Pretty much. Again, it's more stringent for a manufacturer whose purpose is to build them for sale. If you are attempting to get a variance on your own projector, that you have no intention of selling, renting etc., there are more areas where that list comes in to play. And a lot of areas where they are reported to be more lenient. In many cases you'd be protecting yourself from yourself and you've already got intimate knowledge of the projector. There are some that are still necessary such as writing an instruction manual, which doesn't make much sense to me but, nonetheless it does to CDRH. I'm going through the process right now and am just finishing diagrams, paperwork, writing a manual, and so forth for a home build and we'll see what happens. I don't have the electrical expertise I should probably have to describe circuits and may be asking for assistance with that.
I still think the real emphasis should be on the level of competency of the operator more than the box itself. You study, you take an exam and have a license of some sort from CDRH allowing you to purchase and use a projector for public, compensated display. 3 meters up, with a physical beam block in place, the emission from my CR-Tec chi-jectors or, Kvant Spectrums is no more or less safe than my Luminance RGB, a X-Laser Skywriter, an LSDI Compact 2, or whatever.
But, the system we have is the system we have. I'm still learning more about playing in it.