EN 60825-1:2007 and other Safety Legislation/Guidance

I notice quite often there appears to be some confusion over what EN 60825-1:2007 is and where it fits in among EU legislation, so I’m taking a moment to try and summarise its purpose and that of the other laser related legislation and guidance in the EU.

Even with many of the professional show providers I regularly come across when assessing show safety, there is some confusion over what EN 60825-1:2007 is about, and very little awareness of other laser related legislation, so hopefully a few of those who I am sure lurk here, will pick up a tip or two.

EN 60825-1:2007 the Product Safety Standard
IEC 60825-1, EN 60825-1, BS EN 60825-1, what do they mean? Primarily, they are product safety standards. And in practice the prefix to the 60825-1 makes little difference to their content.

The people that actually write the standard are a committee within the IEC (International Electrotechnical Commission), made up of representatives from different nations around the world. This committee works continually at gradually evolving the standard by holding several meetings a year, with aim to publish updates normally every 5-6 years. The document they produce is prefixed by the IEC designation.

The supply of any goods within the European Community requires that a ‘CE’ mark is placed on the product, and that a ‘Declaration of Conformity’ is provided by the supplier of the product. (Note the legal responsibility for this falls on the supplier, not the manufacturer, as many assume. i.e. that means the legal obligation to declare conformity falls on the supplier of a product being imported from outside the EU, not the factory in China for example.)

The ‘CE’ mark is intended to demonstrate that a product meets the minimum safety requirements for supply in European member states. Now this is where IEC 60825-1:2007 comes into play… The EC has adopted the IEC standard as it own ‘EN’ standard, which gets published in the EU Journal. Because the standard has become adopted it is prefixed with an EN, so becomes EN 60825-1:2007. In essence however, the two documents contain the same information.

What does change however is that the document takes on a new legal status and becomes a ‘Harmonised Standard’. Such harmonised standards, published in the EU journal, state the minimum safety features a product must incorporate to demonstrate safety compliance, and therefore be fit to have a ‘CE’ mark placed on them.

i.e. EN 60825-1:2007 describes how a laser product should be classified, (Class 1, Class 4 etc), and what product features are needed, based on the classification, in order for it to have a CE mark placed on it.

Individual Member States may additionally adopt the EN standard by adding their own designation to the EN standard, such as in the UK where the ‘British Standard’ is described as BS EN 60825-1:2007. In Germany they use DE, etc.

So in summary EN 60826-1:2007 is nothing more than a product safety standard. It does not tell people how to do shows or work with lasers safely (as I often see people write in their method statements etc).

User Guidance
Guidance for the safe use of lasers is provided in several other IEC originating documents. Of specific interest to the laser show operator is IEC/TR 60825-3:2008 Guidance for Laser Displays and Shows and IEC/TR 60825-14:2004 A User’s Guide.

The first document is very useful and has been written, as the title suggests, with the laser show user in mind. The second document is still worth a read if you are serious about laser safety, but it is more orientated towards laser applications that isolate laser radiation.

In the UK we have our own 30 page guidance document published by the Health and Safety Executive (HSE) that is commonly referred to by its publication number HS(G)95.

All of these guidance documents are just that…, guidance. So it is not mandatory to follow what is set out in them. However, as published H&S guidance from a government agency, and through the British Standards Institute (PD IEC/TR 60825-3:2008 and PD IEC/TR 60825-14:2004), it is difficult guidance to ignore, and that which most venues, insurance companies, and enforcement agencies expect as a minimum.

Specific Legislation on Laser Usage?
Over the past year there has been some talk of specific legislation affecting the use of lasers in Europe. This came about as a result of EC Directive 2006/25/EC known as the Physical Agents (Artificial Optical Radiation) Directive or shortened to AORD. The purpose of the Directive is to provide a minimum level of protection for workers with the potential to be exposed to harmful levels of artificial optical radiation, across the whole of the European Union.

The Directive was to be implemented by each of the EU’s member states as local law by the end of April 2010. In the UK we have the Directive transposed to UK law through the Control of Artificial Optical Radiation at Work Regulations 2010, which is available from HSE’s website. Other EU member states will have their own legislation in place now too.

The Directive requires that all member states make legal provision to oblige employers to assess and limit worker exposure to harmful levels of optical radiation. It sets, as legal limits, the amount of optical radiation workers can be exposed to. These limits are now the same across the whole of the EU, which are based on the ICNIRP laser exposure limits previously used for MPE assessment.

ILDA 10x MPE Guidance
What of ILDA’s 10x MPE Guidance? – This is a bit of a tricky one… In reality there is ‘probably’ not a significant chance of causing a major injury to a person if they are exposed to laser radiation that 10x the MPE. However to state that you are deliberately exposing people to 10x what are, in Europe, legal limits is not without problem too. For technically it is now a criminal offence to expose a worker to laser radiation above the MPE. So bang goes any insurance cover, and you could run the risk of criminal prosecution. :(

If you’ve made it this far down the post, thank you for reading, and I hope you found it of use!

