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Compliance

Occupational Safety and Health Act: Laser Safety

PURPOSE

The Occupational Safety and Health Act of 1970 (OSHA) provides standards to protect workers’ safety. The Laser Institute of American (LIA) developed voluntary laser safety procedures “to provide reasonable and adequate guidance for the safe use of lasers and laser systems.” The American National has approved these standards, and OSHA has referenced them as the industry standard for laser safety.

HISTORY

The standards for laser safety were created in 1973 by the LIA and approved by ANSI; these standards have been revised many times since then. The most recent version of these standards is known as ANSI Z 136.1 (“ANSI Standard”) and was published in 2014.

APPLICABILITY TO BYU–HAWAII

OSHA’s general duty clause requires employers to maintain safe workplaces and help employees avoid serious injury and death. OSHA itself “does not have a comprehensive laser safety standard” that applies to the use of lasers in any activity. OSHA maintains a technical manual of the most recent research and “consensus standards” on workplace safety. OSHA’s technical manual references the ANSI Standard as the industry standard for laser safety, though OSHA indicates that “there is no inherent requirement for any person or company to adhere to an ANSI standard.”

Although the ANSI guidelines are voluntary, they help employers and employees meet the requirement of maintaining a hazard-free workplace. Different departments at BYU–Hawaii use lasers in connection with research and academic activities. Because lasers are potentially hazardous, BYU–Hawaii voluntarily follows the ANSI Standard in an effort to help protect employees and students from harm.

Beyond the application of OSHAs’ general duty clause to laser safety, OSHA also has specific laser safety regulations that are mandated for use of lasers in the construction industry.

To the extent that BYU–Hawaii uses lasers in construction activities, these construction regulations would apply, as outlined below.

REQUIREMENTS

A. ANSI Standard for Laser Safety

The ANSI Standard gives guidelines for effective laser safety programs, which include the following parts

1. Laser Safety Officer

To comply with the ANSI Standard, institutions must designate an LSO to oversee and control laser hazards. The LSO’s responsibilities include the following:

  • Classify or verify the manufacturer’s classifications of lasers
  • Evaluate the hazards of laser work areas
  • Make sure that control measures are in effect and perform periodic audits
  • Approve procedures
  • Provide or approve appropriate protective equipment
  • Approve the wording on signs and labels
  • Approve new laser installations, along with the laser equipment and facilities involved
  • Ensure that employees receive adequate safety training

2. Hazard Evaluation and Laser Classification

Lasers are classified as Class 1 to Class 4 depending on the radiation emitted during operation of the laser. Under normal operation, lasers of Classes 1, 2, and 3R pose little hazard to operators, but Class 3B and Class 4 lasers can cause damage to the eyes or skin.

Under the ANSI Standard, the LSO must ensure that the laser classification information provided by the laser manufacturer is valid.

In areas where a Class 3B or Class 4 laser is used, the LSO should establish a Nominal Hazard Zone (NHZ) that indicates the space within which the level of “direct, reflected, and scattered radiation” during normal operations is hazardous to the eyes or skin.

3. Safety Control Measures

The LSO is responsible for overseeing laser safety controls by establishing engineering controls, administrative controls, PPE, and supervisory/personnel controls. Adequate safety controls should ensure that employees’ eyes and skin are not exposed to hazardous levels of laser radiation or other laser-related hazards.

i. Engineering Controls

Engineering controls should be the primary means of ensuring safety. Protective housing of the lasers, entryway controls, and filtered windows are among the precautions that should be used to limit access to a laser before, during, and after its activation. Warning signs and labels should be prominently displayed in order to warn onlookers of potential hazards.

ii. Administrative Controls

The LSO or another qualified person must provide periodic laser safety training to users of lasers. Training must be provided to users of Class 3B and Class 4 lasers and should be provided to users of Classes 1M, 2, 2M or 3R lasers commensurate with the potential hazard of the class of laser. Training topics may include but are not limited to effects of laser radiation on the eyes and skin, control measures, non-beam hazards, and responsibilities of management and employees.

iii. Personal Protective Equipment (PPE)

PPE must be used when engineering controls are impractical or inadequate as a last resort.

The ANSI Standards require employees exposed to laser beams to be suited with appropriate laser safety goggles.

iv. Supervisory Control

Class 3B or 4 lasers must be operated with a supervisor who maintains visual surveillance of conditions for safe use and terminates laser emission should there be an equipment malfunction or an unsafe condition arises. This supervision is required unless there are appropriate area control and training measures in place to protect those who may enter the controlled area.

v. Non-beam Hazards

Laser systems pose potential hazards besides exposure to the beam, such as potential electrical, fire, and explosion hazards, and mechanical hazards associated with robotics. The LSO should identify these hazards and employ appropriate safety controls.

4. Medical Surveillance

ANSI provides that “[m]edical examinations shall be performed as soon as practical . . . when a suspected injury or adverse effect from a laser exposure occurs.” Employers may want to offer periodic eye examinations as a health benefit, but, according to the ANSI Standard, no chronic health problems have been linked to working with lasers.

B. OSHA Laser Safety Requirements for Construction Activities

Currently the only laser safety standards mandated by OSHA involve the use of lasers in construction activities. “Construction activity” means “work for construction, alteration, and/or repair, including painting and decorating.” Those who use lasers in the construction industry must be trained and keep proof of their qualification with them, wear suitable and properly labeled laser safety goggles, and must not direct lasers at employees. The OSHA construction regulations also impose specific limits to the light intensities of lasers to which employees are exposed.

In the context of construction activities, the workplace where lasers are used must be posted with standard laser warning placards.44 Lasers must not be used if there is dust or fog in the air or when it is raining or snowing, and must be capped or turned off when not in use. Only mechanical or electronic means shall be used to guide the internal alignment of a laser, and wherever possible, lasers in operation should be set up above the heads of employees.