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ArcticMyst Security by Avery
can a laser operator be their own LSO?
- Thread starter ixfd64
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I find it strange no one can answer this, but I want to know the answer as well so now I'm subscribed
Rule of thumb for USA:
(DO NOT STICKY THIS POST WITHOUT MY WRITTEN PERMISSION)
This is how I think of it:
You are always thinking like a LSO when performing in public and Need to be SAFETY MINDED. That said, when you are formally required to be a FORMALLY TRAINED and CERTIFIED and/or STATE LICENSED OPERATOR is rare. You always are a "Operator" under Federal rules when performing in public.
For ~45 states, you, the Variance Holder and / or Operator, are responsible for following the safety procedures in the manual, compliance with Federal rules, and ALL conditions of your variance. You or your equipment supplier (Imagine That!) set up most of the training and operating conditions that apply to you or your operator in your product manual submission, your initial product report, and your variance application.
In the other five, all hell can break loose if you don't notify, don't follow State law, or have the FORMALLY TRAINED AND/OR LICENSED operator present.
If I reactivate my variance, its worded so I'm the sole operator and responsible for seeing that I comply with the conditions of my variance. I'd keep log books and perform quality control pre-show. My variance had a simple pre-show QC check list. I file a yearly QC report when my variance is active. If I file the report , they auto-reactivate the variance now days. It does not require me to take a formal course or have a license.
For the Federal part:
Since this is Administrative, not Civil or Criminal law, its unique in that you basically have to self-report any non-compliance, and self-enforce the rules and terms of your variance. Think of it as the Honor system. They can come out and inspect you, but that is rare.
IF your in the most of the USA, and IF your the OWNER/OPERATOR, and IF you specify In your variance that only YOU or your designated trained minion/operator employed by you, will operate the system, then your good to go without a FORMAL LSO or LICENSED OPERATOR. Formal LSO training is then just highly suggested.
The operator should be briefed on the basics of 21 CFR 1040, The conditions of the variance, and comply with the directions in the operator's manual. The owner is responsible for ensuring the operator complies with the rules. Most corporations that own a system then set up some form of informal training and formal, written, nightly, quality control procedures. It is always wise to have the operator sign a form that they understand the safety requirements placed upon them.
Large corporate clients (Theme Parks, Cruise Lines) may require you to have a LSO, or have the system inspected for their own legal reasons.
The four main exceptions are New York, Arizona, Texas, New Jersey, and perhaps Massachusetts.
New York, requires operator licensing and formal training with a tough exam. New York is a unique situation requiring a NYS Class B license for the operator and special show reporting and fees. The required New York Class B Operators License requires travel to New York to get. It comes with a difficult exam, and classroom preparation for that exam seems to be only offered by other Class B LSOs.
Arizona requires you to have a trained company LSO with formal training. Arizona has a state licensing system with Fees. in place. The company has a dedicated LSO, who needs to pass a commercial course in medical and laboratory laser safety. The requirements are vague, but under certain circumstances a ILDA LSO course may be acceptable. That LSO must train the operators. Arizona especially looks at operator training during inspections. I've personally been inspected as a guest operator in AZ, and it was brutal. You really need to know your laser safety.
Arizona and New York require advanced notice of laser shows to be filed.
Texas, Arizona, and New York have special reporting requirements and very expensive licenses. AZ is about 400$ a year. Texas is up to 1200$ or so. New York has been known to charge a large scale guest operator as much as 600$ for one night, and then they still had to pay the NYS Class B operator.
The fee for the NYS class B exam is expensive, as well.
New Jersey and "Allegedly" Massachusetts have reporting requirements.
Outdoor Shows are ALWAYS under certain FAA requirements which are outside the scope of this post.
Most groups touring in AZ, TX, and NY hire a local, experienced operator, who has the required state license or permit. They then pay for a company permit to operate the gear, this requires knowing far in advance that your visiting those three states. These yearly fees or on site fee can be steep,
The real nasty grey area is if you let a volunteer run it, link the system to lighting DMX console operated by a untrained operator, Let a DJ jam on it etc. Then you can be in violation if you are not present, and cannot shutter the system should a malfunction occur.
The ILDA LSO course is worth it, if operating in a state that requires an additional LSO or LSO on staff, Especially in Arizona.
Automated operation has special additional CDRH requirements.
Generally the states that require some form of permit also want to see your FEDERAL paperwork done before you apply, and they check if you have insurance. Insurance can be quite cheap and is worth having.
