Laser advertisement - has anyone done this?

[Aberrant5]

Driving near Cannonsburg PA I observed a VERY bright laser emitting from a church steeple, stopping on a neighboring hillside. I later found it was placed there by a laser show contractor based in Cannonsburg in commemoration of a fallen officer. The laser was visible from miles away, just a single beam. The capitalist in me said: “this could be a great way to draw attention for my business”. After a bit of research regarding the safety and legalities of such a device it does not seem out of the question to do something similar in my small town, perhaps with clearance from the laser clearing house I could even transmit a vertical beam for a couple of hours during special events such as the 4th of July etc.

I could care less about burning or other aspects of lasers visibility, safety and cost are my only concerns.

With a budget around $1-2000 do you think I would be able to construct something fairly visible from say a 2-3 mile range?

Would an array of smaller beams running parallel be just as visible as an array that has been focused? And perhaps a bit less dangerous?

- a large part of why I am attracted to this idea is the building/learning aspect of all of this. It’s just very difficult to get an idea of what power laser is necessary to have fairly decent visibility from images as they are subject to camera magic and circumstance.

 

[Aberrant5]

Oh as well, any color is likely suitable though green would be preferable and seems to be a less expensive color to work with.

 

[Encap]

Can be done however---not as easily as you imagine and $1-$2000 is a drop in the bucket.

You will need to comply with all FDA laser laws, rules, and regulations. You probably have to hire a professional Certified Laser Safety Officer to be able to answer all the questions that will need to be answered for the FDA. Is a complicated thing to do especially if you are thinking of making the laser device you will use.
See: https://www.lasershowsafety.info/us-laws.html and
see (LSO) Laser Safety Officer certification info here: https://www.lasershowsafety.info/LSO.html
+ you will need to comply with all State and Town requirements/laws as well-----you will probably need a town code Variance if you are going to operate it more than once for a few hours if allowed at all----especially if it annoys anyone subjected to seeing it for whatever reasons--check with local officials first----maybe the town would not allow what you want to do unless you are the town and the only business in it lol ---town may see it as a 2 to 3 miles beacon of undesireable nuisance, distraction, annoyance etc. to other people.

You will need 2 FDA Variances, one Variance for the equipment ( if you are building the equipment then you are the manufacturer and need to have all aspects required by the FDA covered and must report it all to them---if you buy a laser light show machine it has to be one that has been already given a Variance by the FDA, not just any Chinese laser show will do and one Variance for what you want to do with it. ---to do anything like you are imagining--same as the the Cannonsburg display you mentioned + you will need FAA approval if outdoors:

"Further, if the use is outdoors, FDA will not grant the variance unless the user submits a description of their laser operations to FAA using FAA Form 7400.2 and receives a letter of non-objection from FAA. In this indirect way, demonstration/lightshow lasers and SLA lasers are the only outdoor uses of lasers that are required under Federal law to get permission in advance from FAA. " See: https://www.laserpointersafety.com/rules-general/rules-outdoor/rules-outdoor.html

See: https://www.fda.gov/radiation-emitt...-and-entertainment-products/laser-light-shows
"Laser products promoted for demonstration purposes are limited to hazard Class IIIa by FDA regulation 21 CFR 1040.11(c). This means that projectors are limited to 5 milliwatts output power in the visible wavelength range from 400 to 710 nanometers. There are also limits for any invisible wavelengths and for short pulses. Laser light show projectors therefore may not exceed the accessible emission limits of CDRH Class IIIa. Laser light show manufacturers must submit a variance request for FDA approval in order to sell and operate higher class (Class IIIb and IV) laser light show equipment.

Prior to using Class IIIb and IV lasers for a laser light show in the United States, the following documents must be submitted to the FDA:

• Product Report describing the laser projector,
• 
  
• Laser Light Show Report describing the laser light show, and
• 
  
• Application requesting FDA approval for a variance from the demonstration laser product hazard class limit of IIIa (5mW visible output).

These submissions must be prepared with either the CeSub electronic submissions software or the paper reporting guides listed below.
If you are purchasing a certified laser projector for which a product report has already been submitted, you need only submit the laser light show report and variance application.
Your firm can begin to produce laser light shows only after receipt of a variance approval letter from FDA indicating the conditions under which you may produce the laser light show or distribute laser light show projectors."

