For the FDA/CDRH
The FDA’s Center for Devices and Radiological Health is the U.S. government agency in charge of laser equipment safety. CDRH regulations include mandated safety labels which describe the type and power of laser, the classification and the nature of the hazard. These are the ubiquitous “Caution” and “Danger” labels that should be on every laser device emitting hazardous beams:
Label from a powerful Class 4 laser, over 80 watts. This is from a light show laser used by Laser Production Network of Miami, Florida.
Mandatory Aviation Safety Label
Unfortunately, these labels only cover eye and skin hazards. They do not address eye-safe but too-bright light aimed at pilots. Given the widespread misuse of lasers with aircraft, it is clear that existing labels do not provide adequate information for users.
To further its mission of public health safety, CDRH should require a new Aviation Safety Label. This would have a statement such as “DO NOT aim at or near aircraft.” Additional information can also be added, depending on the size available for the label. Here is a sample:
Adding such a label should not be a problem for manufacturers. Lasers are already required to have labels; one more does not add a significant cost or burden. ILDA already recommends for manufacturers that they voluntarily add a warning about not hitting aircraft, and in September 2009 a major Internet laser distributor did just that.
Details about what lasers should have the label, and about the exact wording, can be worked out. As of August 2009, ILDA is working on a formal proposal to CDRH. Ideally, the label idea will first be implemented as guidance, in the form of a “Laser Notice” recommendation to laser manufacturers and sellers. If the label becomes widespread and helps reduce the number of incidents, this would be great. But if manufacturers and sellers resist a voluntary approach, then CDRH should begin rulemaking proceedings, to make such a label mandatory.
Limitations on portable lasers’ power
In June 2010, Wicked Lasers began selling the Spyder III Pro Arctic, a 1 watt handheld laser that cost only USD $200. This is a highly dangerous Class 4 laser device that, in our opinion, has no justifiable consumer use.
The CDRH should find a way to ban or highly restrict all portable lasers above a certain power. We support around 50 or 100 milliwatts as the minimum. However, the exact number is not critical; what is important is setting a limit. Certainly, there is no need for Class 4 (500 mW visible beam) handheld lasers, so at the very least all portable lasers above 500 mW should be banned. More information on Class 4 hazards, and our recommended regulatory response, is on the June 2010 Alert page.
It is also important to write any laws or regulations to avoid loopholes. Additional information is on the “If you are writing a laser law” page.
For more information about the CDRH, see this page.