Check the life left on your navigation lights

[Ike]

I suspect there is something else going on here with Aqua signal, and I think it may be a mistaken interpretation of a regulation that really has very little to do with navigation lights. I was working in the USCG office of Boating Safety when the USCG began requiring a certification by the manufacturers of nav lights, that the nav lights meet the standards in the COL regs. Prior to that Nav lights intended for recreational boats had to meet the standards, but there was no requirement for the manufacturer to certify that the lights met the standards. I do not remember any discussion dealing with a use by date or how long these LED lights would last. LEDs were becoming more common at that time. (stick with me here, it gets a little more complicated)

Also In the USCode and CFR Regulations there is a requirement that manufacturers of boats and associated equipment are required to recall and replace any equipment that does not meet the standards, for ten years. So, say your boat has a defective light, at say, five years, then the manufacturer would have to replace it.

The Colregs speak only to luminosity and range that the light can be seen. But I think Aqua Signal is concerned that if the light dims within the ten year period they would have to replace the light. So they came up with this mechanism that measures how many hours you used the light and a signal to tell you that. Obviously some other light manufacturers are doing something similar.

This is a way for them to say the light is not defective. You exceeded the life time of the light in hours. So they don't have to replace it if that falls within the 10 year requirement.

There is no requirement in the Col Regs or in the USCode or CFR to do this. And incandescent lights had a bad habit of working, until they didn't. There was no requirement that the manufacturer replace them if they didn't work. It was simply up to the boat owner. This is because the owner is also required by law to have lights that meet the standard. The onus only falls on the "Boat manufacturer", not the light manufacturer, if the boat manufacturer installed the lights. If you, the boat owner installed the lights, it's on you. I think Aqua Signal is worried that the requirement would fall on them which is, I believe, is a mis-interpretation of the regulations. However, I could be wrong, it's been 20 years since I retired and laws change, and policy changes. But if anyone knows different please let me know. I will contact my colleagues in the Office of Boating Safety and see if my interpretation is right or not.

[znep]

Originally Posted by Ike

There is no requirement in the Col Regs or in the USCode or CFR to do this. And incandescent lights had a bad habit of working, until they didn't. There was no requirement that the manufacturer replace them if they didn't work. It was simply up to the boat owner. This is because the owner is also required by law to have lights that meet the standard. The onus only falls on the "Boat manufacturer", not the light manufacturer, if the boat manufacturer installed the lights. If you, the boat owner installed the lights, it's on you. I think Aqua Signal is worried that the requirement would fall on them which is, I believe, is a mis-interpretation of the regulations..

See my earlier post where I link to the EN 14744 European regulation they explicitly mention in the manual.

[Ike]

That is fine in the EU. But it doesn't apply in the USA.

[nfbr]

Any suggestions for a daylight sensor to extend the life?
We just leave on 24/7

[Statistical]

Originally Posted by Ike

That is fine in the EU. But it doesn't apply in the USA.

The recreational small boating market is so small nobody is going to make EU specific lights. If they sell them in the EU they wil comply with EU regs and the rest of the world gets the same thing.

Honestly I don't think this is as terrible as people make it out to be. LED will continually lose brightness over usage hours. Yes your nav lights will "turn on" but the distance they can be seen will decrease over time.

This is the worst kind of failure mode in that it is "fail silently". Incadescent lights might burn out that that provides an obvious feedback. I turned on the lights but they didn't turn on. With LED it is I turned on the lights but they are dimmer eventually they could be so dim as to be as useless as a dead bulb BUT they still do turn on.

[donradcliffe]

The horror of it all. I am going to be run down by a large ship because they didn't see my lights until I was 1.5 miles away instead of 2 miles. In reality, they never looked for my lights because they saw my AIS transponder 10 miles away. Lawyers are standing by.

[rslifkin]

Originally Posted by Statistical

The recreational small boating market is so small nobody is going to make EU specific lights. If they sell them in the EU they wil comply with EU regs and the rest of the world gets the same thing.

Honestly I don't think this is as terrible as people make it out to be. LED will continually lose brightness over usage hours. Yes your nav lights will "turn on" but the distance they can be seen will decrease over time.

This is the worst kind of failure mode in that it is "fail silently". Incadescent lights might burn out that that provides an obvious feedback. I turned on the lights but they didn't turn on. With LED it is I turned on the lights but they are dimmer eventually they could be so dim as to be as useless as a dead bulb BUT they still do turn on.

I like the idea of a warning, I just don't like the idea that a light cuts off at a point. And warning by flashing the light isn't a good way to do it in my mind. I'd rather see an alternative. Even a delay in turn on or something as that doesn't risk confusing another boat like flashing would.

[noelex 77]

Originally Posted by Statistical

Honestly I don't think this is as terrible as people make it out to be. LED will continually lose brightness over usage hours. Yes your nav lights will "turn on" but the distance they can be seen will decrease over time.

Not my anchor light. It deliberately turned off due to the "suicide" program Aqua Signal have decided to incorporate into the circuit.

[noelex 77]

Originally Posted by nfbr

Any suggestions for a daylight sensor to extend the life?
We just leave on 24/7

Many solar controllers have a "load" output that will do this. Since the anchor light has a low power draw I did not think it was worth adding this complexity and additional point of failure, but given the cost and hassle of replacing the light after only six years I think this was a mistake.

