New EU directives making scanning over MPE 'illegal'. Discuss

[norty303]

Cut from this thread
http://www.photonlexicon.com/forums/...right-strength

Posted by James Stewart

OK, I’ll answer briefly on this thread, as I don’t want to hijack what is an excellent topic about altering beam divergence. I suppose if this is something people want to speak about more, then it’s only fair to start a new thread.

The new European legislation comes from the EU Directive 2006/25/EC. And as the numbering scheme suggests, this has been simmering on the back burner since 2006. The full text can be downloaded from:

Physical Agents (Artificial Optical Radiation) Directive 2006/25/EC

http://eur-lex.europa.eu/lexuriserv/...n0038 0059.pdf

As with most of these types of document, it is a good cure for insomnia. ☺

The goal of the legislation is to provide a minimum level of safety to workers where harmful light sources may be used, in a way that is uniform across the EU. It is therefore up to each member state to implement its own set of rules that meet the requirements of the ‘Directive’. In the UK we are set to have this implemented with the new ‘Control of Artificial Optical Radiation at Work Regulations 2010’ which where published for consultation back in November 2009. Other countries will have their own equivalent regulations. And they may already be in force. France and Romania are two countries I know that have already implemented AORD.

You’ll see that the directive not only covers lasers, but also non-coherent light sources. Initially there were concerns how this would impact the theatre and performance industries which use a wide range of high brightness light sources. But the research so far is indicating that the limits are not going to pose any significant problem. And as bright as some of these other sources may ‘appear’, none come close to having the same power densities of even a modest laser beam.

Unfortunately ILDA does not ‘set’ the standard on MPE limits. An ILDA ‘recommendation’ is not an international safety standard. It never was. It was just a recommendation. ILDA has no regulatory authority to issue safety standards, for they are only a trade association. The MPE data is produced by an international scientific organisation called ICNIRP. It is the EU parliament that has decided upon these values as the legally binding limits.

Unfortunately ILDA have been aware of this legislation for a while. I mentioned it to their safety chairman and director following the Russian incident, but received a rather dismissive reply. (hence my quip in my earlier post referring to them as the ‘American’ rather then ‘International’ Laser Display Association)

Patrick Murphy was also here in the UK in September last year, talking about ILDA’s recommendation at a safety meeting where the EU directive was also spoken about in great detail. At the time I did point the potential problem with ILDA recommending to its membership in Europe the x10 MPE issue, and what it could mean it terms of liability. However, I’m sure they have their own plans on how they are going to advise members on staying within the law.

I’m actually not against the x10 MPE proposal itself, if it is used with reliable equipment and well thought out shows (e.g. no slow moving finger beams from multi-Watt lasers at close quarters). But my point was that people need to be a bit careful about how they approach this if they are not to be seen as irradiating people in excess of the new workplace exposure limits.

Sorry it turned out to not be so brief a response.

[Doc]

......and here's the document

http://www.photonlexicon.com/forums/...3&d=1269883352

[norty303]

Interestingly (and I'm only on page 4 of the directive so bear with me) the obligation seems to be on the 'employer' to risk assess levels. So if I'm working in a venue, it seems to be down to the manager to ensure levels are safe for their staff. Thats not to say they may not in turn ask for relevant paperwork as proof of a safe show in order that the manager can ensure they meet their obligation, but it does strike me that we as laserists only have specific obligation to any crew we may employ.

[JStewart]

There is probably no need to panic too much, the sky is not going to fall in over this new legislation. In fact in the UK at least, it adds very little to already implicit H&S legislation with things such as the Management of Health and Safety at Work Regs 1999 etc. A laser operator working to HSG95 guidelines, will have little to fear from the new regs. The difference is that there will soon be explicit requirements for optical radiation exposure risk assessments, training, and provision of information etc. (and by risk assessments, they mean more than “can we get a way with poking a f*!k-off Class 4 laser at people and hope it doesn’t get noticed”)

The new bit is that it sets in stone that MPEs shall not be exceeded.

I usually sit on the fence on most discussions, but after seeing and hearing a growing number of people quoting 10x MPE and 100x MPE, and the fact that ILDA is endorsing it, led me jump off fence, and bring it to people’s attention that saying they are exposing someone to more than the MPE, will not be a wise idea as of next month.

ILDA are aware of the new regs, and I hoped that they would be advising their members as such, but as far as I know, and from experience in speaking with laserists, ILDA have been quite mute on the subject.

