Light safety darkens supplier mood

Jan. 1, 2020
The feds are in the early stages of considering major changes to the automobile lighting safety standard.
The feds are in the early stages of considering major changes to the automobile lighting safety standard. Some of those prospective changes have already sparked intense controversy, including concern about the effect of a shift to a "performance-based" lighting standard on aftermarket products.

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Federal Motor Vehicle Safety Standard (FMVSS) No. 108 “Lamps, reflective devices,and associated equipment” has been in place, essentially unchanged, for three decades. The current standard primarily treats a headlamp as a separate piece of safety equipment that is installed on a motor vehicle with various height and width restrictions. That standard essentially prohibits manufacturers from using new advanced lighting sources, generally grouped under the heading of adaptive front-lighting systems (AFSs). AFSs incorporate advanced sensing (object distance, object angle, road lighting and object type) and lighting technologies to enable dynamic adaptation of the driving beam pattern according to prevailing weather, roadway geometry and conditions, oncoming and preceding traffic, vehicle speed, and/or, if available, GPS Signal Information. Moreover, the standard only deals with how the lighting source works, not how it, in conjunction with other lights, illuminates areas around the car.

The NHTSA is thinking of a new standard that would translate the angular photometric requirements for each lamp in the current standard into areas in three-dimensional space around the vehicle. These areas around the vehicle are then easily correlated to various objects on the roadway, such as oncoming driver-eye locations and overhead signs positions. This would be considered a "whole vehicle-based performance" standard.

The NHTSA's impetus for considering a new standard is a technical report from the University of Michigan Transportation Research Institute, which conferred with the Society of Automotive Engineers' Performance-Based Lighting Task Force.

The Michigan report raised hackles on the backs of necks of aftermarket lighting suppliers.

"We have identified a number of concerns with the approach to replacement equipment in the technical report, and we recommend that further study of the role of replacement equipment in a whole-vehicle testing approach is necessary," says Bart P. Terburg, Automotive Regulations Manager, OSRAM SYLVANIA Products Inc., Automotive Lighting. "We expect that a proposal for a whole-vehicle testing approach that would include abandoning the principle of standardized replaceable headlamp light sources as vehicle lighting safety equipment in FMVSS 108 could meet with significant opposition from light source manufacturers."

Terburg notes, too, that a higher level of integration of replacement lighting components, as suggested in the technical report, does not a priori present a higher potential for improving motor vehicle safety.

The Alliance of Automobile Manufacturers is also lukewarm about a shift to a performance-based system, but enthusiastic about incorporating AFSs into new cars. Not only does the Alliance of Automobile Manufacturers, Inc. (AAM) believe the NHTSA can move forward on AFSs, absent a shift to a "whole-vehicle-based" system, it questions whether the benefits described in the Michigan report for whole vehicle testing outweigh the significant disadvantages. Scott Schmidt, Senior Director, Safety & Regulatory Affairs, AAM, says, "The Alliance strongly urges NHTSA to clarify FMVSS 108 requirements to facilitate the introduction of full AFS to the U.S. market."

But he contends that vehicle-based performance testing is unnecessary to evaluate the performance of full AFSs, and in fact, it could make such evaluation more difficult and expensive. Lamps are generally easier to test at the component level – especially in earlier phases of design and development when vehicle prototypes are unavailable. Vehicle-based performance testing of associated camera and sensor systems used in conjunction with full AFSs is also problematic, because these cameras and sensors are not lighting components and often support other vehicle features, as well. Because of this, manufacturers are reluctant to have sensor performance specifications imposed as part of a vehicle-based test that is focused solely on lighting performance.

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