Most laser regs get enforced when a smart Fire Marshal visits a site and asks if you have paperwork. In the US, there is a vague clause in the NFPA 70 Document about lasers in general. This gets copied into the local building or zoning code. If its there, the Marshal can ask questions... When I was on site, I met many Fire Marshals (Pittsburgh, Cleveland, St. Louis, Phoenix) who asked questions and wanted to see documentation. That is when the rubber hits the road and you want to have at least some paperwork. In most cases, all the Marshal can do is shut you down for the evening. They can also shut down the fog machine, which effectively does the same thing.
A Variance is free, and worth doing, even though its time consuming. It can difficult if you have not done one before. (Ask on the "other forum" if you need help, but do not expect anyone to write it all for you.) Woe betide you if you ever hurt some one and a lawyer finds you did not have your paperwork done. If your ever going to operate outdoors, you cannot file for FAA show approval without a variance in the US. Pilots are now trained to report any outdoor laser activity they see, so its worth having the documents.
(Note, for industrial and scientific outdoor lasing, FAA waves the variance requirement but still requires reporting far in advance.)
Disclaimed:
I'm not a lawyer, I'm not renewing my personal variance for a while, and you can Contact ILDA's Safety Committee Chairman for the latest and greatest advice.
I did pass my ILDA LSO course last year, paid for by my employer. That lets me take care of myself, but one should always obtain the legal requirements of the jurisdiction(s) one is in.
Steve
(DO NOT STICKY THIS POST WITHOUT MY WRITTEN PERMISSION)
This is how I think of it:
You are always thinking like a LSO when performing in public and Need to be SAFETY MINDED. That said, when you are formally required to be a FORMALLY TRAINED and CERTIFIED and/or STATE LICENSED OPERATOR is rare. You always are a "Operator" under Federal rules when performing in public.
For ~45 states, you, the Variance Holder and / or Operator, are responsible for following the safety procedures in the manual, compliance with Federal rules, and ALL conditions of your variance. You or your equipment supplier (Imagine That!) set up most of the training and operating conditions that apply to you or your operator in your product manual submission, your initial product report, and your variance application.
In the other five, all hell can break loose if you don't notify, don't follow State law, or have the FORMALLY TRAINED AND/OR LICENSED operator present.
If I reactivate my variance, its worded so I'm the sole operator and responsible for seeing that I comply with the conditions of my variance. I'd keep log books and perform quality control pre-show. My variance had a simple pre-show QC check list. I file a yearly QC report when my variance is active. If I file the report , they auto-reactivate the variance now days. It does not require me to take a formal course or have a license.
For the Federal part:
Since this is Administrative, not Civil or Criminal law, its unique in that you basically have to self-report any non-compliance, and self-enforce the rules and terms of your variance. Think of it as the Honor system. They can come out and inspect you, but that is rare.
IF your in the most of the USA, and IF your the OWNER/OPERATOR, and IF you specify In your variance that only YOU or your designated trained minion/operator employed by you, will operate the system, then your good to go without a FORMAL LSO or LICENSED OPERATOR. Formal LSO training is then just highly suggested.
The operator should be briefed on the basics of 21 CFR 1040, The conditions of the variance, and comply with the directions in the operator's manual. The owner is responsible for ensuring the operator complies with the rules. Most corporations that own a system then set up some form of informal training and formal, written, nightly, quality control procedures. It is always wise to have the operator sign a form that they understand the safety requirements placed upon them.
Large corporate clients (Theme Parks, Cruise Lines) may require you to have a LSO, or have the system inspected for their own legal reasons.
The four main exceptions are New York, Arizona, Texas, New Jersey, and perhaps Massachusetts.
New York, requires operator licensing and formal training with a tough exam. New York is a unique situation requiring a NYS Class B license for the operator and special show reporting and fees. The required New York Class B Operators License requires travel to New York to get. It comes with a difficult exam, and classroom preparation for that exam seems to be only offered by other Class B LSOs.
Arizona requires you to have a trained company LSO with formal training. Arizona has a state licensing system with Fees. in place. The company has a dedicated LSO, who needs to pass a commercial course in medical and laboratory laser safety. The requirements are vague, but under certain circumstances a ILDA LSO course may be acceptable. That LSO must train the operators. Arizona especially looks at operator training during inspections. I've personally been inspected as a guest operator in AZ, and it was brutal. You really need to know your laser safety.
Arizona and New York require advanced notice of laser shows to be filed.
Texas, Arizona, and New York have special reporting requirements and very expensive licenses. AZ is about 400$ a year. Texas is up to 1200$ or so. New York has been known to charge a large scale guest operator as much as 600$ for one night, and then they still had to pay the NYS Class B operator.
The fee for the NYS class B exam is expensive, as well.
New Jersey and "Allegedly" Massachusetts have reporting requirements.
Outdoor Shows are ALWAYS under certain FAA requirements which are outside the scope of this post.
