Changes Ahead: HS(G)95 The Radiation Safety of Lasers used for Display Purposes
PLASA has now announced that it will be taking ownership of HSE’s guidance notice relating to the use of laser for display purposes, HS(G)95. A full statement from PLASA’s Technical Resource Manager is included at the bottom of this page.
It should be seen as a positive move for updating the existing guidance, but naturally the announcement has lead to a number of questions being asked by people, which we have tried to answer below.
What is happening to HS(G)95?
The Health and Safety Executive (HSE) has decided in review of what information it provides to stakeholders that the successor to guidance document HS(G)95 is better suited to being developed, published and maintained within industry direct, rather than being HSE published guidance. The European office of the Professional Light and Sound Association (PLASA) has started to undertake work to facilitate ownership of the guidance on behalf of the industry. PLASA will therefore become the publisher of the industry guidance relating to laser show applications.
Why are changes taking place?
There are two key drivers affecting the change; one is the need for all government departments to reduce spending, and hence with HSE, the less publications the department is responsible for maintaining, the less money the department directly spends. Secondly, government is keen to be seen as reducing what could be perceived as unnecessary burden to business. Put frankly, government needs to report to the House of Commons that HSE has cut or removed x amount of guidance, regulation etc from its portfolio. HSE ‘guidance notes’ in general are now considered to contain too much ‘information’, and with HS(G)95 starting to look a bit long in the tooth, (it was first published in 1996, when there was no mention of low-cost solid-state lasers, or the Artificial Optical Radiation at Work Regulations), so it was felt that the document was an ideal candidate for being adopted and maintained in future by industry, rather than HSE.
What does this mean for me in the short term? – What guidance should I use?
Since HS(G)95 was introduced it has become universally accepted as the de-facto standard in how both laser and venue operators alike manage laser safety risk. It has provided a common understanding of what is and is not acceptable for laser display applications. No changes have been made to the current version of HS(G)95 as yet, so with the existing document currently being so widely adopted, nobody needs to change the way they should approach operating or managing a laser show installation.
Great! Does this mean we can scan above the MPE now?
The existing guidance from HSE has always been that the MPE at the audience should not be exceeded, either under normal operation, or through a fault condition occurring. This should therefore continue to be the case while the new guidance is updated.
It is not the green light for ILDA’s (International Laser Display Association), paper proposal for 10x MPE limits to be used. Any relaxation of MPE for the audience would only come about if it were supported by scientific research actually quantifying the risk. ILDA’s 10x proposal seems to be the source of much confusion about its status. Therefore for clarification, the 10x MPE limits do not exist anywhere beyond a paper presentation; they are not a standard, or values that have been accepted for use.
From our own experience in the UK, at many venues it can be hard enough task agreeing if 1x the MPE is acceptable, so any proposals of higher permitted exposure levels are likely to face challenges such as venues feeling comfortable with the activity, and insurance liabilities etc. That said, the review panel for the new document will consist of a wide representation of experts in their field, so it is likely a balanced discussion on the topic can be had.
Does this mean what I have learned and been practicing with HS(G)95 is going to become irrelevant?
Not at all. Principles such as the 3m separation distance, emergency stop requirements and risk consideration etc., are unlikely to be disappearing anywhere soon. These and many other ideas are generally shared and recognised world over in different forms of guidance for laser show applications though similar documents published in local territories. It is therefore likely that a reasonable level of continuity will prevail. In fact in the UK, we already have another official ‘best practice’ guidance document for laser displays and light shows published by the British Standards Institute (BSI), PD IEC/TR 60825-3:2008
It is likely that as HS(G)95 is adopted as ‘industry guidance’, it builds on the strengths of its predecessor, adds clarification, and tweaks some of its more obscure points.
Does this mean regulations are becoming more relaxed?
No, the regulations relating to the use of lasers in the workplace (Control of Artificial Optical Radiation at Work Regulations 2010), as well as other more general legislation remain in force, and have not been touched. There is still the explicit need to protect workers and members of the public from harmful levels of laser radiation, with laser MPEs being binding workplace exposure limits. It is only the additional ‘guidance’ that HSE has previously produced that is under review.