See also http://www.laserist.org/us-regs.htm

• Laser Product Report, "Guide for Preparing Product Reports on Lasers and Products Containing Lasers", FDA Form 3632
• Variance, "Application for a Variance from 21 CFR 1040.11(c) for a Laser Light Show, Display, or Device", FDA Form 3147
• Annual Report, "Guide for Preparing Annual Reports on Radiation Safety Testing of Laser and Laser Light Show", Form FDA 3636
• Reporting Guide for Laser Light Shows and Displays, FDA Form 3640
• Laser Light Show Notification, FDA Form 3635 (available through eSubmitter)
• Laser Original Equipment Manufacture Report, FDA Form 3637 (available through eSubmitter)

PS might be a good idea to contact Lightwave International president George Dodworth who does the Cannonsburg shows and discuss with him the feasibility what you are thinking to do see: http://www.lasershows.net/contact/ he/Lightwave have done 10,000 shows and have 25 years of experience-- Lightwave says abot the Cannonburg show: “It's a show that could never make economic sense if anyone had to pay for it. It’s not uncommon to use over $1 million in equipment", so...
see: https://observer-reporter.com/publi...cle_646c8718-f34d-11e8-8a87-2379af6a1cd7.html

 

[Cyparagon]

I've unintentionally drawn attention from several miles away with the output from a projector array. I think that's the cheapest and simplest way to do something like that. 40 watt blue beam for $300.

 

[steve001]

Driving near Cannonsburg PA I observed a VERY bright laser emitting from a church steeple, stopping on a neighboring hillside. I later found it was placed there by a laser show contractor based in Cannonsburg in commemoration of a fallen officer. The laser was visible from miles away, just a single beam. The capitalist in me said: “this could be a great way to draw attention for my business”. After a bit of research regarding the safety and legalities of such a device it does not seem out of the question to do something similar in my small town, perhaps with clearance from the laser clearing house I could even transmit a vertical beam for a couple of hours during special events such as the 4th of July etc.

I could care less about burning or other aspects of lasers visibility, safety and cost are my only concerns.

With a budget around $1-2000 do you think I would be able to construct something fairly visible from say a 2-3 mile range?

Would an array of smaller beams running parallel be just as visible as an array that has been focused? And perhaps a bit less dangerous?

- a large part of why I am attracted to this idea is the building/learning aspect of all of this. It’s just very difficult to get an idea of what power laser is necessary to have fairly decent visibility from images as they are subject to camera magic and circumstance.

As Encap made quite clear. If you like lots of paperwork and the math that goes with it then go for it. If not, hire a laser show company.

P.S. The expression it not "I could care less". It is "I could not care less"

 

[Encap]

I've unintentionally drawn attention from several miles away with the output from a projector array. I think that's the cheapest and simplest way to do something like that. 40 watt blue beam for $300.

$300 for just an 8 diode block of laser diodes 5W each, alone, perhaps.
None of everything else needed to make a functioning device for his purposes operationally and safety wise , much less any costs associated with FDA or FAA requirements for a device Variance approval nor outdoor light show use Variance approval or State and local use approvals

Does bring to mind Styro's hobby playtime indoor use only, 40Watt 8 diode block of blue laser diodes effort video:

 

[Aberrant5]

Sounding a bit less feasible as an integral aspect of this plan is essentially a low cost marketing project. I don't mind devoting some time on the project, as it is interesting, however the budget will need to be nominal.

The city, nor the county are going to give me any trouble. It would only be state and federal level governments that could pose a problem.

-Where is the line drawn between a device that I have manufactured and an already manufactured device that I have simply modified?

If I removed the the plastic case from a laser projector and played a movie on a wall I imagine that would fly?

If I use the original, power source, board, and diode from a couple of projectors, and simply point them all at the same knife edge I would it seems a tough argument to call my mirror a newly manufactured laser?

If I modify the power source and a few small components of the board, point a few of the diodes at a mirror the ATF, FDA, FFA, and CIA throw me in prison and fine me into bankruptcy?

