Requirements for the use of lasers vary by state. As we talked about in last week’s blog, New York has its own state-specific laser regulations. In Massachusetts, lasers are regulated by the Radiation Control Program (RCP) in 105 CMR 121.000, and some of the requirements differ from New York’s.
In Massachusetts, all Class 3B and Class 4 laser devices are required to be registered with the state RCP. However, lasers with embedded Class 3B or 4 lasers that have a rated output of less than 3B, do not need to be registered. In addition, Class 3R, 2M, 2, 1M, and 1 do not require registration.
Lasers can be registered using the RCP’s Laser Registration Application. The registration asks for general contact information, confirmation that appropriate safety procedures are in place, and a detailed inventory of lasers onsite. Lasers that are in storage or transit do not need to be registered, however we recommend that they be tracked in an internal laser inventory.
If your facility has lasers that need to be registered, you need a laser safety program, including a Laser Safety Manual and a designated Laser Safety Officer (LSO). The LSO should be able to provide documentation demonstrating appropriate education and experience and/or have received outside laser safety training from a qualified vendor. The certificate of completion should be provided with the registration application.
The regulations require the LSO to conduct a periodic audit of the laser safety program to ensure all documentation and safety measures are in place. We recommend that this be performed annually, along with an annual inspection of the laser safety eyewear in use. The audits and inspections must be documented.
The LSO is also required to accompany state inspectors during their review of the laser safety program. Initial RCP inspections are announced, but once a company has been initially inspected, regular inspections will occur unannounced, according to a schedule set by the RCP.
It should be mentioned that currently, there is no specific OSHA laser regulation, but both OSHA and the RCP cite the latest version of the ANSI Z136.1 Standard (Safe Use of Lasers) and Z136.8 (Safe Use of Lasers in Research, Development, or Testing) as guidance. If your facility is required to have a laser safety program, you must purchase a copy of the applicable ANSI standards and ensure that they are readily available.
For additional information about laser safety program requirements, or for assistance in determining if your facility’s lasers need to be registered, please email us at [email protected].
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training.