Since September 2022, ILDA has been working on a standard for "Category A Laser Shows." This is also referred to as a "Cat A" show.
The proposed standard describes requirements for a laser show that ILDA considers to be generally recognized as safe under the conditions of its intended use.
The chance of injury (hazardous effect or adverse biological change), from a laser show performed according to the Cat A requirements, is considered by ILDA to be vanishingly small.
Click the green button to download the most current public draft. At the bottom of the page is a blue button; click it to see the list of changes for earlier versions.
A Cat A Laser Show incorporates regulatory requirements from U.S. FDA, and standards practices from ANSI Z136. It includes these important requirements:
• 6 watts maximum (peak) power from any one laser beam [Note: the 6 watt figure is temporary; an exact power level is still being discussed]
• No unterminated beams
• All beam termination points must be visible to the Laser Operator, assisted if necessary by Laser Spotters
• Use FDA-certified laser projectors in the U.S.
• No human exposure to light from Class 3B or 4 lasers
• Continuous monitoring of all beam paths, locations and termination points during laser emission by a trained Laser Operator, assisted if necessary by Laser Spotters so there are no unmonitored paths/locations/termination points
• The Laser Operator has an e-stop or equivalent method to immediately terminate emission in case of actual or imminent laser safety hazard
• Secure mounting of laser projectors, and masking of laser emissions to restrict them to intended, safe areas
• Prevent damage to materials
• Anticipate problems in advance of the show, and plan for mitigation procedures
• Keep a log of all laser usage, and any problems/issues that may arise
• Training is required for Laser Safety Officers and Laser Operators; training and/or instruction is required for Laser Spotters and Laser Personnel
• The person responsible for the laser's safe operation -- usually this is the Laser Safety Officer -- shall take an in-person or live online laser safety course, and shall pass a test prior to operating an ILDA Cat A Laser Show
If a show conforms to the ILDA Category A Laser Show standard, ILDA will not object to the show, regardless of whether it meets governmental reporting requirements such as having a variance.
2) Persons doing laser shows should still file for any government-required reporting such as having a variance. Just because ILDA is OK with a Cat A Laser Show, does not mean that U.S. FDA, state or local officials would not investigate and prosecute any reporting violations.
3) ILDA urges ANSI Z136.10, IEC, FDA and others to consider adopting the requirements and recommendations of the Cat A Laser Show Standard. Specifically, to relax government review and pre-approval (e.g. variances, annual reports, etc.) if a show meets the Cat A Laser Show requirements.
The third point, about eventual FDA adoption, is important.
An FDA variance is permission to vary from the rules. The variance form currently includes simple requirements (i.e., restricted beam distances and locations, operator control) as standard items. ILDA believes that shows meeting those simple requirements should not be required to obtain permission in advance. Only shows with special features such as audience scanning or unsupervised laser use should require further FDA review, and advance permission.
ILDA hopes that FDA regulations can eventually be modified, perhaps via a Laser Notice, to state that laser shows meeting specific requirements such as those in Cat A Laser Show Standard, do not need to file with FDA in advance. (Or, perhaps the laser show operators would need to file once with FDA, the way that Part 107 drone operators file once with FAA but then do not need to file separately each time their drone has different flight paths.)
Of course, if a person were to violate the Cat A Laser Show requirements, FDA would retain their authority to investigate and penalize them.
The Cat A standard states that Cat A shows must be designed, or the design must be supervised, by a person with Laser Safety Officer training AND that the training shall include coverage of the Cat A requirements.
This means that even if a "regular" Laser Safety Officer designs or supervises a Cat A show, it is not officially Cat A unless the LSO also was trained on the Cat A requirements.
LIST OF CAT A OPERATORS AND LSOs
In May 2023, ILDA added Category A-specific information to our Laser Operator and Laser Safety Officer course material.
A list of everyone who has passed ILDA courses, as well as courses taught by Roberta McHatton, is on this page. Those persons who received Category A training are listed in green.
As of mid-June 2023, Cat A LSOs are only found in the list of ILDA Laser Safety Officers. We do not have any Cat A Laser Operators at this time, and Roberta has not yet added Cat A material to her LSO course.
An analogy can be made between laser show regulation, and how drivers and motor vehicles are regulated.
A person can drive a standard automobile or light truck after certified training (driver's license) and if they are using a properly registered vehicle. They do not have to file with the U.S. Department of Transportation 30 days before going for a drive. They do not have to file an annual report with DOT. If there are traffic violations, these can be dealt with using punishments including fines, license revocation, and jail.
On the other hand, persons who drive larger, more hazardous vehicles like semi-trailers are subject to much more regulation, including limitations on how long they can drive each day and week, and keeping logs of their driving time.