Most groups touring in AZ, TX, and NY hire a local, experienced operator, who has the required state license or permit. They then pay for a company permit to operate the gear, this requires knowing far in advance that your visiting those three states. These yearly fees or on site fee can be steep,
The real nasty grey area is if you let a volunteer run it, link the system to lighting DMX console operated by a untrained operator, Let a DJ jam on it etc. Then you can be in violation if you are not present, and cannot shutter the system should a malfunction occur.
The ILDA LSO course is worth it, if operating in a state that requires an additional LSO or LSO on staff, Especially in Arizona.
Automated operation has special additional CDRH requirements.
Generally the states that require some form of permit also want to see your FEDERAL paperwork done before you apply, and they check if you have insurance. Insurance can be quite cheap and is worth having.
Most laser regs get enforced when a smart Fire Marshal visits a site and asks if you have paperwork. In the US, there is a vague clause in the NFPA 70 Document about lasers in general. This gets copied into the local building or zoning code. If its there, the Marshal can ask questions... When I was on site, I met many Fire Marshals (Pittsburgh, Cleveland, St. Louis, Phoenix) who asked questions and wanted to see documentation. That is when the rubber hits the road and you want to have at least some paperwork. In most cases, all the Marshal can do is shut you down for the evening. They can also shut down the fog machine, which effectively does the same thing.
A Variance is free, and worth doing, even though its time consuming. It can difficult if you have not done one before. (Ask on the "other forum" if you need help, but do not expect anyone to write it all for you.) Woe betide you if you ever hurt some one and a lawyer finds you did not have your paperwork done. If your ever going to operate outdoors, you cannot file for FAA show approval without a variance in the US. Pilots are now trained to report any outdoor laser activity they see, so its worth having the documents.
(Note, for industrial and scientific outdoor lasing, FAA waves the variance requirement but still requires reporting far in advance.)
Disclaimed:
I'm not a lawyer, I'm not renewing my personal variance for a while, and you can Contact ILDA's Safety Committee Chairman for the latest and greatest advice.
I did pass my ILDA LSO course last year, paid for by my employer. That lets me take care of myself, but one should always obtain the legal requirements of the jurisdiction(s) one is in.
Steve
Last edited:
As for Canada:
Forgive me, I rewrote the above post a dozen times trying to take the "Annecdotal" part out of it.
Search for posts here by X-Laser on Canadian Laser Show Safety. X-Laser, Inc. sells gear into Canada. Dan at X-Laser is a gentleman and will tell you what he knows.
Transport Canada needs advance notification on outdoor shows so they can approve, disapprove, or issue a Notice to Airmen (NOTAM) as needed.
Compliance with IEC 60825 or adopting the US rules 21 CFR 1040 CDRH to meet the "Radiation Emitting Devices" (RED) rules is/was required.
My friend who owned a Canadian Laser Show company kept the Ontario and Canadian Governments informed in writing of his actions. He did this as he was audience scanning, thus he wished to have some legal framework or document in place. When I visited him for a week, I found his government's informal, written, co-operation interesting. He let me run his system with only a short, informal, briefing.
For Ontario it was the Ministry of Labour, Radiation Protection Service, For Canada as a whole it was Health Canada's Consumer and Clinical Radiation Protection Bureau.
One thing is for sure, don't hit a Airplane with a laser in Canada. Any Charges, if filed, are brutal. If you do a show outdoors, work with Transport Canada.
Steve
Forgive me, I rewrote the above post a dozen times trying to take the "Annecdotal" part out of it.
Search for posts here by X-Laser on Canadian Laser Show Safety. X-Laser, Inc. sells gear into Canada. Dan at X-Laser is a gentleman and will tell you what he knows.
Transport Canada needs advance notification on outdoor shows so they can approve, disapprove, or issue a Notice to Airmen (NOTAM) as needed.
Compliance with IEC 60825 or adopting the US rules 21 CFR 1040 CDRH to meet the "Radiation Emitting Devices" (RED) rules is/was required.
My friend who owned a Canadian Laser Show company kept the Ontario and Canadian Governments informed in writing of his actions. He did this as he was audience scanning, thus he wished to have some legal framework or document in place. When I visited him for a week, I found his government's informal, written, co-operation interesting. He let me run his system with only a short, informal, briefing.
For Ontario it was the Ministry of Labour, Radiation Protection Service, For Canada as a whole it was Health Canada's Consumer and Clinical Radiation Protection Bureau.
One thing is for sure, don't hit a Airplane with a laser in Canada. Any Charges, if filed, are brutal. If you do a show outdoors, work with Transport Canada.