 

[Encap]

In imagination everything is possible, not so in the real world.
You can do whatever you want inside at home for yourself with whatever you can get you hands on to play with as long as it is only for your own personal use inside your home.
Use outdoors to advertise a business and "draw in people" is a completely different story.
There are no loopholes in the FDA Laser Laws, rules, and regulations--don't even bother to daydream about it. You can't mix and match parts from disassembled finished products that complied with all the FDA laws, rules, and regulations and pretend it isn't something different from the original product or that you didn't do it, if that is what you mean. LOL

If you want to do what you indicated in your original post--- use laser beacon outdoors to advertise your business--then there are actually two FDA variances required. One is for the lasershow-creating equipment, and the other for how it is used (audience location, barriers, etc.). A single 4-page form "Application for a Variance" (FDA form 3147; see post #2 for a link) is filled out whether for a device or for the show.
Study: http://www.laserist.org/us-regs.htm

Laser products promoted for demonstration purposes are limited to hazard Class IIIa by FDA regulation 21 CFR 1040.11(c). This means that projectors are limited to 5 milliwatts output power in the visible wavelength range from 400 to 710 nanometers. There are also limits for any invisible wavelengths and for short pulses. Laser light show projectors therefore may not exceed the accessible emission limits of CDRH Class IIIa. Laser light show manufacturers must submit a variance request for FDA approval in order to sell and operate higher class (Class IIIb and IV) laser light show equipment.
Prior to using Class IIIb and IV lasers for a laser light show in the United States, the following documents must be submitted to the FDA:

• Product Report describing the laser projector,
• 
  
• Laser Light Show Report describing the laser light show, and
• 
  
• Application requesting FDA approval for a variance from the demonstration laser product hazard class limit of IIIa (5mW visible output).

See: https://www.fda.gov/radiation-emitt...-and-entertainment-products/laser-light-shows


The following definitions are basic to the regulations:
A laser is a device capable of producing or amplifying electromagnetic radiation in the wavelength range from 180 to 1 x 106* nanometers by the process of controlled stimulated emission [1040.10(b)(19)].

A laser system consists of a laser in conjunction with its power supply [1040.10(b)(23)].

A laser product is any device that constitutes, incorporates, or is intended to incorporate a laser or laser system [1040.10(b)(21)].

"A manufacturer is any person or organization in the business of making, assembling, importing [1000.3(f)], or modifying laser products [1040.10(i)] "
See top of page #2: https://www.fda.gov/media/74026/download
and

"Code of Federal Regulations

Title 21, Volume 8

Revised as of April 1, 2018

CITE: 21CFR1040.10

(i) Modification of a certified product. The modification of a laser product, previously certified under 1010.2, by any person engaged in the business of manufacturing, assembling, or modifying laser products shall be construed as manufacturing under the act if the modification affects any aspect of the product's performance or intended function(s) for which this section and 1040.11 have an applicable requirement. The manufacturer who performs such modification shall recertify and reidentify the product in accordance with the provisions of 1010.2. and 1010.3."

Laser projectors and laser light shows are “demonstration laser products” as defined by 21 CFR 1040.10(b)(13):
“Demonstration laser product means a laser product manufactured, designed, intended, or promoted for purposes of demonstration, entertainment, advertising display, or artistic composition.”
See: https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?FR=1040.10

"In general, if you are using a higher powered laser projector outside of your home, you must get permission from the U.S. Food and Drug Administration. You may also be subject to state regulation, such as needing a permit, a laser operator’s license and/or having to register your laser projector.

FDA Laser Notice 51 requires anyone who is “introducing into commerce” a laser projector that is Class 3B or Class 4 (e.g., above 5 mW output), to have an approved variance from the FDA. Further, they cannot purchase the laser projector before the variance is approved.

The short version of “introduction into commerce” means just about any use, except for use at home with family and friends. For example, a variance is required if there is some type of commercial transaction, such as a person paying to see a concert or have drinks at a bar where a laser projector is being used. It can also mean that an advertiser is paying to support an event with free admission, or the laser is advertising a product, service or event that costs money "
See: https://www.lasershowsafety.info/faq.html

 

[steve001]

Sounding a bit less feasible as an integral aspect of this plan is essentially a low cost marketing project. I don't mind devoting some time on the project, as it is interesting, however the budget will need to be nominal.

The city, nor the county are going to give me any trouble. It would only be state and federal level governments that could pose a problem.

-Where is the line drawn between a device that I have manufactured and an already manufactured device that I have simply modified?

If I removed the the plastic case from a laser projector and played a movie on a wall I imagine that would fly?

If I use the original, power source, board, and diode from a couple of projectors, and simply point them all at the same knife edge I would it seems a tough argument to call my mirror a newly manufactured laser?

