LEDs were brought into the IEC 825-1 standard since the optical hazard from some LED devices approached or exceeded those for lasers covered by the standard.
To eliminate the need for classification or testing of products containing low power LEDs, when LEDs were added to the standard the Scope of the document was revised to state: "Any laser product or LED product is exempt from all further requirements of this part 1 [meaning IEC 825-1] if classification by the manufacturer [meaning the LED component manufacturer] according to clauses 3, 8, and 9 shows that the emission level does not exceed the AEL of Class 1 under all conditions of operation, maintenance, service, or failure." Thus if a product included only LED components that have been certified as Class 1 by the component manufacturers, no action with respect to IEC 825-1 need be taken by the product manufacturer. I have heard that some test houses are not willing to accept the component manufacturer's certification on the LED - if that is a widely adopted policy, it would certainly defeat the intent of those of us on the IEC TC76 committee when we adopted the wording to specifically exempt low power LEDs. The changes that were included in the A11 amendment to EN60825-1 will make it easier to classify some harmless LEDs as Class 1. A similar (but not identical) change is in the voting process for IEC 825-1 and is expected to be adopted later this year. Also under consideration is a proposal to expand Class 1 to include measurements made under more realistic conditions, but that will be about 2 years away. Other approaches are also being considered within the TC76 committee to reduce the requirements for indicator LEDs. It is also worth noting that the U.S. CDRH has proposed to amend their laser safety standard to harmonize with IEC 825-1. The proposal [informal as of this date] is to also include LEDs, although the proposed measurement criteria would be made under realistic conditions. Bob Weiner Weiner Associates
