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Dedicated to conservation and multiple use of public lands for recreation opportunities. Edited by: John Stewart |
NHTSA Targeting Glare From Front Mounted Lamps
The National Highway Traffic Safety Administration (NHTSA) is reviewing consumer and law enforcement complaints concerning the perceived glare from headlamps and front-mounted auxiliary lamps. To this end, NHTSA is requesting comments on means to reduce glare. The agency is focusing its attention on: 1) HID lights; 2) fog lights and other optional lights; 3) high-mounted headlights on trucks and SUVs.
NHTSA plans to propose action to regulate fog lamps, auxiliary and driving lamps at the federal level and is initiating research to study all potential factors that may cause some lamps to be perceived as an annoying light source. NHTSA has also stepped up review and enforcement against aftermarket manufacturers that market lighting equipment that is not in compliance with federal standards and could be contributing to the perceived glare problem.
We Urge You to Contact the SEMA Government Affairs Office and NHTSA to Express Your Concerns. (see below for contact information)
NHTSA officials are asking the public and industry for comments on theseissues to help them determine how to proceed. The SEMA Government Affairs staff is preparing comments on behalf of the industry. To that end, we need your help in crafting technical arguments to the following points:
· The aftermarket industry is on the leading edge of technological advances in new lighting products that promote safety and provide styling alternatives. Innovative aftermarket lighting products for cars, trucks and SUVs provide greater road illumination and create increased visibility.
· Cutting edge technology, such as HID lamps, that comply with federal standards result in more light than halogen lamps and an increased field of view, allowing the driver to see more clearly and concentrate better.
· The experience of some drivers when facing HID lamps for the first time from an oncoming vehicle is the same as when halogen lamps first replaced non-halogen lamps. Approaching drivers who are unfamiliar with the whiter light may instinctively look at the HID lamps rather than away. That reaction will disappear as the light source becomes more familiar.
· We are aware of no evidence that suggests that HID lamps are responsible for highway accidents. Current legal mounting heights for headlamps range from 22 to 54 inches to accommodate variations in vehicle size and ground clearance while addressing safety concerns. NHTSA may reduce the upper mounting height to 35 inches (based on one SAE recommendation), an action which could unnecessarily prohibit sales and use of aftermarket equipment (e.g. suspension and body lifts, larger tires) to modify utility vehicles for extra ground clearance or off-road capabilities.
· Headlamp misaim may increase as a vehicle ages, often causing glare. NHTSA should encourage states to focus enforcement on correcting misaimed lamps.
· NHTSA should encourage local law enforcement to uphold current laws restricting conditions when fog lamp/auxiliary lamp use is allowed.
· Aftermarket lamps should not be required to conform to the specifications of standardized original equipment manufacturers' (OEM) lamps. Aftermarket manufacturers should only be required to meet the lighting parameters required by NHTSA. The distinction must be drawn between complying and non-complying products, not OEM and aftermarket products since many aftermarket products upgrade or enhance OEM lights.
· If NHTSA can show scientific evidence of a glare problem, the agency should support practical solutions, such as enhanced mirrors, window tinting, special beam pattern for lamps mounted over a certain height, etc.
· NHTSA should work with lighting industry manufacturers to develop a consistent and street-enforceable means to distinguish compliant lamps from non-compliant lamps based on performance criteria, not design specifications.
SEMA encourages aftermarket compliance with existing NHTSA standards. The association provides detailed information on how members can comply with federal lighting standards through its website, magazine articles, and e-mail broadcasts.
To obtain a copy of NHTSA's request for comments go to
http://www.nhtsa.dot.gov/cars/rules/rulings/glare.html
If you would like to contact NHTSA directly with your written comments, the deadline is NOVEMBER 27, 2001.
Direct your comments to:
National Highway Traffic Safety Administration
Docket No. 01-8885;
Notice 01 Docket Management,
Room PL-401
400 Seventh Street, SW
Washington, D.C. 20590
Contact the SEMA Government Affairs Office with your thoughts.
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