Acquisition, Modification, Sale, or Transfer of Lasers
The campus LSO must be informed by the PI of the acquisition, modification, sale, or transfer of any Class 3B or 4 lasers. Other classes of lasers are not controlled in this manner. The PI must notify the LSO of all Class 3B or Class 4 laser/laser system:
- Acquisitions - complete and submit an LUA application form; or
- Transfers from the jurisdiction of one PI to another PI on or off campus; or
- Disposals or selling of the equipment.
Laser Use Authorization (LUA)
The LUA is initiated by the PI or PI designate for Class 3B or 4 lasers by completing an LUA application form (see Appendix D). The completed form is sent to the LSO who contacts the PI to discuss the laser system and application. After the LSO has evaluated the proposed LUA, the LSO may choose to approve the LUA application or request the chair or full NIRSC to review the application depending on the complexity of the proposed setup. A list of all LSO approved LUA applications shall be presented at the next NIRSC meeting. After review and approval, a copy of the LUA is sent to the PI. In general, LUAs are reviewed by EH&S each year during the annual audit. Modification or termination of an LUA is done at the request of the PI or under special circumstances; the NIRSC may also modify or terminate an LUA. The LUA may be temporarily suspended by order of the LSO or the NIRSC if they feel that the health or safety of a laser user or the public is in immediate danger. The LSO or their designee maintains documentation of all changes to an LUA.
Any laser/laser system that is intended to be used in a human subjects experiment/ protocol is required to undergo additional review and approval by NIRSC and the UC Berkeley Committee for the Protection of Human Subjects.
Laser Safety Training Requirements
Initial Training
All people seeking to use a Class 3B or 4 laser are designated as a “laser user” (including PIs) and are required to meet the campus laser safety training requirement. Laser Safety training is provided either online or in-person routinely by the LSO or EH&S designate. Laser users can enroll in the laser safety class by going to the UC Learning Center website and searching for the course title: EHS 301 Laser Safety Initial.
Laser users who have met the LBNL initial laser safety requirements (LBNL EHS 302) will be granted exemption from meeting the campus laser safety training class. The LBNL EHS 302 and EHS 303 is considered equivalent to the campus training class.
Refresher Training
All laser users, including PIs, are required to refresh their knowledge of laser safety every three years (from initial training). Laser users can fulfill this requirement by completing an online laser safety refresher training course. The laser safety refresher course is available through the campus UC Learning Center. Search for course title: EHS 302 Laser Safety Refresher.
Other Training
Supplementary laser safety training is available from the EH&S upon request. The NIRSC may direct a PI to obtain a supplementary laser safety training presentation for his/her users. The LSO maintains documentation on all training presentations. The PI shall also provide and document that all laser users operating under his/her LUA have received specific hands-on instruction in the use of the laser system, safety precautions associated with the laser, any standard operating procedures (SOPs) relating to the laser, and proper use of laser protective eyewear.
Suspected Laser Incidents
Laser users must inform the PI and LSO of any suspected laser incidents/exposures. The LSO is responsible for investigating laser incidents; providing a report to the PI and the NIRSC, and maintaining records on incidents. Please refer to Appendix D, of the Standard Operating Procedures template for the Emergency Procedure for Laser Accidents. Eye examinations will be performed on UC Berkeley staff whenever a laser eye exposure is suspected.
Following the incident, the PI is responsible for filing all appropriate campus documentation related to the incident. After an incident, the laser/laser system must not be used until the LSO and the NIRSC has reviewed the incident, reviews and approves corrective actions/recommendation, and approves a restart.
Laser Safety Inspections
Laser facilities are inspected by the LSO or their designee to assure that the lasers are being operated in a safe manner. After the appropriate safety training and initial inspection, he LSO may offer the PI the option of performing a self-assessment in place of an LSO inspection periodically. If the PI agrees to a self-assessment, they must complete the Laser Safety Inspection form and return the completed form to the LSO for review within 30 days of the request. See Appendix D for a copy of the Laser Safety Inspection form. Copies of all inspection reports are provided to the PI for their review. The LSO maintains records of all inspections performed.
If there is an imminent hazard, the LSO is authorized to stop the operation and will advise the PI and the chair of the NIRSC of this action. The PI is responsible to correct unsafe conditions in a timely manner. The LSO or their designee will re-inspect the laser facility to verify the correction of the unsafe condition. The LSO will inform the NIRSC of uncorrected unsafe conditions and the PI will be asked to attend a NIRSC meeting to brief the NIRSC on the issue.
Consequences of Non-Compliance
When problems are identified during an inspection of a laser and its operation, the LSO or EH&S designate will prepare a report detailing the issues(s) and corrective action(s). Identified non-compliance items reported shall be corrected in a timely manner or as communicated in the report. The LSO or EH&S designate may either perform a follow-up inspection or request confirmation of compliance.
In the event of any serious violation or discovery of unsafe conditions, the LSO will bring the matter to the attention of the PI. The LSO may take action to prevent any imminent danger by stopping work. The LSO will inform the NIRSC chair after taking such action. The LSO may also refer the matter to the NIRSC Chair or committee to address.
Serious or chronic non-compliance issues can result in review by the NIRSC and may lead to restrictions, more frequent EH&S surveys, additional training, or in severe cases, suspension or termination of the LUA.