ILDA Category A Laser Shows are somewhat analogous to standard automobile operation. They would not need pre-approval, while other more powerful and/or complex laser shows would still require prior FDA review via the variance process.
Incidentally, the analogy breaks down when it comes to adverse consequences. ILDA's goal is zero injuries from shows that follow all the Cat A requirements. We believe this is quite achievable.
The notes below contain the changes in the first public version, 7b, and in subsequent versions.
The draft document contains all version changes since the first version (3.0) that was submitted to ILDA's Board of Directors. There is a list of changes — the same as those below — at the very end of the draft document.
Changed the name from "ILDA Standard Basic Laser Show" to "ILDA Category A Laser Show." A commenter had pointed out that "Standard Basic" was clunky, and that short and simple names work well for other standards such as MIDI and DMX. The ILDA Board discussed options and preferred "Category A" over other suggestions such as "Type A", "Type 1" or initialisms like "BLS - Basic Laser Show." The Board and others also felt that letters should be used, to avoid confusion with the number used for laser classes. Finally, beginning with "A" also gives room for future related standards to be called "Category B", "Category C", etc.
Additional changes: Added a footnote about a claim of injuries in a September 2022 laser show in Kolhapur, India. Added a footnote discussing the difference between "masking" and "attenuation." Added a paragraph to the LSO definition making it clear that in this document, the LSO "is the person who designs, produces, supervises or otherwise is in charge of the overall laser safety aspects of a Cat A Laser Show."
Added a note that the 6 watt limitation is still under discussion; a value from 5 to 10 watts is likely to be the final wattage. Changed references to areas where aircraft could "safely land" to "safely fly or land." Strengthened the prohibition against laser light being on a person (previously it stated no laser light on any Laser Personnel's face or in their eyes). A note was also added to clarify and explain this prohibition. Strengthened the prohibition against mounting lasers on a moving structure (was previously a note; now is a "shall not" prohibition). Changed the list of training topics from a "should" to a "shall" to ensure the items will be presented. Clarified the requirements for the person who designs, produces, supervises or otherwise is in charge of the overall laser safety aspects of a Cat A Laser Show. Added a list of advantages for FDA, if they were to require video recording of shows.
In a potentially significant change, added language about refresher courses for persons who previously had LSO training that did not include information about the Cat A requirements and standard. The new language will help clients, regulators and others to identify LSOs who have been formally trained on the Cat A standard. Reviewers of this document should look over this section (currently Section 5.3.6) and provide any input they might have regarding this language and section.
Finally, fixed minor wording changes. Substituted the word "stop" for "terminate" in any usage where the beam emissions are made to cease by human action. This is because the standard also uses "terminate" to mean beams that end on a surface so they do not travel further. It was felt that using "terminate" for two very different concepts could be potentially confusing. Also, changed references about "potential hazards" to "imminent hazards" when discussing Operators and Spotters taking action upon seeing such hazards.
Colored the words "shall" and "should" to help them stand out as items that must be done, or items that are suggested recommendations.
Added info about using lowest practical power levels and extra caution during setup and alignment. Added two notes to clarify that the 6W limitation does not mean that Class 4 lasers up to 6 watts are safe. Set notes in a smaller type size to indicate they are subsidiary to the main text. Colored the Appendix headings so it is easier to distinguish the Appendix from the main Standards requirements sections. Added footers so a reader can always know what section (chapter) they are in.
Minor wording/formatting changes and boldfacing some ideas for emphasis. Added a cover page and a green laser "splat" logo. Removed the discussion of driver's license ages in the U.S., which was there to support setting the minimum age of a Laser Operator at 17. Added " venue owners and those in charge of an event" to the list of persons with authority to stop a laser show. Added language to the section on terminated outdoor shows, stating that if in doubt about termination, do not do a Cat A show or treat it as a regular non-Cat A show and consult the aviation authority. Added language to the section about 2.5 meter separation on a balcony, to more precisely describe how the 2.5 meters is measured. Clarified beam aiming at a moving panel, so that if a beam misses the panel it must not violate the distancing requirements of this Standard. Switched the listing of access restriction and warning signs so access restriction comes first and is stated to be preferred over warning signs. Strengthened the requirement for a general purpose LSO course to cover laser show safety topics in sufficient depth. Strengthened the requirement that laser safety course tests cover both factual and applied knowledge (changed from "should" to "shall").
