The Variance Thread

[ElektroFreak]

In response to an ongoing issue some people have had with figuring out exactly where to start when trying to obtain a variance in the US, I'm starting this thread in the hopes that the members here who have been through the process would be able to help the rest of us by providing simple, easy to understand instructions on how to complete the process, along with any pointers they may have based on their experience.

There is much to be said for being legal and conducting legal shows, but it can be VERY difficult to find any easy-to-follow guidelines on the Government websites. There should be an easily accessible resource available to anyone that is seeking a variance that gives a rundown of where to start and the steps to follow and in what order.

Please, if you are a member here who has been through the process, help the rest of us by posting about your experiences here.

Thanks in advance on behalf of the rest of the US members!

(Apologies if there is already a thread dedicated to this specifically)

[gottaluvlasers]

1) download THIS
from my site.

I am running out right now and will respond in more detail later. but i made that file folder for easy access to pretty much everything that is needed for Laser variances in the U.S.

-Marc

[mikkojay]

I was wondering if someone were to make a projector, then go through all of the details of filling out the specs and send it though the paper mill, and get it approved...
Couldn't someone (or the same person) theoretically make a clone of this projector, as long as the same components, materials, dimensions, etc. were used, then make a copy of the variance request paperwork, bump the serial number by one, and be good for the most part?

I know that part of the fun is assembling a projector of your own is coming up with the design, arrangement, parts and pieces and all, but if the above scenario were possible, I wouldn't mind adhering to a predetermined recipe as long as I knew the paperwork would be a no-brainer.

It is probably not going to happen, but I could almost see a generic PL-approved generic projector design with a shopping list, cad files, dimensions, etc out on the FTP in a pdf file. In the same folder would be an accompanying pdf with 90% of the request form filled out with the technical specs of the projector. Everytime someone builds one, they make a donation to PL or the primary "original paperwork filler-outer" to get the next serial number.

The end result would be that you get a proven design, paperwork is easy, someone gets a "commision", and you get your legal piece of paper.
The only downside would be custom alterations that all of us love to do.

We could poll for the standard modules, etc. and call it the PL_RGB600 or something.

Is that crazy?

-Mike

[f22warzone]

I had an idea like that and was even answered their would still be a way to say place different lasers and all you have to do is summit a modification form of the original i think.... correct me if i am wrong

[ElektroFreak]

That sounds like a good idea potentially, but I don't know if it would work..

@gottaluvlasers: Thanks for the link! It's full of a lot of good info. Can't wait to hear more about your experience with variances.

[gottaluvlasers]

Ok, here goes-

"I was wondering if someone were to make a projector, then go through all of the details of filling out the specs and send it though the paper mill, and get it approved...
Couldn't someone (or the same person) theoretically make a clone of this projector, as long as the same components, materials, dimensions, etc. were used, then make a copy of the variance request paperwork, bump the serial number by one, and be good for the most part?"

Excellent questions. In essence, yes. this is what a "certified" projector like the LT1000 is. The LT1000 is pretty much the industry standard for certified enclosures. i use this, the LT2000 and the smaller LT500 for almost every single one of my builds.

This enclosure holds its own product report. The product report was completed MANY years ago. if memory serves me correctly, around 1987. and over the years has been ammended and updated many times. it is a "generic" product report meaning...

it was approved as a laser enclosure with its own variance number (90V-0382) providing that the end user builds the system to the approved variance specs. the original variance gives VERY broad guidlines:
(these are just examples. some may not be factual).

the system must contain (originally)
1. lasers from Coherent, Melles, SP, Uniphase (etc...etc...)
2. Powers up to 40W @wavelengths from 400something-600something.
3. Shutter(s)
4. key switches
5. emission indicators
6. labels.

Now- as long as the system you build does not modify any of the original guidelines to that variance, than you are using a certified enclosure. providing you obviously build your part of the system up to code.

if you decide that...you want to use a 1064 laser in this enclosure or a CO2 laser, well...now the system is no longer certified. it was only designed and approved for use as a visible light laser enclosure. so you would have to do a complete new product report becasue this would be considered a modification.

The enclosure itself, if being sold as a certified enclosure, must be sold with everything that made it certified:

shutter, labels, electronics, emmision indicator, key(s) switches and user manual must be included.

This is why ALL those foreign dingleberries that say their projectors are "FDA Certified" are completely full of CRAP!!! becasue part of a certified laser projector is also that it will not be sold to anyone who does not posess a Laser light show variance.

Now back to the LT1000-

this is pretty much exactly what youre talknig about mike. this projector enclosure is already certified. you buy it, put your components in it, do YOUR laser light show report and Application for a variance and boom...you have a laser light show variance.

you are paying a premium price for the leg work and pre-certification to already be done on these. the product report and certification process especially on higher power lasers takes anywhere from 2, 3 months to years!! (yes, years!)

