Amendments to the CDRH federal performance standard for laser products a status report

Abstract

Federal law requires that all laser products that are imported into or introduced into commerce in the United States comply with the performance standard published in the Code of Federal Regulations (CFR), Title 21, Parts 1040.10 and 1040.11, administered by the Center for Devices and Radiological Health, U.S. Food and Drug Administration. Although it contains somewhat different requirements for hazard classification, engineering controls and labeling, the ANSI Z136.1 standard defers to the CDRH standard. The CDRH standard first became effective in August, 1976 and has twice been amended, in 1978 and in 1985.In the early 1990s, U.S. experts met to formulate an approach to bring the requirements of the CDRH standard and those of the International Electrotechnical Commission (IEC) standard, IEC 825 into closer agreement in order to lower barriers to international trade and to remove any excessive compliance burdens on manufacturers. In 1993, the CDRH published, formally in the Federal Register and informally, a Notice of Intent to amend the CDRH standard. Responses to those notices have now been analyzed and informal draft amendments were distributed in 1996. This draft is now being prepared for formal issuance as a Notice of Proposed Rulemaking.Meanwhile, the IEC standard was amended in 1993 and republished as IEC 825-1; these amendments were met with considerable controversy since they resulted in over classification of the hazard of many products, especially light emitting diodes (LEDs) that have large divergence and increased source dimensions. Additional amendments are now being developed to correct this problem. The CDRH has carefully monitored developments in the IEC and actively participated in its proceedings as a guide in developing its own proposal.This paper describes the major changes that are being proposed for the CDRH standard and presents some rationale for the major changes. The more significant changes include expansion of applicability to include LEDs, reduced emission durations for classification, revised measurement procedures for hazard classification, reduced performance requirements for lower power visible radiation products, and revised requirements for medical products.Federal law requires that all laser products that are imported into or introduced into commerce in the United States comply with the performance standard published in the Code of Federal Regulations (CFR), Title 21, Parts 1040.10 and 1040.11, administered by the Center for Devices and Radiological Health, U.S. Food and Drug Administration. Although it contains somewhat different requirements for hazard classification, engineering controls and labeling, the ANSI Z136.1 standard defers to the CDRH standard. The CDRH standard first became effective in August, 1976 and has twice been amended, in 1978 and in 1985.In the early 1990s, U.S. experts met to formulate an approach to bring the requirements of the CDRH standard and those of the International Electrotechnical Commission (IEC) standard, IEC 825 into closer agreement in order to lower barriers to international trade and to remove any excessive compliance burdens on manufacturers. In 1993, the CDRH published, formally in the Federal Register and informall...