buffo
Laser light show variance from the CDRH in record time
Hey guys;
How many of you are frustrated with the long and complicated process of getting your laser light show variance from the CDRH? If you'd like to know about a very cool solution that could get you your variance in less than a month, read on:
I'm sure a lot of you read my post about X-Laser back in 2010. (If not, here's a link.) Basically, that post was the result of a visit to Washington DC, where I met Dan and his father, and was allowed to tour the X-laser facility and ask lots of questions. It stemmed from some skepticism on my part (and many other PL members) concerning some of the claims that Dan had made here in the forum. I just had to see it for myself before I could believe some of the things he was saying. And if you read that post from 2 years ago, you'll see that I was very impressed with their operation, and I also retracted the skeptical comments I had made prior to my visit.
I thought I had a pretty good handle on how everything worked at X-laser, but evidently I missed something very important regarding their E-Z Variance Package. My recent revelations regarding this product are the subject of this post.
For those of you who are unfamiliar with the E-Z Variance Package, here's how it works: You purchase an X-laser projector, and for an extra $49 they send you a gift card that contains a code you can use to log in to their secure E-sign website for variance applications. This is basically a portal that links you to X-laser, and it also has back-end widgets that link you to a secure digital e-signature service. So once you've gone through the training presentations that come on the CD-ROM that was included with your projector, you can use this code to go on-line and file for your CDRH laser light show variance. (Bear in mind that the training is designed for someone that knows nothing about lasers or the CDRH. Most of it will be a simple review for the average PL member!)
Once you go on-line, the website asks you a few simple questions: Name, Address, Phone Number, Company Name, and then two very important pieces of information: The serial number of your X-laser projector, and the code on the E-Z variance package. This information is then compared with their records at X-laser, and if they verify that you did in fact purchase that serial number, the site allows you to continue. (Otherwise, you are bounced out and you have to contact X-laser to be reset.)
Once you are verified, the site asks you to affirm that you have completed and that you understand the training that came on the CD-ROM, and then they ask you to affirm that you will abide by a series of general safety rules (including never allowing an untrained operator to use the projector, never having beams less than 3 meters off the highest point in the audience where someone could stand, etc...). Once you have checked yes to these items, the website generates your variance application right then. However, many non-safety related areas are blacked-out and can not be seen by you. These areas are filled in by some of the back-end code running on X-laser's website; they contain specific information about X-laser's products as well as key files and checksums that the CDRH can use to verify that the submission is valid and came straight from X-laser's secure site. (They black these parts out both to protect their investment in the e- sign technology and to prevent people from submitting fraudulent variance applications without having an X-laser projector purchase.)
When the variance form is all finished, the website asks you to electronically sign the document in two places. This is as simple as typing in your name in two text boxes on the side of the page, but behind the scenes there is special code running to verify that this is a valid e-signature. The CDRH has agreed to accept this system in leu of a paper copy document with a real signature on it, though I believe X-laser is the only company that has a system like this that the CDRH has approved.
Anyway, once you sign the application and hit the submit button, you are done. The form is sent to the CDRH, along with all the E-signature stuff needed to validate it. The entire process takes about 3 minutes on-line, and you should have your variance in less than a month. (Many X-laser customers have been getting their variances in just 2 weeks!) So far, this sounds really good, but the best part is something I left out.
The variance you receive will be a virtually unlimited Class IV variance that is valid for any certified laser projector, for all venues (including outdoor shows, assuming you have an FAA letter of non-objection), for all show types and durations. The only thing that you can't do is audience scanning, mirrored ball scanning, and holographic element use. (Those last two are basically the same as audience scanning in the sense that beams end up going into the audience.) Otherwise, it's the full-meal deal.
The X-Laser website states that the variance kit only works for X-Laser products. However, this is not actually true. A variance is a variance; thus it cane be used for just about any certified projector that has been manufactured under a manufacturer’s variance. The reason X-laser tells their customers that the variance is limited is because their target market is not very savvy when it comes to the CDRH regulations; X-laser doesn't want people thinking that once they have a variance they can buy some cheap non-compliant (and illegally imported) projector off E-bay and legally use it for commercial shows. It's basically a liability issue for X-laser. They can't hope to educate all their customers on the difference between a certified projector and an illegal one, so they just tell them that the variance is only good for X-laser projectors. (Which are of course certified.)
But here's the key: If you have another projector that is certified but you don't yet have your laser light show variance, all you need to to is purchase an X-laser projector along with one of their E-Z variance kits. Then you'll have your laser light show variance in less than a month, and you'll be able to use it with both projectors! What's more, now that you have your light show variance, you can rent projectors from other laserists (provided the projectors are certified) and use them with your variance. Even if all you purchase is a Class 3B projector (say, a 150 mw green-only projector) from X-laser, the variance you receive will be good for all lasers, including high power class IV monsters up to 20W CW.
The best part is that because of the portal they've set up with the CDRH, X-laser can get you your variance in record time. They tell their customers that it will be less than a month, but as I mentioned above, many of their customers are getting their paperwork back from the CDRH in 2 weeks or less. How cool is that?
So for the cost of another projector plus a measly $49, you could be legal by the end of the month, instead of waiting until next year. Sound cool? Yeah, I thought so too! Which is why I'm posting all this now. (A few of you got a phone call about this over the weekend, but I finally found the time to type this all out so everyone could see it.)
If you doubt what I'm saying, pick up the phone and give Dan a call over at X-laser. (Warning: they are in the process of moving to a new office, so he's going to be busy! Don't be surprised if you have to leave a message...) But talk with Dan if you don't believe me. And then sit back and think about how long you want to wait for your
variance...
Adam
Reply With Quote
Originally Posted by buffo
Really, anyone is free to tackle the CDRH / FDA, and.. do (essentially) the same thing, for themselves.. ..But, Kudos to X-L, for taking it all to-task / bloodying their knuckles, and - really - effectively eliminating *all* the 'excuses', not to 'be legal' *coff*Allen*coff* 
....and armed only with his trusty 21 Zorgawatt KTiOPO4...
jk.. 
