CDRH does not require measurement under single fault conditions.  They do
require that you submit a report for your laser product which is the laser
device within the end-system.  I don't know if your NRTL will accept the
device's CDRH report as part of your safety submittal or if they will want
the CDRH report for the end-product.

For the CE Mark, EN60825-1 requires single fault measurements and
specifically states that the system be classified.

Jack

-----Original Message-----
From: Gary McInturff [mailto:[email protected]]
Sent: Tuesday, October 31, 2000 3:20 PM
To: EMC-PSTC (E-mail)
Subject: Laser Sanity check.



        Has anyone out there successfully got a piece of equipment which
utilizes a class 1 laser,  through UL without the laser manufacturer either
recognizing the component itself or the manufacturer sending UL a copy of
the CDRH report to UL for review? Possibly a VDE or TUV certificate for an
IEC-825 evaluation.


        Here is what I believe (and this refers only to a UL submittal not
one of the various other NRTL's)
        Without a UL being able to verify the laser as class 1, and class 1
under at least a single fault condition, I can't use it in a Listed end
product.
        The possibilities are that the I have the manufacturer send a copy
of the CDRH report to UL. That with the appropriate plastics and PCB and UL
will recognize it.
        Alternately, they will allow it as an unrecognized component if they
have the proof of class 1, again from the CDRH report, and an examination of
the plastics etc, and possible some additional testing.
        Because I don't control the manufacture and design of the report I
doubt that I could just submit the laser transceivers themselves and have
them investigated and approved for use in my end product.

        Like I said, that is what I believe, and I believe after using these
things for awhile and asking UL directly about it but two small vendors not
knowing anything about this make me question my understanding. Has anybody
done it differently?
        Fill me with better knowledge oh wise and powerful Oracles.
        Thanks
        Gary
        

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