Boy the waters are murky sometimes. Next up on the "I don't understand" list....
I present the manual for the Chauvet Scorpion GBC: http://www.chauvetlighting.com/produ...M_Rev08_WO.pdf for your reading pleasure.
This is a readily available, "buy without a varience", Class 3a projector. 30mW 532 and 40 mW 473. They state it's "classified per 21 CFR 1040.10 and .11." That also say it "complies with US FDA CDRH Laser safety standards 21 CFR 1040.10 and .11" In one area, I see where they claim "fat beam" technology but who knows. Maybe that's how they got the product itself approved or, how it is the public in the US can just buy and use it. Or... did they build it in such a way that it wasn't submitted and approved at all?
Some of the things that don't make sense is they claim on the safety labels that the "power of each beam at aperture is <5mW 473nm and 532nm 300m Sec CW" supposedly *As measured under IEC measurement conditions for classification. (Huh?)
The next thing concerns "interlocked housing". O.k. so, CDRH wants the housing of a projector to have interlocks which would turn off the lasers if a lid or cover is off. I gather that these do not have them and it states in the owners manual,
"Non Interlocked Housing Warning
This unit contains high power laser devices internally.
Do not open the laser housing, due to potential exposure to unsafe levels of laser radiation.
The laser power levels, accessible if the unit is opened, can cause instant blindness, skin
burns, and fires."
So, by putting this in an owners manual, is that an acceptable form of getting around having interlocks installed? I already kind of understand that, if I build the projector and, am the owner and the end user, that interlocks are kind of silly since they'd only be there to protect myself from myself. I think the disclaimer sticker "No user serviceable parts inside." has been debated about being successfully used by some as well.
There is also a bunch of other warnings in the manual regarding safety and it being illegal to point it into an audience. They give the cursory 3 meters above and, 3 meters horizontal separation warning. Yada, yada, yada...
I'm not blasting Chavet. I like their stuff. I OWN a lot of their stuff. I'm just trying to figure out what THEY do to navigate CDRH with new products.
So... Is the way to get around a lot of this stuff simply writing a manual?
What's prompting this is that next up on my "to work on" projects is getting my currently US non legal projectors, legal. I understand I'll need to create a product report in order to do that and thus call myself the "manufacturer". Does writing a good owners manual circumvent some of the things such as interlocks that are supposedly necessary then?
Chauvet has more money that I do.... does that, um, play into these things perhaps??