As many of you surely already know, here in the United States the Food and Drug Administration is the regulating body for lasers (this may seem odd, but that is surely one of the least odd things about U.S. government regulations), and in 21 CFR 1040.10, there is special definition created for lasers used in survey work:
(39)Surveying, leveling, or alignment laser product means a laser product manufactured, designed, intended or promoted for one or more of the following uses:
(i) Determining and delineating the form, extent, or position of a point, body, or area by taking angular measurement.
(ii) Positioning or adjusting parts in proper relation to one another.
(iii) Defining a plane, level, elevation, or straight line.
However, all survey lasers need to comply with the entirety of 1040.10, in terms of limiting human exposure to the laser appropriately depending on the class of the laser. There are rules on labeling the danger, as well, and any number of specifications for safeguards and compliance.
Further, in 21 CFR 1040.11, there is specific language for survey lasers as follows:
(b)Surveying, leveling, and alignment laser products. Each surveying, leveling, or alignment laser product shall comply with all of the applicable requirements of 1040.10 for a Class I, IIa, II or IIIa laser product and shall not permit human access to laser radiation in excess of the accessible emission limits of Class IIIa.
Seems reasonable. And pretty clear. Perhaps even redundant. However, yet another government body is looking into certifying lasers: The FAA. As noted by MAPPS, there is currently a public comment period open in regard to a proposed “Certification of Airborne Surveillance and Searchlight Systems Using Lasers or Infrared Searchlights in 14 CFR parts 27 and 29 Rotorcraft.” Now, you might be thinking, “my airborne lidar system isn’t a surveillance or searchlight system – no problem!” But then you don’t have an appreciation for government regulation. If your system meets the definition of “airborne surveillance” that’s what it is, regardless of what you call it or use it for.
You can see the proposed certification policy here (scroll down to the second box of text). It’s 10 pages of gobbledygook, of course, but I think this part is the part to which people need to pay attention:
The following policy provides guidelines for installing systems that contain Class IIIa, Class IIIb, and Class IV lasers, or IR filtered searchlight features.
Well, the Optech ALTM is a Class IV laser, right? Seems like this policy would govern the installation of an ALTM system, of which there are easily more than 100 out there in the world. And Riegl’s new VQ-580, designed for the scanning of snow and ice, and VQ-820-G, for bathymetric applications, are both IIIb lasers. So the policy would cover those. You get the idea.
And as I read the policy, in order for a plan with such a laser installed to receive “airworthiness certification” those lasers would have to be disabled. As in:
Wiring and switch provisions to disable the laser or IR searchlight should be part of the approved type design. For the laser feature, the type design data should show that the laser features are disabled (for example, the laser harness connector is capped and stowed).
Or:
For installations with a disabled laser feature or IR searchlight feature, the instructions for continued airworthiness (ICA) should include inspection instructions to verify that the laser feature or IR searchlight features are electrically disabled. Should an operator choose to enable the laser feature or IR filtered searchlight feature, procedures to transition from the FAA approved configuration to an unapproved configuration and back to the FAA approved configuration should be included in the ICA. It is highly recommended that the ICA contain maintenance procedures to protect the flight crew, the flying and non-flying public, and maintainers from laser hazards.
There is some serious paperwork and additional work that will need to be done in order to keep flying the systems that are already in the air should this policy got into place. You can try to make sense of the new policy (which is not a new “regulation” the document says) along with me, but most importantly you need to make your voice heard before the policy goes into effect.
The public comment period lasts until Aug. 31 and there is a form provided right here on that same page as the proposed policy, along with the contact information for Mark Wiley, Rotorcraft Standards Staff, Regulations and Policy Group, ASW-111: (817) 222 5134; fax (817) 222-5961; email at [email protected].
Look at what’s being proposed and let them know if special accommodation should be made for the surveying industry and airborne lidar. No one wants unsafe lasers to be blasted on an unsuspecting populace, or to have them interfere with commercial aircraft or military aircraft operations, but it’s imperative that the FAA understands how these lasers are being used and for what purpose and that this policy doesn’t adversely affect what is a growing and prospering industry.