We only used this light at night rather than leaving it on 24 hrs a day so the extra life would not have been great, but climbing the mast every six years and paying $200 to Aqua Signal for a planned failure is not ideal, so any extra life would have been worthwhile.

[Statistical]

Originally Posted by donradcliffe

The horror of it all. I am going to be run down by a large ship because they didn't see my lights until I was 1.5 miles away instead of 2 miles. In reality, they never looked for my lights because they saw my AIS transponder 10 miles away. Lawyers are standing by.

So you turn off our nav lights and run dark with AIS only? I assume not. Keep in mind LED can get a lot dimmer than just 25% reduction. What about when it can't be seen beyond 1/3rd nm vs 2 nm. The output will just continually decay with time.

[wholybee]

Originally Posted by Ike

I suspect there is something else going on here with Aqua signal, and I think it may be a mistaken interpretation of a regulation that really has very little to do with navigation lights. I was working in the USCG office of Boating Safety when the USCG began requiring a certification by the manufacturers of nav lights, that the nav lights meet the standards in the COL regs. Prior to that Nav lights intended for recreational boats had to meet the standards, but there was no requirement for the manufacturer to certify that the lights met the standards. I do not remember any discussion dealing with a use by date or how long these LED lights would last. LEDs were becoming more common at that time. (stick with me here, it gets a little more complicated)

Also In the USCode and CFR Regulations there is a requirement that manufacturers of boats and associated equipment are required to recall and replace any equipment that does not meet the standards, for ten years. So, say your boat has a defective light, at say, five years, then the manufacturer would have to replace it.

The Colregs speak only to luminosity and range that the light can be seen. But I think Aqua Signal is concerned that if the light dims within the ten year period they would have to replace the light. So they came up with this mechanism that measures how many hours you used the light and a signal to tell you that. Obviously some other light manufacturers are doing something similar.

This is a way for them to say the light is not defective. You exceeded the life time of the light in hours. So they don't have to replace it if that falls within the 10 year requirement.

There is no requirement in the Col Regs or in the USCode or CFR to do this. And incandescent lights had a bad habit of working, until they didn't. There was no requirement that the manufacturer replace them if they didn't work. It was simply up to the boat owner. This is because the owner is also required by law to have lights that meet the standard. The onus only falls on the "Boat manufacturer", not the light manufacturer, if the boat manufacturer installed the lights. If you, the boat owner installed the lights, it's on you. I think Aqua Signal is worried that the requirement would fall on them which is, I believe, is a mis-interpretation of the regulations. However, I could be wrong, it's been 20 years since I retired and laws change, and policy changes. But if anyone knows different please let me know. I will contact my colleagues in the Office of Boating Safety and see if my interpretation is right or not.

That is quite interesting. My aqua signal navigation lights, after 5 years, now have plastic lenses that are UV damaged, faded, and no longer illuminate the same color or distance as when new. By your guess, would they need to be replaced under CFR? Because even with a new bulb, it isn't meeting the standard. (I suppose, I haven't the equipment to test it).

[Ike]

You could try filing a consumer complaint with the Coast Guard.

https://uscgboating.org/php-contact-...ect-report.php

[nfbr]

I was thinking of hanging a lower anchor light under the boom, this might be the trigger to do that job.

[Dockhead]

Originally Posted by rslifkin

Thinking about it, it seems odd to me that light manufacturers are so worried about the LEDs degrading to less than their specified output, yet so many nav lights (particularly older incandescent ones) have lenses that degrade significantly and are often ignored even when that's likely a far larger impediment to proper output than a slight degradation in LED brightness. On the lens degradation thing, I'm starting to get the very slightest yellowing of the lens on my Signal Mate masthead / anchor light unit. The Hella NaviLED Pro side and stern lights are still crystal clear and look as good as the day they were installed (4 years ago for all of the lights).

In particular the 10,000 hour limit for the Hellas seems awfully short. Particularly if they're used on a small commercial or government/police where I often see boats operated with nav lights on all the time, even in broad daylight. I can see some of those applications using up a set of these lights withinin a few years.

I'm still of the opinion that having a nav light flash as a status indication is somewhere between stupid and dangerous regardless of the intended purpose.

I think it's actually great progress that we are notified when the LEDs approach the end of their ability to meet specs.


I agree with Noelex however that it's wrong to disable the light.


This is a huge leap forward from the days when people let their lenses go to wrack and ruin without ever thinking about. You still see those all over the place.

[noelex 77]

Originally Posted by nfbr

I was thinking of hanging a lower anchor light under the boom, this might be the trigger to do that job.

The standard marine anchor light at the top of the mast is an ideal way to ensure you are displaying the legally required lighting. This is important in the event of a collision.

I think it is sensible to also use lower lights, preferably ones that illuminate the mast or superstructure.

The combination of light at the top of the mast and lower lights provides the best chance for being seen in adverse situations such as when you have a background of bright shore lights or heavy rain. The light at the top of the mast can usually be seen at a greater distance, but the lower lights makes it easier for an approaching boat to judge exactly how far away you are.

The lower lights do not have to be marine certified anchor lights. The collision regulations encourage (or mandate for large vessels) boats to display additional "deck lights" of any type providing they cannot be confused with another navigation light.

Multiple lights also provide a backup in case the marine anchor light fails. With modern LED lights I had judged failure unlikely, but I had not considered that any manufacturer would program their anchor light to deliberately fail completely.