The following step (s) may be taken by EH&S and/or by NIRSC to resolve non-compliance items:
- EH&S (LSO or designee) performs a follow-up inspection with PI or lab contact in a timely manner after the initial report)
- NIRSC Chair or NIRSC department representative contacts the PI and/or lab safety contact with a formal request to the PI with copies to the Department Chair.
- A request may be made for the PI to attend the next NIRSC meeting
- NIRSC Chair formally informs Vice-Chancellor for Research (VCR) of the suspension or termination of an LUA or LUA user.
If at any time the LSO is not satisfied with the users' safety and health practices, the project may be halted (with NIRSC/chair approval) until corrections have been made. The LSO’s action(s), other than stop-work orders, may be appealed to NIRSC.
Standard Operating Procedures
For lasers, standard operating procedures (SOPs) are required for all active Class 3B and 4 lasers. These SOPs must:
- Describe hazards and controls associated with the use of the laser
- List laser protective eyewear requirements
- Describe procedures for start-up, shut-down, alignments, service, and maintenance
- Describe safety precautions (stray beam/unwanted reflection checks, beam blocks, avoidance of the beam on a horizontal plane with the user's eyes, beam enclosures, eyewear, hands-on training, etc.) to be followed
- Describe how to respond in an emergency situation
Include an Authorized Laser User signature page for users to sign that they have read the document
SOPs are to be reviewed and approved by the PI and then the LSO. A copy of the SOP should be available for review at all times. PIs and laser users should review their specific SOP annually, or more often if conditions change.
An SOP template is available for campus users through the EH&S Laser Safety Program website and is referenced in Appendix D - Laser Safety Forms.
Personal Protective Equipment (PPE)
The PI shall provide their laser users with the appropriate laser eye protection. See Appendix E for an eyewear selection guide. Appropriate laser eye protection must be used for beam alignments or anytime an open beam exceeds the ANSI Z136.1 maximum permissible exposure (MPE) value. The LUA document will detail the MPE and the required minimum optical density (OD) for laser protective eyewear. The LSO should be consulted prior to purchasing any laser protective eyewear.
Some ultraviolet (UV) laser uses may require the use of skin protection. Any need for skin protection will be identified by the LSO and communicated to the PI through the LUA.
Additional PPE such as respirators, face shields, gloves, lab coats, and hearing protection, etc. may be required whenever engineering controls cannot provide protection from harmful ancillary hazards and is warranted by the campus PPE criteria or policy.
Beam Management
Laser beam(s) must be restricted to the immediate location of use. Beams paths should be enclosed whenever practical. Beam stops/barriers must be used to terminate beams. The use of shutters, curtains, beam tubes, and other beam control devices are strongly encouraged. It is the responsibility of the PI and their laser users to verify through a survey that appropriate beam management is being practiced.
Posting and Labeling
All access points to the laser facility must be marked with an ANSI standard laser hazard warning signs. Laser enclosures must be labeled to alert users to laser hazards as per
the ANSI standard. Labels, laser hazard signs, and advice on their use are available from EH&S. See Appendix F for the approved ANSI laser warning signs.
New or renovated campus laser facilities will be required to meet the campus laser safety design requirements.
Access Control
Whenever the laser is in operation, access to laser facilities is restricted to laser users or persons being escorted by laser users. Access control must be maintained by a positive means such as locked or interlocked doors. Laser warning signs alone are not considered sufficient to control access.
For the entryway to a Class 3B Class 4 laser facilities, a door, blocking barrier, screen, curtain, etc. shall be used to block, screen, or attenuate the laser radiation at the entryway. The level of laser radiation at the exterior of these devices shall not exceed the applicable MPE, nor shall personnel experience any exposure above the MPE immediately upon entry.
Substitution of Alternate Control Measures (Class 3B or 4)
The ANSI Z136.1 Laser Standard (4.2) provides the LSO authority to substitute control measures specified in the standard for Class 3B and Class 4 laser or laser systems with other procedural, administrative, or alternate engineering control measures which provide
equivalent protection.
Administrative Control Measures for Class 3B and Class 4 Lasers
The following administrative controls are used for Class 3B and 4 lasers:
- Access limited to authorized laser users
- Current laser safety training for all users
- Baseline eye exam
- Standard Operating Procedure
- Perform and document stray beam/unwanted reflection checks
- Establish a Nominal Hazard Zone (NHZ)
- Post appropriate laser hazard warning sign
- Appropriate laser eye protection is required
LSO may require additional control measures as needed*
Engineering Control Measures for Class 3B and Class 4 Lasers
The following engineering controls are used for Class 3B and 4 lasers:
- Use of appropriate beam stop or attenuators and beam enclosures
- A door, blocking barrier, screen, curtain, etc. shall be used to block, screen, or attenuate the laser radiation at the entryway
- All open portals (windows, doorways, etc.) from an indoor facility are either covered or restricted
LSO may require additional control measures as needed*
Record-Keeping Requirements
EH&S maintains all records/documents (paper and electronic) pertaining to the campus laser safety program. Baseline eye exam records are considered medical records and maintained by the UC Berkeley Meredith W. Morgan University Eye Center.