Similarly, product legislation requiring the minimum safety features such as key switches, interlocks, start/reset buttons, and labelling etc to be present on laser projection equipment, through Laser Product Safety Standard BS EN 60825-1:2007 is still applicable.
How long will the process take
It depends upon what everyone decides in terms of work that the needs to be carried out. The panel is likely to be made up of volunteers, and through the nature of committees, things can take a longer than everyone would like to progress, but I’m sure everyone will be keen to see the work undertaken as efficiently as possible.
How can I get involved?
A full copy of the email sent from PLASA’s UK Technical Resources Manager, Ron Bonner is included below. If you would like to get involved with the process, you can follow the link to the short survey and leave your contact details, or alternatively contact Ron direct.
How can I keep informed?
PLASA will likely make further statements in the future as the work progresses. LVR will also ensure its clients, and those that have been on one of our training courses are kept in the picture as things move forward, through our newsletters and Facebook page.
Who is PLASA?
The Professional Light and Sound Association is an international membership body representing those that supply technologies and services to the event, entertainment, and installation industries. It is the European office of PLASA, based in Eastbourne that is facilitating the review of the HS(G)95 guidance.
PLASA statement in full
HS(G)95 'The radiation safety of lasers used for display purposes
You may have heard that following a review of Health and Safety Guidance No 95 (HS(G)95) "The radiation safety of lasers used for display purposes", the Health and Safety Executive (HSE) has agreed to transfer ownership of the guidance to PLASA on behalf of the industry.
HSE is currently undertaking a review of all its external guidance. There are a number of internal and external drivers for this review, significantly HSE's Strategy which supports adapting and customising guidance for low and moderate risk SMEs and the Coalition Government's requirement that guidance on regulation is proportionate and focussed on compliance (Common Sense, Common Safety and Growth Agenda).
The review of HS(G)95 determined that the document offers guidance on matters of procedure that is well respected and well used by industry but which goes beyond what is required to comply with health and safety law. A revision by HSE would remove some of this useful procedural guidance.
Consequently, a transfer of ownership was agreed, which will allow us to retain much of the helpful procedural content within the document. HSE recognises that industry has the technical ability to update and maintain the guidance, which will help to ensure it is future proof. It also provides the industry with an opportunity to demonstrate stronger health and safety leadership.
PLASA acknowledges that this decision hasn't been welcomed by all within the Entertainment Industry as many believe that an HSE guidance document does carry an authority of its own. However, and in recognition of this point, HSE's Entertainment Sector and HSE's Technical Specialist in this area will provide support during this transition and help with the process of securing an HSE endorsement of any subsequent guidance the entertainment industry produces. PLASA also aims to update the guidance via industry consensus through fair representation. PLASA recognises that whilst having the ownership of the guidance it does not have a mandate to produce the guidance in isolation and as such plans to involve as many stakeholders whose work will be affected by revised or replaced guidance. It was hoped to convene a small representative review panel made up from the various trade bodies, unions, health experts, venues, Laser production companies etc. to discuss the future and format of any subsequent guidance documentation. However, the interest to be involved by so many in the review process has unfortunately meant this plan has been revised.
The plan now will be to carry out a simple consultation on the future direction of the document and through consensus, decide how the revision will be carried out. I stress this consultation is about what the industry wants to do regarding the revision and the future of the guidance (if indeed it is decided that the guidance should continue?). It is not a consultation regarding any content of any future guidance.
I have put together a questionnaire using Survey Monkey http://www.surveymonkey.com/s/98PSMXC with simple set of questions regarding the future of the guidance which I would be very grateful if you would take a moment to answer.
I will close the consultation on July 31st 2013. The results of which will be made public and plans made immediately to progress the revision if the consultation results decide that outcome.
Thank you for your participation.
Please feel free to pass on this consultation to anyone you consider being a stakeholder that you feel would be interested in participating in the process.
Thank you in anticipation.
Ron Bonner, Technical Resources Manager
PLASA Ltd, Redoubt House, 1 Edward Road, Eastbourne, BN23 8AS, UK.
Tel: +44 (0)1323 524120 : DDI +44 (0)1323 524129 : 07710 909308 Fax: +44 (0)1323 524121
Email: firstname.lastname@example.org : Website: www.plasa.org
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