If I modify the power source and a few small components of the board, point a few of the diodes at a mirror the ATF, FDA, FFA, and CIA throw me in prison and fine me into bankruptcy?

If one buys separately all parts to make a working laser one has not crossed the line. However, using said laser for a commercial purpose puts one over the line. When modifying an already assembled laser for a commercial purpose one has crossed the line from the start.

 

[Cyparagon]

$300 for just an 8 diode block of laser diodes 5W each, alone, perhaps.

I paid about $250 for a 24-diode used array and about $50 for a 30V 10A bench PSU without trying very hard. Add in a cooling fan and a few balancing resistors from your junk drawer and it's done. You don't need to make it hard.

 

[Encap]

I paid about $250 for a 24-diode used array and about $50 for a 30V 10A bench PSU without trying very hard. Add in a cooling fan and a few balancing resistors from your junk drawer and it's done. You don't need to make it hard.

Sounds very reasonable and is easy enough to do as a basement project exposing nobody but the builder to the laser output.
Not somethng to suggest as good idea for a noob without any laser knowledge or experience + no idea of the hazard involved and safety aspects re: possible eye damage involved.

The not so easy and time consuming part is for the OP's use he needs to get the FDA Variances for the laser device and for use as a Demonstration Laser Product/Laser Show for running it outdoors to promote his commercial business i.e meet all the FDA laws ,rules, and requirements.

 

[Aberrant5]

Thank you Encap, your advice would have taken me quite a few hours bobbling through piles of BS to uncover.

 

[Aberrant5]

Hmm, my best friend and college roommate is a local attorney, I am going to run this past him:

"It can also mean that an advertiser is paying to support an event with free admission, or the laser is advertising a product, service or event that costs money "

The business I am advertising does not sell anything to the public, we buy gold and other items. I imagine the argument could be made that I provide a service, however it is not the strongest argument and just as well, under no circumstance do we CHARGE money for anything. As well it would be rather difficult to call it an event, I don't intend to market it, we are talking about something mounted on the roof of a 3 story building and displayed. There is no crowd, there is no venue, there is no advertisement. To say that I cannot display a laser from my roof without the intention of fostering an event or something or the sort would seem to almost breach 1st amendment rights...

If you were to transmit a home made laser from your back porch into the sky it would be a legal activity. What if my home happens to be the 2nd floor of my commercial building???

On the other side of the FDA, I imagine if I purchased something such as this:

World Most Powerful 7 Watts 445nm 455nm 470nm Blue laser - The Striker series

The World's Most Powerful Blue Handheld Laser A Legit 7 Watts INSANE Laser Power This is the world's most powerful blue handheld laser as of 2020 You may see a 10-watt or even 100-watt laser on other websites, but those are over inflated power ratings. A 10-watt blue laser diode does not yet...

www.sanwulasers.com

It would be rather hard to argue that I constructed it, I have a receipt :O

 

[Encap]

Hmm, my best friend and college roommate is a local attorney, I am going to run this past him:

"It can also mean that an advertiser is paying to support an event with free admission, or the laser is advertising a product, service or event that costs money "

The business I am advertising does not sell anything to the public, we buy gold and other items. I imagine the argument could be made that I provide a service, however it is not the strongest argument and just as well, under no circumstance do we CHARGE money for anything. As well it would be rather difficult to call it an event, I don't intend to market it, we are talking about something mounted on the roof of a 3 story building and displayed. There is no crowd, there is no venue, there is no advertisement. To say that I cannot display a laser from my roof without the intention of fostering an event or something or the sort would seem to almost breach 1st amendment rights...

If you were to transmit a home made laser from your back porch into the sky it would be a legal activity. What if my home happens to be the 2nd floor of my commercial building???

On the other side of the FDA, I imagine if I purchased something such as this:

World Most Powerful 7 Watts 445nm 455nm 470nm Blue laser - The Striker series

The World's Most Powerful Blue Handheld Laser A Legit 7 Watts INSANE Laser Power This is the world's most powerful blue handheld laser as of 2020 You may see a 10-watt or even 100-watt laser on other websites, but those are over inflated power ratings. A 10-watt blue laser diode does not yet...

www.sanwulasers.com

It would be rather hard to argue that I constructed it, I have a receipt :O

The quote you mentioned was information presented by The International Laser Display Association on a safety info page here: https://www.lasershowsafety.info/faq.html not from FDA information. Not sure if asking a lawyer would be of any value at all.
Would imagine only a specialist attorney who knows all the FDA laws, rules and regulations concerning regulating radiation-emitting electronic products--in this case lasers in particular would be of any help.

