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Thread: Reporting Illegal Lasers/Laser shows

  1. #71
    Join Date
    Aug 2013
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    Houston
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    "(6) Labels for noninterlocked protective housings. For each laser product, labels shall be provided for each portion of the protective housing which has no safety interlock and which is designed to be displaced or removed during operation, maintenance, or service, and thereby could permit human access to laser or collateral radiation in excess of the limits of Class I and table VI. Such labels shall be visible on the protective housing prior to displacement or removal of such portion of the protective housing and visible on the product in close proximity to the opening created by removal or displacement of such portion of the protective housing, and shall include the wording:

    (i) "CAUTION--Laser radiation when open. DO NOT STARE INTO BEAM." for Class II accessible laser radiation.

    (ii) "CAUTION--Laser radiation when open. DO NOT STARE INTO BEAM OR VIEW DIRECTLY WITH OPTICAL INSTRUMENTS." for Class IIIa accessible laser radiation with an irradiance less than or equal to 2.5*10-3 W cm-2.

    (iii) "DANGER--Laser radiation when open. AVOID DIRECT EYE EXPOSURE." for Class IIIa accessible laser radiation with an irradiance greater than 2.5*10-3 W cm-2.

    (iv) "DANGER--Laser radiation when open. AVOID DIRECT EXPOSURE TO BEAM." for Class IIIb accessible laser radiation.

    (v) "DANGER--Laser radiation when open. AVOID EYE OR SKIN EXPOSURE TO DIRECT OR SCATTERED RADIATION." for Class IV accessible laser radiation.

    (vi) "CAUTION--Hazardous electromagnetic radiation when open." for collateral radiation in excess of the accessible emission limits in table VI, item 1 of paragraph (d) of this section.

    (vii) "CAUTION--Hazardous x-rays when open." for collateral radiation in excess of the accessible emission limits in table VI, item 2 of paragraph (d) of this section."
    "This is not "work". It's a disease, addiction and passion. Only slightly cheaper than cocaine, but similar effects."
    -dnar

  2. #72
    Join Date
    Jan 2006
    Location
    Charleston, SC
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    2,147,489,446

    Smile

    If you were going to argue the point that customer access to the case was limited by the case screws even though they are standard Phillips screws, then your product report would need to say something like "Access to the case requires the use of tools, and this is one of the activities that is expressly forbidden in the owner's manual. No tools are provided with the projector, and there are warning labels on the case informing the user that no tools should be used on the case and that they may be exposed to dangerous radiation if they ignore the warnings and open the case".

    Personally, I think this is a stupid way to write the product report. It opens you up to a lot more scrutiny while offering little if any real additional safety. It's far better to simply ignore the type of screws altogether and just focus on the owner's manual, your warning labels, and your QA/QC procedures that ensure the labels are in place. Or, if you really want to be doubly-safe, go ahead and use safety screws that actually do require a "special tool".

    The problem with saying that you use safety screws, of course, is that now you absolutely must use those screws on every plate that can be removed to access the laser deck. If you run out of them, you can't certify any more projectors until you get more. In my opinion they are more of a pain in the ass than they are worth.

    EDIT: To address JD3's post (which came in just before mine), I would like to refer to my post above.

    Note that 21 CFR 1040.10 (f) (1) requires a housing to protect the user from access to light levels in excess of class 1. You meet this by stating that your housing is made of metal, and is sturdy enough to block all light (with the exception of the aperture, which has it's own exemption and label requirements that are stated later).

    (2) requires interlocks for any portion of the housing that is "designed to be opened during operation or maintenance". The way you get around this is by stating clearly that none of the operational or maintenance activities require access to the inside of the case. Thus all of the sub-categories that deal with case interlocks do not apply.

    (g) (6) requires non-interlocked housing labels for any removable panel that does not have an interlock, but unlike section (f), this applies for panels that are required to be removed for operation, maintenance, AND SERVICE. Since service has to include things like tuning the scanners, adjusting the alignment, etc, you need to have the labels installed if you don't interlock your housing.

    Adam
    Last edited by buffo; 04-11-2015 at 16:17.

  3. #73
    Join Date
    Nov 2007
    Location
    SoCal / San Salvador / NY
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    4,018

    Thumbs up

    Quote Originally Posted by buffo View Post
    Send the new picture in as further evidence.
    +1, and.. Better still, if you can send the FDA the *link* from their site (and, sure.. Grab a 'Dated print-screen shot', in-case they 'scrub it'.. that's far more damning, then if you just email them "a pic", because then they have 'posted their own warrant'...

    ..That's what hung 'Epic Fail', there.. DB seemed to proudly leave up the vids on his site showing the aud-scanning he does - stating - "PHX, AZ", Date, etc, thereby blowing-away his initial retort to them (when they called him out, previously) - remember the first-vid we all were like O_O over? He claimed '..Oh, ya, that was in some other country', and they had no choice but to 'buy it' / take his word.. Unless / until, they find a 'smoking gun', otherwise... They Did..

    ....and armed only with his trusty 21 Zorgawatt KTiOPO4...

  4. #74
    Join Date
    Jun 2007
    Location
    Phoenix AZ
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    349

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    " 15 characters"
    Last edited by Laser Wizardry; 11-13-2015 at 12:36.

  5. #75
    Join Date
    Apr 2006
    Location
    Miami, FL
    Posts
    3,590

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    Quote Originally Posted by Laser Wizardry View Post
    I had a run in with a former state inspector that claimed my hex head machine bolts did not need a special enough tool, and I successfully countered that by pointing out that in some industries, a star or a torx is just as common if not more common than an allen wrench.
    that's the problem with such vague language....

    to me a special tool is any tool that is missing at the precise moment I need it! lol

  6. #76
    Join Date
    Jan 2006
    Location
    Charleston, SC
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    2,147,489,446

    Cool

    Quote Originally Posted by flecom View Post
    to me a special tool is any tool that is missing at the precise moment I need it! lol
    With my luck, that would be every tool ever made!

    I can't tell you the number of times I've been working on something and suddenly lost track of the exact tool I need. What's worse is when it was just in my hand 30 seconds previously, but now I can't find the damned thing to save my life! (I usually find it under a piece of paper that has notes on what I'm working on. That, or else I got up to get a drink with the tool still in my hand and absent-mindedly set it on the counter in the kitchen.)

    It doesn't help matters that my eyesight is getting worse. If I'm not searching for a tool, I'm looking for my damned reading glasses!

    Sigh - getting old really sucks.

    Adam

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