Steve
Last edited:
Sigurthr
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Thank you tremendously, Steve! I was hoping someone like you might enlighten us.
Could you perchance elaborate on outdoor scientific lasing requirements with the FAA? This area interests me greatly as I have done a lot of free space optical / lightwave communications and other such non lasershow activities (and yes, I'm FCC licensed).
Could you perchance elaborate on outdoor scientific lasing requirements with the FAA? This area interests me greatly as I have done a lot of free space optical / lightwave communications and other such non lasershow activities (and yes, I'm FCC licensed).
Ah, this is undefined for Ham Radio.
There is NO memorandum of understanding between FCC and FAA on this...
640 Terahertz (light) is a grey area. Yes, the FCC allows it under a guise in the wording, ARRL recognizes it, but FCC and FAA do NOT have a memorandum on this. So, Skyscatter/Cloudscatter is out of the question without filing with FAA. Direct paths between buildings or mountaintops are another matter.
FAA's rule, if a helicopter can get into the beam, you should file. If your in navigable airspace you should file.
Common sense, if your following your spirit of your license and running minimum usable power/QRP , Your on a tripod, and your not using more then say 50 mW, I would not worry about it. Most laser distance records were set using CW and milliwatts anyways.
However if you start getting to the point where the NOHD is more then a hundred yards, etc, Its time to start thinking seriously about complying with the rules. Keep in mind you have the sensitive flight zone and critical flight zone exposure distances to think about as well. Google "lasers in airspace, FAA" and the calculations will pop up, I'm thinking its 7400.2 G for the latest revision,
If your running power levels (watts) where scatter is visible some distance away from the laser, keep in mind pilots are obliged to report you if they can see the beam.
Upcollimation to reduce power per unit area is a very good idea.
Consider using LEDs, you'll get more range, as laser beams are subject to horrible interference effects beyond a few kilometers. Incoherent light actually wins in this case.
Some of the current world records for light communications was set with Luxeon Stars, with Fresnel Lenses, not with lasers. Over a few kilometers, lasers really "suck" for lightwave communications with any bandwidth , unless your in a vacuum or using fiber optics.
The current laser record was set with a Hecad, but bandwidth over the long path was found to fall to near ON/OFF, a few Hertz at best.
If you have a incident, your probably wide open for prosecution on this, callsign issued or not.
Alternatives for Laser, See:
http://www.google.com/url?sa=t&rct=...=hkGJTsB3zyCvt7ZR4bfjAw&bvm=bv.69837884,d.aWw
Modulatedlight.org
Steve
Last edited:
Sigurthr
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I was operating at 455THz or so, but same rules would apply I'm sure. What's the significance of 640THz, btw? That's ~468nm.
Good to know about the heli rule. Yes, my main concern was direct paths between tall structures and natural features, and between those places and ground. We did what all good laser owners should do in such circumstances; do rough alignment with <5mW pens and had spotters for any aircraft in the observable sky.
I typically ran around 40mW CW, but I never got better than half a kilometer or so in terms of range. The main hurdle I encountered was alignment, since I wasn't using precision equipment. Initially I maxed out at around 100m range using 15mW, but found that if I purposefully diverged the beam and then increased output power to lift the signal out of the noise floor to compensate it alleviated alignment issues with acceptable performance.
It was fun and got everyone in the radio club excited and I educated them about lasers and laser safety. I packed all the equipment away and haven't used it since those sessions last year, but there was some talk of other members wanting to try for some international QSOs using lightwave across St Mary's River or "long distance" (~<5mi) links between a mountain and ground. I told them it was too dangerous to try the international one, due to various regulations and the specular reflection and boating hazards. No plans ended up being made. I did want to try the mountain-ground one though but was considering using 500mW (again with a lens assembly that would diverge the spot to around 2 square meters at the target location). The idea would be all participants would be wearing OD7+ goggles rated for the wavelength and the spot size would reduce the optical hazard in addition to easing alignment. I was unaware of any FAA regulations, as was our ARRL rep who said we were clear for up to 1.5W of power (we're all extra class licensees).
The required reporting of a visible beam was one of my concerns, but I didn't know if it only applies to skyward beams or all visible beams. I brought it up when discussing the cross-river idea; I basically said there were too many witnesses given the population density and monitoring of the border.
Thanks a ton, this info is very helpful and quite targeted (pun intended) to the application at hand. I had no idea of the poor bandwidth. I assumed that atmospheric interference aside it shouldn't degrade measurably as long as the signal is out of the noise floor of the receiver.
I'm rather intrigued about receiver sensitive and noise rejection for LED based units. We used lasers because it was easy to ensure a high S/N ratio given that the signal was many orders of magnitude above ambient light level.