Bottom line seems to be that if you want to shine a laser in the sky as a personal activity not associated with a business in any way directly or indirectly, it is not in violation of FDA laws, rules, and regulations provided it does not interfere with an aircraft or flight path of an aircraft which is a Federal crime. In USA it is Illegal to aim laser pointer beams at aircraft or their flight path; up to 5 years in prison and up to $250,000 fine + civil penalty as well. see: https://www.laserpointersafety.com/rules-general/uslaws/uslaws.html#US_FDACDRH_21_CFR_10401011 and see: https://en.wikipedia.org/wiki/Lasers_and_aviation_safety The FAA actively works with federal, state, and local law enforcement agencies to catch violators and pursue civil and criminal penalties.

If the laser or projector output is more than 5mW and if it is associated with a business i.e doing what you described in the OP, creating a beam visible for 2 to 3 miles/a rooftop beacon to attract attention to your business ---then for that activity you need FDA Variances and FAA approval letter to get the FDA Variance.

If you are going to obtain or use a laser especially one over 5mW it would be a good idea to study up on laser eye hazards and safety--excellent web site here: https://www.laserpointersafety.com/ and see laser hazard chart here: https://www.lasersafetyfacts.com/resources/FAA---visible-laser-hazard-calcs-for-LSF-v02.png

Would be a good idea to obtain professional advice about what you want to do if you are not familiar with FDA laws, rules, and regulations concerning lasers and laser uses. Probably best bet is one of the Laser Show people who know what they are doing re: outdoor use of lasers. The Lightwave guy George Dodworth who did the Cannonburg church show would be a good one to speak with.

Do whatever you want to do--is up to you.
The point of replying at all to your OP was to give you a heads up on what you need to consider for FDA approvals of your proposed activity to be in compliance with FDA laws, rules and regulations re: lasers and be considered safe to do.

PS Aside from exceeding the legal output limit of 5mW for lasers of whatever type for your envisioned use without Variances, the hand held laser you mentioned has a duty cycle of 60 seconds on/60 seconds off to avoid damage to the laser meaning you can run it safely for only 60 seconds at a time so....

 

[steve001]

Hmm, my best friend and college roommate is a local attorney, I am going to run this past him:

"It can also mean that an advertiser is paying to support an event with free admission, or the laser is advertising a product, service or event that costs money "

The business I am advertising does not sell anything to the public, we buy gold and other items. I imagine the argument could be made that I provide a service, however it is not the strongest argument and just as well, under no circumstance do we CHARGE money for anything. As well it would be rather difficult to call it an event, I don't intend to market it, we are talking about something mounted on the roof of a 3 story building and displayed. There is no crowd, there is no venue, there is no advertisement. To say that I cannot display a laser from my roof without the intention of fostering an event or something or the sort would seem to almost breach 1st amendment rights...

If you were to transmit a home made laser from your back porch into the sky it would be a legal activity. What if my home happens to be the 2nd floor of my commercial building???

On the other side of the FDA, I imagine if I purchased something such as this:

World Most Powerful 7 Watts 445nm 455nm 470nm Blue laser - The Striker series

The World's Most Powerful Blue Handheld Laser A Legit 7 Watts INSANE Laser Power This is the world's most powerful blue handheld laser as of 2020 You may see a 10-watt or even 100-watt laser on other websites, but those are over inflated power ratings. A 10-watt blue laser diode does not yet...

www.sanwulasers.com

It would be rather hard to argue that I constructed it, I have a receipt :O

I'll give you the Readers Digest version of what Encap wrote. When you use a laser for a commercial purpose you need a variance. No ifs, ands or buts. That is the law. I'm pretty sure your lawyer buddy won't be of much help.

 

[Encap]

I'll give you the Readers Digest version of what Encap wrote. When you use a laser for a commercial purpose you need a variance. No ifs, ands or buts. That is the law. I pretty sure your lawyer buddy won't be of much help.

What he said ^^^ .

Is pretty much the gist of it w/o the details or references.