In the introduction, specified that the Standard only applies to conventional laser shows and devices, not to laser-derived lighting sources. Added a note about the length of the document, noting that the main section is only about 12 pages. Removed "indoor and outdoor arenas" from the list of potential Cat A locations since such arenas may require power over the Cat A limit. Removed the word "peak" from discussions of the maximum power, to avoid confusion with "peak power" as used with pulsed lasers. Reworded the third paragraph under "Maximum Power" to avoid a confusing double-negative. Removed two unnecessarily redundant notes about maximum power. Moved a recommendation about warning signs that was in the main body; instead it is now a note. Added an option for remote video monitoring for relatively small, specific laser areas. Explicitly added the venue and event operator to those authorities having jurisdiction within the scope of this Standard. Removed an unnecessarily redundant note about beams missing moving surfaces. Revised the language about terminated outdoor shows, making it clearer that if in doubt about beams being in navigable airspace, do not lase in that area. Added LED lighting instruments to video cameras and projectors as being sensitive to laser damage. (Some instruments with a single LED source at the focal point of a lens would be just as susceptible to damage as a camera or projector.) Moved the "Notice to authorities" to be the last item in Section 3. Removed the section discussing Laser Operator/Spotter responsibilities if Spotters have the ability to e-stop. This seemed too specific, as well as too obvious in the rare cases where Spotters have e-stops. Moved language about roles and responsibilities from the Training section to the Roles and Responsibilities section. Added instructions on how to word and provide certificates of completion to Laser Spotters and Laser Personnel taking a safety course. Added some clarifying language to sections 7.3 and 7.4 of the Laser Safety appendix. Moved some material about laser safety courses from the main body to a note, for better flow. Added a copyright date and notice on page 2, in part so that page 2 can remain largely blank. (If printing the Standard, this prevents ink bleed and show-through on page 1, the cover.)
In a potentially significant change, added the requirement that a Cat A LSO must have passed an LSO course, or a refresher course, that specifically teaches the Cat A Standard. Also stated that ILDA will allow a one-year grace period after adoption of the Cat A Standard, for existing LSOs to take a course or refresher course to "come up to speed" on the Cat A Standard. See Section 3.21. Reviewers should check to see if they wish to comment or make alternative suggestions.
In section 3.22.3, Laser Operator training and instructions, added a definition of "mitigate" for those unfamiliar with the term. It is additionally defined as reducing or removing (e.g., a hazard). In section 3.22.6, Continuously Monitor the lasers, removed a reference to the lasers being on moving trusses, since earlier in the standard it is prohibited to have the lasers on a structure that is moved during the show. In section 3.5.2, Outside the U.S., changed from a "should" to a "shall" that laser systems shall be certified, inspected or otherwise approved for use under the laws and regulations of the jurisdiction. Added a requirement that any software button be visible, accessible and operable at all times during laser emission, and that the laser not emit light prior to running, or after exiting, the software program. Added a requirement that if the LSO course is limited to laser light shows, the title of the course on the certificate shall reflect that limitation.
Includes four changes suggested by Horacio Pugliese in a March 6 email to ILDA:
1) Added a requirement to test masks and projection zones before a show.
2) Added a requirement to 3.22.8 stating that if multiple e-stops are used (for different zones) each e-stop shall be clearly marked and the Laser Operator shall be trained to activate the correct e-stop if necessary.
3) In 3.35, made two logging requirements that were "shoulds" into "shalls".
4) Clarified in 5.2.1 that the Cat A standard only allows use of continuous wave lasers.
Also, removed discussion of pupil size as a consideration of safety at laser shows; a 2023 ILSC paper by Mark Shand of Waymo indicated that laser injury potential is roughly invariant for pupil sizes from 4-5 mm to 7-8 mm.
Added a few training topics: Fundamentals of laser operation; non-beam hazards of lasers; avoiding damage to cameras, video projectors and LED lighting instruments; optional presentation of ILDA's Basic Principles of Lasershow Safety; laser safety standards and organizations. Re-arranged a few topics. This was done to better align the Cat A requirements with ANSI and (especially) Arizona. Underlined all shalls and shoulds so they show up better when this document is printed in black-and-white (e.g., a monochrome laser printer).
Removed any statements or implications that a Laser Operator must take and pass a formal course. Now, the Laser Operator is allowed to be trained by the LSO or a similarly qualified person. This is because experience has shown that the vast majority of laser shows have been safely operated by persons who have no formal training. There continues to be a requirement for Laser Operator training on specified topics -- just not formal training. Added a Regulatory Note that some jurisdictions may require a certificate of training or similar written document, and that a list of topics covered may be desirable.
Began to use the Cat A logo with the green laser symbol with an "A" in the center. For example, lapel pins have been manufactured with this logo, and it is on the certificates of LSOs who have taken Cat A material in their course either at time of taking the LSO course or in a separate Cat A update course.
Clarified under “Example Venues” that a Cat A show could take place in a larger hotel meeting room, but not something as small as a conference room.
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