Evaluation of Ground-based Outdoor Laser Operations by Flight Standards Inspectors

1. Evaluation of Ground-based Outdoor Laser Operations by Flight Standards Inspectors FINAL http://www.faa.gov/pilots/laser/

2. LASER Light Amplification by Stimulated Emission of Radiation.

3. Laser Incidents Las Vegas, NV The cockpit of a departing Southwest Airlines had the cockpit illuminated by a laser. The pilot looked out the window and became visually impaired. They continued to their destination (LAX) and were seen by flight surgeons and ophthalmologists who confirmed visual impairment but not permanent damage.

4. Laser Incidents, cont. Salt Lake City, UT A Delta Airlines pilot was grounded for three weeks because of a laser eye injury sustained on final approach to SLC. He was treated for a swollen retina and remains sensitive to bright light.

5. Potential Laser Ocular Bio-Effects Vitreous Hemorrhage Retinal Burns Corneal Burn Laser Glare

6. Incidents, cont. Further investigation by FAA and FDA found at least 50 other incidents in the Las Vegas area. The military also indicated incidents had occurred. This demonstrated that a problem existed in the Las Vegas area and something needed to be done immediately. At the FAA’s request, the FDA immediately issued a moratorium ceasing all laser activities in the Las Vegas area. The moratorium did more than stop the incidents between lasers and aircraft operators, it helped to establish additional guidelines in the determination process.

7. FAA Concerns EARLY FOCUS: Laser Light Shows: “How to protect users of the NAS from the potential adverse and/or hazardous effects of ground-based outdoor laser operations used in advertisement and entertainment”. The FAA’s objective is to keep lasers (visible and non-visible) away from pilots rather than keeping pilots away from lasers. ONGOING FOCUS: Scientific and Research Lasers in the NAS. Scientific/research lasers in accordance with 21 CFR Section 1010.5 may be exempt from Title 49 and, in addition, may not be able to comply with the above procedures. Regardless of whether or not a proponent is exempt from the provisions, a proposal will still be reviewed.

8. Organizations Involved in Development of Current Outdoor Laser Operations Rules & Policy FAA SAE G-10T, Laser Hazards Sub-committee Airline Pilots FDA - CDRH International Laser Display Association

9. Responsibilities The Administrator of the FAA is responsible under Title 49 U.S.C. to: • ….ENSURE THE SAFETY OF AIRCRAFT AND THE EFFICENT USE OF THE AIRSPACE…. Title 49 Transportation, Subtitle 1 DOT, §106 (g) (A), Subtitle VII, Part A, Subpart 1, § 40103 (b) (1)

10. Responsibilities, cont. AFS Role The Regional Flight Standards Division (RFSD) is responsible for providing a Safety Analysis to the Air Traffic Organization (ATO) to determine any potential effect that a proposed ground-based outdoor laser operation would have on civil flight crews and flight operations. Guidance contained in FAAO 7400.2 & AC 70-1 is applicable to all ground-based outdoor laser activities.

11. Responsibilities, cont. The Center for Devices and Radiological Health (CDRH), part of the Food and Drug Administration (FDA) under Title 21 U.S.C. is responsible for establishing and managing the electronic radiation control program. Certain laser equipment and operations fall within their authority. 21 CFR PART 1010 § 1010.1; § 1010.4; § 1010.5 PART 1040 § 1040.10 (a), (b) (13) § 1040.11 (c)

12. FDA – CDRH Laser Product Classes CLASS I - Low levels of radiation - no biological damage. Example - CD Player CLASS II - Eye damage after direct, long-term viewing. Example - Grocery Store Scanner CLASS III a. - Capable of ocular injury in a short exposure. Example - Land Surveyor’s Transit

13. FDA – CDRH Laser Product Classes, cont. CLASS III b. - Potential to injure human tissue (eye or skin), direct beam or reflection. CLASS IV - Injury by direct or reflected beam, scattered or diffused.

14. Regulation Of Ground-based Outdoor Laser Usage • The FDA – CDRH regulates the manufacture of laser products and permits only Class I, II, and III a. lasers light shows without a variance. • Class I or II lasers are not very effective with large crowds of people. • Outdoor events often use Class III b. and Class IV lasers. • It is possible to use Class III b. and Class IV lasers in a way that makes them as safe as Class I or II lasers. • The FDA can permit the use of Class III b. and Class IV lasers by issuing a variance (equivalent level of safety).

15. Variance The Food and Drug Aministration, Center for Devices and Radiological Health (CDRH), regulates the manufacture of laser products but does not regulate the use of laser products. A ground-based outdoor laser light demonstration is considered to be a laser product and, if the irradiance energy level is greater then 5 miliwatts per square centimeter, the demonstration requires a variance to Title 21, Code of Federal Regulations, Section 1040.11 c. The variance (issued by the CDRH) requires the laser user to notify the FAA of the proposed laser operation and resolve any objections that the FAA may have. If FAA objections remain, the variance is invalid.

