Ban Blinding Headlights! Soft Lights Foundation Submission to NHTSA

Dear Supporters,

The Soft Lights Foundation submitted the following public comment on NHTSA's Request for Comment on the proposed negotiated rulemaking committee for vehicle lighting. (https://www.regulations.gov/document/NHTSA-2026-1981-0001)

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NHTSA proposes 18 members for the Committee, with membership heavily weighted towards industry.  NHTSA specifically states that anyone who feels that the membership categories don't fully represent their interests, should submit a comment. 

The Soft Lights Foundation proposes the following committee members, one representative each:

1. NHTSA.
2. U.S. Food and Drug Administration (See 21 U.S.C. 360ii).
3. Automaker (e.g. Ford, GM, or Tesla).
4. Elderly organization (e.g. American Association of Retired Persons).
5. Eye organization (e.g. American Academy of Ophthalmology).
6. Medical organization (e.g. American Medical Association).
7. Auto organization (e.g. American Automobile Association).
8. Vehicle lighting manufacturer (e.g. Osram or Sylvania).
9. Automotive research facility (e.g. University of Nebraska Lincoln or Mount Sinai Light and Health Research Center).
10. Standards setting body (e.g. IEEE or SAE).
11. Autism organization (e.g. Autism Society of America).
12. National Eye Institute.
13. Optical engineering association (e.g. Optica or SPIE).
14. Transport Canada.
15. Insurance Institute for Highway Safety.
16. Bicyclist organization (e.g. League of American Bicyclists).
17. Trucking association (e.g. American Trucking Associations or Owner or Operator Independent Drivers Association).
18. Consumer Reports.
19. U.S. Access Board.
20. U.S. Occupational Safety and Health Administration.
21. Epilepsy organization (e.g. Epilepsy Foundation).

We also recommend that the following topics be addressed by the committee.

1. Glare.
2. Restrictions on spectral power distribution, including blue wavelength light.
3. Overall limits on intensity, including both luminous intensity and luminance.
4. Restrictions and minimum requirements for source size.
5. Headlamps, Daytime Running Lamps, turn signals, brake lights, tail lights, and restrictions on all lighting parameters.
6. Upper and lower beam photometry.
7. Standardized mounting height for headlamps.
8. Eliminating the 0.5 degree testing loophole.
9. Enforcement of federal safety regulations under FMVSS-108.
10. Explicit statement of NHTSA's steady burning position for auxiliary warning lamps.
11. Photobiological, neurological, hormonal, and psychological safety.
12. Non-visual systems such as infrared and LiDAR, and restrictions on electromagnetic radiation.
13. Adaptive Driving Beam, including the comfort and psychological impacts.
14. Harmonization with Canadian and International standards.
15. Restrictions on flicker and Pulse Width Modulation for neurological safety.
16. Impacts of speed, hills, bumps, corners, and turns on glare.
17. Comparison of lighting technologies against the sealed beam halogen headlamp in terms of cost, comfort, physical safety, eye safety, glare, and other parameters.
18. Replacement cost for headlamps.
19. Address regulatory petitions submitted by the Soft Lights Foundation to NHTSA, including the petitions to set an overall maximum on luminous intensity and limit on CCT.
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NHTSA needs to hear from you.  You may use these comments as a template, or create your own.  NHTSA wants to know who should be on this committee.  All auto industry representatives?  Or should the committee also include people representing our interests?  Let NHTSA know.  (https://www.regulations.gov/document/NHTSA-2026-1981-0001)

Sincerely,

Mark Baker
President
Soft Lights Foundation
www.softlights.org
mbaker@softlights.org
X: @softlights_org
Bluesky: @softlights-org.bsky.social