RE: FDA registration of laser

2003-06-16 Thread Ed Eszlari
, EMC-PSTC >Subject: RE: FDA registration of laser >Date: Wed, 11 Jun 2003 07:50:34 -0400 > > >No registration is required if: >1) You put a Class I laser product into your product (in its entirety) and >your product is Class I. >2) You include the documentation that came

RE: FDA registration of laser

2003-06-11 Thread Peter L. Tarver
Chris - Your rationale for not resubmitting is valid *if* the GBICs are Certified as Class I (I haven't seen one yet that isn't). Your rationale for resubmitting is missing some what ifs. Specifically, if you remove (or cover with a label) any of the required markings or use the device outside t

Re: FDA registration of laser

2003-06-11 Thread garymcintu...@aol.com
Nope, you are absolutely correct on the GBIC's or the new smaller pluggable LC connector optics. You are just a distributor of those under the laser guidelines. Again, its a fully contained module that you make no changes to, and they have no controls or failure modes that you could induce to chan

RE: FDA registration of laser

2003-06-11 Thread Chris Maxwell
I want to leech off of this question; I hope that I don't get it off track. We currently produce a module that use GBICs. For the unfamiliar, a GBIC is an optical transceiver for gigabit ethernet. Our quality personnel handle CDRH submissions; and our current thinking is that we don't need to r

Re: FDA registration of laser

2003-06-11 Thread garymcintu...@aol.com
I think I agree with the laser 42 reference, but I would be a little careful. The notice applies to units that are not only complete in their construction and as such their output cannot be affected by the circuits into which they are being installed. E. g. If the drive voltage increases to

Re: FDA registration of laser

2003-06-11 Thread David Heald
Kim, You DO need to register. Testing may not be required, but is strongly encouraged regardless (technically you can refer to the laser component manufacturer's results). Note: This is assuming that you aren't just putting an off the shelf enclosed CD/DVD ROM drive in a system, which shouldn'

RE: FDA registration of laser

2003-06-11 Thread Peter L. Tarver
Kim - If the drive is already certified as a Class 1 laser product and you do not modify it or remove any of the required markings, you don't need to do anything, irrespective of the internal laser source's laser class.Refer to Laser Notice 42 at http://www.fda.gov/cdrh/radhlth/pdf/laser-not

RE: FDA registration of laser

2003-06-11 Thread FastWave
No registration is required if: 1) You put a Class I laser product into your product (in its entirety) and your product is Class I. 2) You include the documentation that came with the laser product with your product. 3) You leave all the labeling on the laser product as you received. There is an

Re: FDA registration of laser

2003-06-11 Thread T.Sato
On Wed, 11 Jun 2003 10:54:36 +0200, Kim Boll Jensen wrote: > When using a CD or DVD driver in a product (PC or audio product) and the > driver is FDA registered, do I need to register the final product at FDA > too. I can't find a paragraph in 21 CFR which tells me when not to > register. I w

RE: FDA registration of laser

2003-06-11 Thread Colgan, Chris
As far as I know, yes, you have to register the actual product with the FDA. That's what I have always done anyway. The fact that the driver is FDA registered will make it a fairly simple paperwork exercise. If you think about it, customs will not be able to associate the driver's FDA accession