Passing this testing is not as easy as some make it sound.
The main lab that tests these lights to USCG specifications fails MANY of them. I looked into building an LED anchor light and part of the costing analysis was to talk with the lab that does the USCG standards testing.
The testing is not that expensive when you consider what a worthy production run would be. Testing for a single anchor light was under $1000.00, about $925.00 IIRC.
This means that for a production run of 1000 lights it is adding less than $1.00 per light to sell a USCG certified navigation light. Outrageous? Not at all, especially to know your product meets the legal criteria for a navigation light.
If you submit a complete package of lights there is also a major discount on this testing. They will also stop testing at the first sign of failure, which just happens to be color when they are testing LED fixtures.. If it passes color, and many anchor lights fail because they are too blue, they stop and charge you only for that portion.
Remember that all these failures are lights built by companies who feel strongly enough they can pass the requirements to send in their fixtures and pay for the testing. They also test LED products for intensity over time. They have tested numerous products that meet the standards when first turned on but after a few hours they no longer pass when the intensity has fallen off.
You can now buy USCG certified navigation fixtures for not much more than a bulb only, so why not stick with something that keeps you known to be legal? LED navigation lights have come way down in price.
While I fully agree that ANY light is better than no light at all some of these lights I see out there can be outright dangerous. Pinks, blues, dim, cut off angles poor etc. etc.. Last summer I was working on a customers boat and noticed a "festoon" style LED bulb he had inserted into an Aquasignal Series 25 navigation light fixture posing a dangerous situation. Perhaps through vibration, or maybe he installed it that way, it had rotated around and was facing backwards. The incandescent originally designed for this fixture emits light 360 degrees so if it rotates there is no change in how the nav-light performs. These light fixtures have no reflector and the festoon was single sided.. It was not even facing the lens... Doh'....
Of course I do have a vested interest in this having had one of my best friends father killed in a boating accident where navigation lights were involved. I do not wish this on ANYONE. My friend and her family went though days of forensics testimony on the navigation light portion of the investigation & trial, not fun.....
When one of you guys has someone you know very well die in a night time boating accident I would be interested in talking with you after that incident about your views on navigation lights...
BTW this just happened last week, at night, here on Casco Bay. The USCG investigation is well under way. They hit so hard it literally blew the bow nav-light clean off the boat..
Hamilton Marine one of our local chandleries feels so strongly about not being involved in the liability chain they have this sign hanging right next to the LED lights where you can't miss it:
And this is the back of a package of an IMTRA LED bulb.
Seems no one wants to accept the potential liability for installing aftermarket LED's not even the people making them, or the people selling them. That says a lot to me....
I guess that; "The operator of vessel assumes all liability when using this product as a replacement for the original approved light source."
means it is all on you to decide if using aftermarket LED's in existing fixtures is a worth while venture.
For me it is not, but your boat, your choice....