Best regards

James Stewart
LVR Limited

Sir James -

Excellent-info - thanks for the effort.. :cool::)

Do us a 'flavor'? Please, if you would, whenever you get the chance, create a 'Topic', in the "PL SafetyWiki", here: http://www.photonlexicon.com/wiki/in...itle=Main_Page ...and create a 'Topic' on the Main Page, there, and link-it to a 'Sub-Page', (rather than posting this all on the 'Main Page') with all this 'expanded info' in-it... (...if you have questions on how to do that, you can always PM admin, tho it's pretty-easy...) :cool:

This will ensure that this excellent info will always be easily, and quickly accessible, here in PL, and, probably most-importantly, *searchable* and 'living' as it evolves... :cool:

Most-excellent of-you, Sire... :)
cheers..
j

I'm unfortunate enough to be in a position were I deal with H&S regs and law as a large part of my job and British H&S law is very contentious by design.

What this essentially means is many things are not unlawful until somebody gets hurt.

Example one:

An employer sends an operative to a job to change a fuse, the panel is 10' high so the operative climbs a ladder and changes the fuse; job done no laws broken, everybody's happy.

Next day the same kind of job comes along, the operative climbs the ladder, but this time he loses his footing, falls, breaks his neck and dies.

Now the employer is in deep shit.

There is no law that says you can't use a ladder for a simple task like that but there is guidance that says the employer must use the safest means of access and here's the HSE's favourite catchphrase 'So far as is reasonably practicable'

Now in court you can try to defend yourself all you like but there's no getting away from the fact that a man's life is worth more than the cost of hiring a podium step or a portable tower. It was therefore 'reasonably practicable' to spend £40 to hire one, you have therefore been negligent, broken the law and are going to jail.

Most H&S law in the UK is based on common, not statute law and is extremely contentious.

I see the same applying with lasers, no laws are broken until somebody gets hurt, then it's time to break out the Savlon, your arse is going to be stinging.

Thanks for the info. In my experience in the nuclear, ionizing radiation field, I've found the British to be very safety conscious. So much so that they are apt to label a window with a sign bearing the word "window" or a stair case with a sign bearing the words "caution, stair". After reading this post I'm wondering if you could use the 10X MPE formulation in a light show if the light show company had employees working the show. In effect, they would be "at work" and subject to the Health and Safety Executive ("HSE") limits. Perhaps this could be solved by O.D. = 1 laser safety glasses.

Quote:

---

Originally Posted by RayTracer

Thanks for the info. In my experience in the nuclear, ionizing radiation field, I've found the British to be very safety conscious. So much so that they are apt to label a window with a sign bearing the word "window" or a stair case with a sign bearing the words "caution, stair".

---

True, they stopped just short of slapping a sticker 'Caution, solid object. Obstacle hazard' on any object that could possibly be positioned in a human path.

I guess they just ran out of those stickers. *retardo

On the laser safety front, I do wonder how we would ever make a trade-off between 'safe scanning' (under MPE per AORD) and creating spectacular shows. After all, audience scanning under MPE is not going to produce any visible effects for the audience, making it useless altogether.

Overhead shows aren't everything here. In the EU, people are pretty much expecting lasers to 'touch' them, and a show that does not do so (because it wants to stick to the law) becomes disappointing and the show company in question won't last long.

@dsli john – will put this in the wiki when I get a moment to take a look at how to move it over.

@Doc, you are right in the sense that UK H&S legislation is deliberately non-prescriptive. And that is for good reason, to prevent limiting how work tasks should be carried out, (and the more cynical would say it also removes the liability issues). But it is not quite right to say that most UK H&S is based on common law, for it is statute legislation that underpins the H&S regulations in this country.

The ICNIRP exposure limit figures, which have previously been seen as ‘guidance’ by HSE, are now mandatory limits; they are written into statute law, and to state that you are exceeding them, when people at work could be exposed, means you are stating that you are committing a regulatory offence, if it is foreseeable that the workers could be exposed to the laser radiation.

In a typical scenario where lasers will be used for entertainment, it is likely that there could be security, stewarding, vendors and bar staff present. These people have the same rights as any other worker not to be exposed to harmful agents. If the law makers have deemed that 1 x the MPE (or ELV to give it is up to date term), then, like it or not, that is what statute considers to be harmful.

So in this instance, if you are working in club, and laser beams are hitting the bar staff, even if the exposure is set to 10x MPE, a regulatory (criminal) offence is being committed. And playing devil’s advocate, if an employee wanted to make a claim against the venue, they would be in a strong position to pursue it.

