My personal opinion -- not ILDA's opinion -- is that there is not much demonstrated need for a laser license or operator variance.
This is based on the experience of 30 years of audience scanning overseas, where the number of injuries or problems appears to be negligible compared with the number of persons exposed.
This is also based on US "illegal" laser operators who don't seem to be blinding persons despite the MANY audience scanning shows we know that go on in the U.S.
My personal suggestion is to leave CDRH regulations the way they are. Only instead of having to file in advance and saying "yes, here are our diagrams of how the shows is done", simply say that all U.S. laser shows must follow CDRH regulations. If a show is found to be not following regulations, then the person would be fined or jailed as is normally done now. (E.g., nothing will happen more than a slap on the wrist...)
All this does is level the playing field. Right now, conscientious laserists are jumping through unnecessary hoops to file show variance paperwork. This puts them at a disadvantage relative to the many laser operators who do "illegal", non-varianced shows (or varianced shows that exceed the variance restrictions).
I think the current show variance system is largely unnecessary, relative to more important public health efforts that the FDA needs to be doing. Leave the regs the same (3 meter rule, etc.) but simply say "laserists must follow this" and if an inspection or a complaint shows that a laserist is not following them, then penalize the person the exact same way as if they had filed and then violated a variance.
Again, this is my personal suggestion and views, and does not reflect anything related to ILDA. Dan Goldsmith and the new ILDA Regulatory Committee will be working on ILDA's official policy as their time permits.
-- Patrick