We had to supply accession numbers for all of the lasers used in our
equipment and submit a copy of our FDA report to satisfy UL. For CB, we have
to provide certificates for each laser against EN60825 - this is more
difficult, as some European component manufacturers are self-declaring,
meaning a full assessment of the component is required.

Dave Wilson

 -----Original Message-----
From:   Kenneth McCormick [mailto:[email protected]] 
Sent:   Monday, November 20, 2000 3:08 PM
To:     [email protected]
Subject:        Lasers in ITE Equipment


I am working with a client who has posed a question that I am not sure that 
I can accurately answer.

What are the NRTLs (and for that matter, other test laboratories) requiring 
for Laser Certifications.  Annex NAE of UL1950/CSA C22.2 No 950 is an 
INFORMATIVE annex(and mentions the regultory requirements of a CDRH Report 
in US and a REDR in Canada), however Clause 4.3.12 leads me to believe that 
proof of compliance with these regulatory requirements is REQUIRED by the 
standard. With EN60950, compliance with IEC825 is required by clause 4.3.12.

Are the certifying laboratories witholding certification until the 
manufacturer can show compliance with the applicable requirements, or are 
they simply stating that compliance with the applicable laser requirements 
is the responsibility of the manufacturer?  If they are holding 
certification, what proof will typically meet their requirements?  Will 
documentation showing that the application has been submitted to the CDRH 
suffice, or do they typically require the final reports and approval issued 
by CDRH? What laser markings, if any, are these laboratories requiring in 
their compliance reports?

Is anyone aware of some documents that summarize the requirements of the CFR

& IEC825?

Thank you in advance,
Kenneth
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