As I said, 10x the MPE in itself is, in my view unlikely, to pose a significant health risk to a person exposed to it. But if it is stated as being in someone’s safety policy as being the figure used, they are leaving themselves open, in the case of scrutiny.

(This is an area I think ILDA has really failed its membership. Why was it last year when I asked ILDA members on routine laser inspections, very few knew anything of the new European legislation? – It could be argued that the individual laser businesses have a duty to keep themselves well informed on new legislation, but surely is that not a benefit of belonging to a trade association? which is supposed to have its finger on the pulse. This directive came about in 2006, so there has been plenty of time for ILDA to get on board, and try and help influence its implementation. And in what would seem to add insult to the situation, the organisation that suggests the 10x figure to its members, at the time the 1x MPE is made a legal requirement over Europe. I suppose the EU region is not important outside being outside of the US. (rant over!))

So to summarise, specific risk assessment and avoiding exposing workers to laser radiation to levels greater than those defined in the EU directive are, like it or not, regulatory requirements, and statute law.

@Stoney3K – it is possible to make quite dramatic laser effects that touch an audience, and are under 1x MPE (sometimes significantly so). People have however got to move away from just buying software and plugging it into a box containing a highly collimated beam that waggles with two mirrors.

Quote:

---

Originally Posted by JStewart

@Stoney3K – it is possible to make quite dramatic laser effects that touch an audience, and are under 1x MPE (sometimes significantly so). People have however got to move away from just buying software and plugging it into a box containing a highly collimated beam that waggles with two mirrors.

---

(For the record, I didn't mean 'emotionally touch', rather 'occupy the same personal space as said audience member', e.g. physically touch.)

You will have to be more specific though. One of the essential properties of a laser effect is that it uses a coherent beam which (because of its coherence) can be highly collimated. Otherwise we'd be making pencil beams ans mm-flat liquid ceilings with a gas discharge bulb shot through a gobo, which doesn't really work.

If you're referring to things like diffraction grating and lumia effects, I can vote for the former, but how much different is the latter from any other 'projector' which shoots psychedelic effects into the audience, for example, an oil projector with a 500W lamp? Shooting lumia looks cool, but your laser's coherence is completely killed, nulling the entire point of using a laser for it.

I can also do audience scanning beam shows with a 10K lumens HD video projector pointed straight at the crowd. There's absolutely no regulation on that, and I can assure you those things are more than a bit brighter than a 445nm with a moving beam.

Visible beams, to an audience, says 'laser'. MPE and visible beams are mutually exclusive, unless you happen to be in a fog-storm.

Quote:

---

Originally Posted by Stoney3K

One of the essential properties of a laser effect is that it uses a coherent beam which (because of its coherence) can be highly collimated.

---

You're forgetting the 'energy-density-balancing factor' of beam diameter... ie: you can have plenty-well collimated, very solid-looking beams, at larger, 'eye-safer' beam-diameters, to satisfy the energy-density-parameters of MPE-limits, and this is just one way that many of the EU safe-show experts 'push' that MPE-level envelope.

Quote:

---

Originally Posted by Stoney3K

I can also do audience scanning beam shows with a 10K lumens HD video projector pointed straight at the crowd. There's absolutely no regulation on that, and I can assure you those things are more than a bit brighter than a 445nm with a moving beam.

---

Mmmeeaah, I think you gotta do some 'brush-up reading' on energy-density, buddy... :)

The 'issue' with lasers is how much energy-density there-is, in a given 'area'. As-that relates to laser-safety, what-then 'matters-most' is how much of it is entering a human-pupil (since most-shows will not have people close-enough to lasers to worry about 'skin-burn hazards'..) - which is 'typically' gauged at 7mm - even more of a concern at a 'typical rave' / concert where, potentially, many people will have greater 'drug-induced' dialation...some, reportedly even 14-15mm + (therefore, 'more' of the extremely 'dense' laser light can enter the eye)...but from the law's standpoint, they don't factor that-in, just how much 'energy-density', overall, is proposed to-be shot into peoples-eyes...

Which, again, yes, circles-back to 'offsetting' factors such as beam-dia. / divergence, etc, etc... But, in the case of, say, 10W of collimated 445 (which introduces other 'concerning-factors', due to the *color* of the light), even with a 'fairly-large' beam, say, 15mm, there will most-certainly be a 'greater eye-safety concern' from the laser-source, vs your 10K lumen projector-example...again, due-to 'energy-density'... :cool:

I 'hear' what you're saying - believe me, we (here in the US) *know* the 'pains' of too-low an accepted-MPE for creating 'effective' immersive-fx in-shows, but, as James said, it most-certainly is possible to have laser-fx be 'effective, yet safe'... It's a 'mad laser-skills thang'... :D

cheers...
j

Quote:

---

Originally Posted by dsli_jon

You're forgetting the 'energy-density-balancing factor' of beam diameter... ie: you can have plenty-well collimated, very solid-looking beams, at larger, 'eye-safer' beam-diameters, to satisfy the energy-density-parameters of MPE-limits, and this is just one way that many of the EU safe-show experts 'push' that MPE-level envelope.

