they don't specify what revision of J595 is required. Also, it's possible the Israeli regulation requires only proof of compliance with the color, photometry, and physical-inspection portions of J595. You need to do check into what the Israeli regulation actually requires before you go to that meeting you're trying to set up, or they'll probably just ignore you (or worse).

And this product is legally imported, while I need to send my products aboard for approval.

Well, if that's how the game is played in Israel, then perhaps your options are to either join them (put together phony test reports or pay a rubberstamp test lab for a rubberstamp report) or do it right and advertise that fact heavily to differentiate your product from all the rest.

Regarding headlights, the story is different:
What we make is strictly used on tanks and armored vehicles.
The self-certification possibility is of great help

Again, the American-style self certification does not necessarily mean anything outside the US and Canada.

The problem is in Europe - there it seems tanks can be driven on roads!!!

Well, not necessarily, it's just that they have to have road-legal lighting systems.

Here comes the stupid part - the installation in some of these vehicles is at 180cm height (almost 71") much above the 120cm European maximum height or the 54" in the US.

It should not be difficult for you to understand that tanks and other such vehicles aren't subject to the headlamp height restrictions applied to ordinary vehicles.

Another thing is leveling mechanism which is required for lamps and not allowed by the users.

Eh? What do you mean "not allowed by the users"?

 

[-Virgil-]

I see two scenarios :
1. Truck-lite headlamp's "DOT" mark is legit, in that case I don't know if it is that important to know if it is self certified or not because this mark obviously means nothing, looking at the beam

There is too much room in both the US (SAE) and rest-of-the-world (ECE) standards for bad headlamps. There's a persistent myth in America that European headlamps are better than US lamps. That's wrong. There are good and bad US lamps, and there are good and bad European lamps. Less-than-knowledgeable enthusiasts tend to focus on parameters that are relatively unimportant to the safety performance of a headlamp, such as the cutoff sharpness.

2. Truck-lite would in fact not pass DOT tests

That's probably not the case -- I think they are probably producing a compliant product. Is it a good lamp? No. But it's probably compliant.

 

[Alaric Darconville]

Another thing is leveling mechanism which is required for lamps and not allowed by the users.

Do you mean to say that the leveling mechanism is not allowed to be adjusted by users (that is, they must be automatically controlled without user intervention or user override)?

 

[tay]

Do you mean to say that the leveling mechanism is not allowed to be adjusted by users (that is, they must be automatically controlled without user intervention or user override)?

It could be that the military does not want auto-levelling on their vehicles because of additional complexity and risk of failure.

Are there commercial available headlamp auto-levelling systems that are compliant with more stringent military standards?

 

[Emanuel]

There are problems with your comprehension. In the first place, SAE standards are not updated every year. The rough schedule for document review and revision is every five years, though some go much longer than that and some are updated more often than that, as warranted by changes in technology or other factors. The latest version of J595 is 2008/11, but even so, the fact that they tested to J595_2005 does not necessarily mean they are out of compliance.

Any laboratory performing official certification/approval should work under ISO 17025. One of the basic rules is working on the latest standards updates, exactly as keeping the equipment calibrated.

SAE J595 was updated in 11 or 12 2008 to LED technology. I think that testing a product in 2009 according to a 2005 standard version shows what this lab is. (maybe self certified too???)

Regarding local rules, no, the requirement is to have the test done. If the intention was to have only photometry, then somebody would mention SAE Jxxx paragraph/s yyy.

What I tried to show is that you can put any paper in front of them, nobody looks at it anyway.

 

[Emanuel]

It could be that the military does not want auto-levelling on their vehicles because of additional complexity and risk of failure.

Usually there is a factory setup, not user adjustable.
Yes, the less mechanics involved the more reliable the assembly is.
Let's not forget the extreme vibration and shock such a lamp is subjected to in a tank.

Another reason is dust, accumulating in the adjusting mechanism.

 

[tay]

Usually there is a factory setup, not user adjustable.
Yes, the less mechanics involved the more reliable the assembly is.
Let's not forget the extreme vibration and shock such a lamp is subjected to in a tank.

Another reason is dust, accumulating in the adjusting mechanism.

I've worked with some military helicopter lighting systems, and the fact that they were approved for use in commercial aircraft did not mean that we could put them in military aircraft. A significant amount of photometric lab testing and field testing was required to qualify these LED assemblies for use in military aircraft.