People will most likely be able to carry on as normal with their displays. So really it’s just a warning that with the new legislation about to be implemented, unless you have a laser system that can ensure a reduced exposure time at higher irradiance levels, then stating that you’re 10x over applicable MPE is something to be cautious of.

James

[mccarrot]

But what about high power chinese DMX projectors without projection zones. Those projector are not able to set a projection zones above the audience. Will those projectors be forbidden in clubs?


In europe you are innocent until proofed different. Its very hard to proof a show was above MPE, so practically I don't think this rule will affect anyone scanning somewhat above MPE if its still relatively safe (like the 10MPE proposal) If no accidents happen, there is no claim, there is nothing to proof.

[White-Light]

James as I said in the other thread:

I've only glanced at it because I can't be bothered to read all of the bumph but as I read it (the 1st few lines anyway ), its a workplace directive to protect "workers" not a public display directive so presumably the duty only applies to protecting employees from the radiation, not the audience at large.

I can see ways of overcoming this: 1. Keep all employees outside of the scanning zone (not necessarily practical eg in the case of security staff), or 2. Issue employees with safety equipment so as to protect against the hazard when they enter the scanned zone eg. laser goggles and if necessary clothing that protects the skin.

PS sorry for the thread hijack but expanding beams for safety is kind of related. I do agree some seperation would be nice but its best done by a mod as then posts can be moved.

Doesn't this just apply to workers not the general public?

In which case can't it be got around by issuing safety equipment to employees who have to enter the audience zone when 10x MPE is running?

[Stoney3K]

Doesn't this just apply to workers not the general public?

In which case can't it be got around by issuing safety equipment to employees who have to enter the audience zone when 10x MPE is running?

I guess this is going to be the same as sound regulations: EU law requires that noise levels are below 85dB(A) at all times to ensure workers' health. Employers are required to provide adequate protection (e.g. earplugs).

So my guess is that venue operators will be issued some nice safety goggles and be done with it. If somebody in the audience is stupid enough to stand in 120dB of noise or a 10MPE laser show, it's not their responsibility.

[JStewart]

You are right, the legislation is only there to protect workers, and does not cover the public. In a typical venue though, there will be security staff, bar staff, and glass collectors all sharing the same area where the lasers may be in use.

In all probability if people were really only producing shows that exposed people to 10x the MPE, then someone would have to be quite unlucky to notice any damage to eyesight.

I think the issue is likely to come about as people are starting to use higher power lasers in the same way that lower power lasers have been used in the past. A 1W laser in a typical large nightclub, if the effects have been well thought out, (and no finger beams), can probably go through its life not causing noticeable damage to people’s eyesight (not that I’m condoning poking effects into people’s faces without a proper assessment though). But with some of the powers that people are starting to wave into people’s faces, the effect is likely to increase the risk of someone noticing an injury.

Using a 1mr 10W laser at 30ft would create an exposure level over 3000x the MPE for a quarter second exposure. But even for a single 1ms exposure, which is typical for a finger beam type effect, this would still be an impressive 800x the MPE. Of course, a real life finger beam is made up of several 1ms hits in quick succession on the same spot, especially if it is slow moving, which has an effect of increasing the amount the MPE is exceeded further.

You could argue that using a Beam Attenuation Map solves the problem, by reducing the power levels at the point of contact with people. But to do so means reducing the power down to around 20mW(!) in the attenuation zones. 10W going to 20mW, both in real life and on cam, would be distinguishable, when you see the fans sweep down.

As for the ‘burden of proof’, I don’t know about other EU member states, but in the UK under s.40 of the HASAWA, in health and safety law there is a reversal of the burden of proof. This means that it is not up to the prosecution to prove that something was unsafe. But instead the burden is on defendant to prove that the way they carried out their work was safe.

[QUAZAR]

Using a 1mr 10W laser at 30ft would create an exposure level over 3000x the MPE for a quarter second exposure.

If your club was that small, you have no business putting a 10W laser in there.
Conversely, if your venue is big enough to require 10 watts, you dont crowd scan the front row.

With careful control of the lighting, I have managed to perform exciting shows in venues holding 2500 people using a pair of 500mW DPSS units. I am not saying this is the ideal laser for venues that big, but it can be done.

As always, use the right tool for the job in hand.

[norty303]

As always, use the right tool for the job in hand.

Therein lies a problem.

People (non-specialist laser companies, doing sound/lighting as their main business) are now buying the biggest laser they can afford/lay their hands on, on the basis that they can cover the widest variety of shows with it.