---

Yes, but as I said, that would be voiding the point of using a laser for it. I can create an 8" solid-looking beam from a gas moving head or profile spot without any trouble, but it would be less impressive than the razor-thin effects audiences expect from lasers.

The problem is not that there is no technical means by which we can create safer shows, but the issue is more that audience's expectations (in Europe) don't want us to. If you run a safe show, sure, you won't get sued, but your club stays empty next time and you'll go bankrupt anyway.

Quote:

---

Which, again, yes, circles-back to 'offsetting' factors such as beam-dia. / divergence, etc, etc... But, in the case of, say, 10W of collimated 445 (which introduces other 'concerning-factors', due to the *color* of the light), even with a 'fairly-large' beam, say, 15mm, there will most-certainly be a 'greater eye-safety concern' from the laser-source, vs your 10K lumen projector-example...again, due-to 'energy-density'... :cool:

---

I deliberately used that 10K lumen projector as an example because it too, would present a possible eye hazard when viewed directly. Those things are usually powered by gas discharge lamps of 500W to 1kW, and if you do the raw math, you'd find that projecting a narrow beam from them would put them in the danger zone. 1200W HMI follow-spots have the same problem.

Just some calculations on that front:

Assume a simple gas discharge spot with a 500W gas lamp. Luminous efficacy about 5%, including optical losses throughout the fixture, totalling about 25W of pure light (full visible spectrum) at the aperture.

Now if such a spot would project a 12" (300mm) cirular beam into the audience, the irradiance would be 353W/m2. In comparison, the sun is about 120-150W/m2.

So there's a reason I don't like staring into video projectors, just as I wouldn't stare into the sun. ;)

*yawn*... sorry, werking very late, so I'll respond a bit...

Quote:

---

Originally Posted by Stoney3K

...I can create an 8" solid-looking beam from a gas moving head or profile spot without any trouble, but it would be less impressive than the razor-thin effects audiences expect from lasers.

---

8"?? lol, when I said "very solid-looking beams, at larger, 'eye-safer' beam-diameters" I wasn't thinking 'hyperbole'... :) I'm talking, like taking a 5mm beam, and making it 10 or 15mm - that will still look like a 'kickin-beam' in a large, 'long-throw' venue, and, yet, be 'safer' from an energy-density-standpoint, than the 5mm-beam will...

Quote:

---

Originally Posted by Stoney3K

If you run a safe show, sure, you won't get sued, but your club stays empty next time and you'll go bankrupt anyway.

---

You'd make a very-fine Texan, Stoney... *retardo JK, my Texas-brethren,

Attachment 22934 :)

...but, clearly, there are plenty of EU Sho Co's that can prove that it's not necessary to 'skirt the line' to make a great-looking, immersive-yet-safe show... Granted, there certainly have-been some shows, over there, that *looked* mighty un-safeish... but, trying to 'judge laser-safety via YouTube video' is a piss-poor method, at best... not exactly 'accurate'... :)

Quote:

---

Originally Posted by Stoney3K

I deliberately used that 10K lumen projector as an example because it too, would present a possible eye hazard when viewed directly.

---

Sure, however...

Quote:

---

Originally Posted by Stoney3K

Assume a simple gas discharge spot with a 500W gas lamp. Luminous efficacy about 5%, including optical losses throughout the fixture, totalling about 25W of pure light (full visible spectrum) at the aperture.

Now if such a spot would project a 12" (300mm) cirular beam into the audience, the irradiance would be 353W/m2. In comparison, the sun is about 120-150W/m2.

---

Umm, how are you accounting for distance to your 'sampling-point', in "the audience"? What you need to do is, for the sake of 'hypothesizing this', pick a 'distance' from your light-source, to the 'meter', base the 'sampling area' on a 7mm aperture, and *then* we can start to compare energy-densities of, say, that 10K vs 10W of 445 (or whatever) as it relates to 'eye-safety' on retinas... [popcorn]

I'm not in any-way 'contesting' that such a light, in your example, would not be 'unpleasant' to look at - possibly even marginally-hazardous, as-if you stared into the sun, for a bit... But, I'm pretty-sure, even without fully hardcoring-thru the math, here, that both the energy-density, and the 'ocular hazard' will be exponentially-higher, from the laser-source, in this discussion... :cool:

In-all, James 'point' still stands: "People have however got to move away from just buying software and plugging it into a box containing a highly collimated beam that waggles with two mirrors" - yep, no substitute for good, old fashioned methodology vs assumption... :cool:

cheers, I'm off to Pillowlandia... :)
j