Variance process if using a CERTIFIED projector (with an accession # and/or variance already like the above LT1000 example):

1) Fill out Laser Light Show report. (included in the file i posted earlier)
2) Fill out Variance Application (also included)

3) you will get an acknowlegement letter just saying, "we got your request...we'll let ya know!"
4) Approval letter. "Go ahead and lase the crap outta ravers and blind em!"

you guys can go here:

http://www.regulations.gov/search/Re...e+matchall&N=0

to look at some of my correspondences.

Mike-

your idea for a "generic" PL enclosure is brilliant! a collabortive (sp?) effort. a team of builders. a team of designers. a team of paperowork gurus.

it could very easily be completed!!! i think this needs to be pursued!!!

Variance process if NOT using a certified projector:

same as described above. however, you would need to do a product report prior to your laser light show reprt and prior to your variance application.

once the product report is completed you will get an accession # (or variance #) for that projector design to allow you to now bring it into commerce.

then proceed as explained above.

Questions welcome...

-Marc

[ElektroFreak]

Thanks for the excellent post!

If I'm not using a certified projector, then what defines if my laser sources are acceptable? If my Chinese laser has a power supply with the necessary safety features and interlocks, is that sufficient?

If my case is not a certified case, but one that I built/modified how does this affect things? The case has a hinged lid that covers the aperture. Does this count as a shutter?

If I make the case so that the key lock and emission indicator on the laser's power supply accessible from outside the case is this sufficient for certification?

Are there any particular requirements of the case aside from being able to contain the workings of the projector?

[sugeek]

...

Thank you Marc you are a great resource, and we appreciate you sharing your knowledge!

-Adam

[photon fondler]

Ok, here goes-
your idea for a "generic" PL enclosure is brilliant! a collabortive (sp?) effort. a team of builders. a team of designers. a team of paperowork gurus.

it could very easily be completed!!! i think this needs to be pursued!!!

-Marc

I'm in,the LT1000 is a bit pricey.

I build pretty much the same thing for like $500, although much time is spent on taping my breadboards,machining slots and what not which is probably why the hefty price tag.Saving like 600 bucks is must for a guy who turns around with the money earned and puts it back into lasers.

[mixedgas]

[QUOTE=mikkojay;122995]I was wondering if someone were to make a projector, then go through all of the details of filling out the specs and send it though the paper mill, and get it approved...
Couldn't someone (or the same person) theoretically make a clone of this projector, as long as the same components, materials, dimensions, etc. were used, then make a copy of the variance request paperwork, bump the serial number by one, and be good for the most part?
Quote
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I'm gonna play devils advocate here for a minute....

The gov does not like or did not like "KITS" in the past. That scheme is close to being a kit.
The question is how much error or deviation will the government tolerate.

I think Each user has to generate their own serial numbers and do their own Quality Control work and manufacturers report. You can't have a PL serial number or model number series. If two users specified the same model and serial, confusion would rain. The fear is too many people would just send in a unmodded copy without doing the manufacturing tests. That would tick off some folks in the government for sure.

Also when you specify exact parts, you LOCK yourself into those parts.
Ie if you spec a GM20 as a shutter, it has to be a GM20.

Its not always simple.

Wording like, " A spring return shutter Same as or similar to a "General Scanning GM20 or Ledex Model xxxx" is used so you can change parts.
That is a little tricky to get right.

Drawings are often black boxes with the function specified but NOT the internals. Because if you make a change or replace a part later, you don't want to have to refile or amend. This could make it hard for a person filing to use the same wording. Or you specify a LEDTRONIC led and the guy filing uses a radio shack part.
Certain things are specified like the interlock loop diagram.

If you do it, and they get a pile of reports where they suspect there is NO QC, or lousey workmanship, Ie just a copy of the paperwork with no changes, is somebody is gonna start rejecting each new duplicate application without looking at them?

How do you make sure there is no shoddy work to bias them against the clones?

How are you going to handle external lasers, external effects, beam tables, fiber feeds etc?

That box pretty much locks you into a DPSS system that fits in the box! What if a user needs to run a argon? So your making a "Industry Standard Projector" functionality.

What happens if they find a fault and recall one of them? Do all users get recalled?

Therefore it would be best to CALL CDRH and get clearance to do this beforehand so they know whats up?. That way a acceptable standard of QC can be maintained with respect to safety features.

How ticked off are you going to be when some shoddy overseas maker uses the PL standard paperwork and then screws something up?

How ticked are you going to be when someone starts selling this paperwork with a blank Insert name here block?

How ticked are they going to be when they get 100 unchanged applications for 40 watts of 532?


Steve