Kenneth,

Typically the CDRH will send you two letters. The first one lets you know
that they
received the report, and they issue you an accession number. A second letter
(about
3 months later) notes that they have reviewed report and (provided they find
nothing
wrong) will tell you that no further info is required. THAT is their
'approval' (for lack
of a better word) letter.
That is the letter you provide to UL. The engineer at the UL office near me
(Melville) required 
the report that I submitted to the CDRH. I had no problem giving them that.
What would've happened if I didn't give them that info?  Would they hold up
approval? I don't know. I usually have all my 'ducks in a row' so I have no
idea.

Basically the same holds true for EN 60950 compliance. You need to
demonstrate
compliance with IEC 825 (EN 60825). 'Compliance' may be a misnomer. You need
to demonstrate
that your equipment is properly classified and that the appropriate 
controls/warnings/instructions, as/where applicable, are in pplace for the
corresponding
classification.

Here's the links for the CDRH. (You will need to purchase 825. I have not
found any
good on-line information).

http://www.fda.gov/cdrh/radhlth/cfr/21cfr1040.10.pdf

http://www.verity.fda.gov/search97cgi/s97_cgi.exe?action=View&VdkVgwKey=http
%3A%2F%2Fwww%2Efda%2Egov%2Fcdrh%2Fradhlth%2Flaser%2Ehtml&DocOffset=10&DocsFo
und=134&QueryZip=Laser&Collection=C4&SearchUrl=http%3A%2F%2Fwww%2Everity%2Ef
da%2Egov%2Fsearch97cgi%2Fs97%5Fcgi%2Eexe%3Faction%3DSearch%26QueryZip%3DLase
r%26ResultTemplate%3Dstndrslp%252Ehts%26QueryText%3DLaser%26Collection%3DC4%
26ResultStart%3D1%26ResultCount%3D10&hlnavigate=ALL

John A. Juhasz
Product Qualification &
Compliance Engineer

Fiber Options, Inc.
80 Orville Dr.
Suite 102
Bohemia, NY 11716  USA

Tel: 631-419-2324 (direct)
Fax: 631-567-8322
 


-----Original Message-----
From: Kenneth McCormick [mailto:kmccormick...@hotmail.com]
Sent: Monday, November 20, 2000 6:08 PM
To: emc-p...@majordomo.ieee.org
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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