As of September 2022, ILDA is 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. The gray boxes list the changes in various versions as the document is developed.
The notes in these gray boxes contain the changes since the first public version, 7b.
The draft document contains all version changes since the first version (3.0) that was submitted to ILDA's Board of Directors. The list of changes is at the very end of the document.
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.
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 not require 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.
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.
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