Hi, Peter.

Since a phototransistor is not an emitter, classification should be 
unnecessary.  There must be something else involved or its classification is as 
part of a system that includes an emitter.  I wonder if it's mislabeled.

The FDA does have requirements for quality control systems, which are typically 
required at the time a report is submitted to the FDA for review.  Pretty 
loose, but the expectation is that your company does whatever is necessary to 
ensure the certified laser class is not exceeded, which can include receiving 
inspection activities.  However, unless your company is the certifier of the 
product, your obligations are limited.

Refer to 21CFR, §1002 at

http://www.fda.gov/cdrh/comp/eprc.html

and

http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfTopic/topicindex/topindx.cfm?alpha=l

(scroll down to the section on lasers for scads of information)


Regards,

Peter L. Tarver, PE
[email protected]


> From: Peter Hays
> Sent: Thursday, October 27, 2005 1:51 PM
> 
> Hello group,
> 
> We have a product that contains a small photo 
> transistor that is classified as “laser class 
> 1M”. My question is that is there any specific 
> procedure as far FDA is concerned that we need to 
> put in place in our receiving inspection 
> department? i.e. do we need to do follow any test 
> or record keeping? 
> 
> Thanks
> Peter
> 


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