16. Variance, cont. As per the FDA/FAA MOU, FDA – CDRH variances contain a requirement to notify the FAA when any proposed ground-based laser light show or display would project laser light into airspace during: • Testing • Installation • Setup • Rehearsals • Show operations

17. Excerpts From FAA/FDA MOU FAA conducts an aeronautical study of all proposals received for outdoor laser activities to determine the potential effect upon aircraft operations. The FAA aeronautical study is intended to ensure adequate protection for users of The NAS. Specific requirements of the aeronautical studies can be found in FAA Order 7400.2. FAA activities associated with aeronautical studies include, but are not limited to, the following: 1. Providing the expertise and knowledge of known airport locations, flight paths, and traffic patterns in the areas surrounding the site of the laser display which may be in place at the time of the display. 2. Coordination with the military liaisons stationed in the region or locale of the show to include consideration of the effects on military flight operations which may occur in the area of the display during the time of its operation 3. Review of proposed laser light show operations producing projections into airspace in accordance with FAA Order 7400.2 4. Issuing the appropriate determination letter (OBJECTION or NON-OBJECTION, including any applicable conditions in the latter case) to the laser light show proponent; and 5. Discussing the reasons for an objection with a laser light show proponent and negotiating possible suitable modifications or limitations of the proposed show with the goal of resolving the reasons for objection.

18. Laser Terminologies Temporary Adverse Visual Effects Distraction, Startle, Glare, Flashblindness, Afterimage Hazardous, Adverse Eye Bio-Effect vs. Distance (Threshold Point) Maximum Permissible Exposure (MPE) Nominal Ocular Hazard Distance (NOHD) Irradiance Energy Levels (from highest to lowest power) miliwatts per square centimeter (mW/cm² ) microwatts per square centimeter (µW/cm² ) nanowatts per square centimeter(nW/cm² )

19. Temporary Adverse Visual Effects Effects on Unaided Vision - Startle - Glare/Dazzle - Afterimage/Flashblindness With Night Vision Goggles - Flare or blooming of screen EVS/HUD - TBD

20. Temporary Adverse Visual Effects, cont. Startle – Refers to an interruption of a critical task due to the unexpected appearance of a bright light, such as a laser beam. Glare/Dazzle – A bright light that makes it difficult to see, such as, oncoming headlights or a momentary laser pointer exposure. These visual effects last only as long as the light is actually present. Afterimage/Flashblindness – A shadow image left in the visual field after the source of bright light has been removed. This is similar to the effect produced by the flashbulbs, and can occur at exposure levels below those that cause eye injury.

21. Laser Hazards vs. Distance VISUAL EFFECTS Hazard Distance Laser Startle Afterimage Potential Retinal Injury Glare From “Commercial Laser Pointers and Night Flying – Don’t Be Startled,” presentation, by D.H. Sliney, US Army Center for Health Promotion and Preventative Medicine, Laser/Optical Radiation Hazards Program (DOHS/25), Laser Eye Protection, p. 28.

22. Measurements, MPE & NOHD Nominal Ocular Hazard Distance (NOHD)The maximum distance from the laser system beyond which the laser beam irradiance does not exceed the MPE for that laser. The beam is an eye hazard from the laser source to this distance. Maximum Permissible Exposure (MPE)The level of laser radiation to which a person may be exposed without hazardous effect or adverse biological change in the eye or skin. This value is used in the calculation of Nominal Ocular Hazard Distance (NOHD).

23. Laser Terminologies, cont. Calculated Laser Beam Distances Nominal Ocular Hazard Distance (NOHD) Sensitive Zone Exposure Distance (SZED) Critical Zone Exposure Distance (CZED) Laser Free Exposure Distance (LFED) Flight Zones Laser Free Zone (LFZ) Critical Flight Zone (CFZ) Sensitive Flight Zone (SFZ) Normal Flight Zone (NFZ)

24. Calculated Laser Beam Distances There are four laser beam distances that are important in evaluating the safety of ground-based outdoor laser operations. 1. Nominal Ocular Hazard Distance (NOHD) - The beam is an eye hazard (is above the MPE), from the laser source to this distance. • Sensitive Zone Exposure Distance (SZED) - The beam is bright enough to cause temporary vision impairment, from the source to this distance. Beyond this distance, the beam is 100µW/cm2 or less. • Critical Zone Exposure Distance (CZED) - The beam is bright enough to cause a distraction interfering with critical task performance, from the source to this distance. Beyond this distance, the beam is 5 µW/cm2 or less. • “Laser-Free” Exposure Distance (LFED) - The beam is dim enough that it is not expected to cause a distraction. Beyond this distance, the beam is 50nW/cm2. The laser beam distances are calculated by the laser operator and reported on the application form Worksheet, FAA Form 7140-1.

25. Airspace Flight Zones There are four Flight Zones that are important in evaluating the safety of ground-based outdoor laser operations. Laser Free Zone (LFZ) Critical Flight Zone (CFZ) Sensitive Flight Zone (SFZ) Normal Flight Zone (NFZ) These flight zones will be charted (Plan & Profile View) and evaluated by the AFS Inspector as part of the Safety Analysis.

26. Airspace Flight Zones, cont. Laser Free Zone: Surface to 2,000' Above Airport Elevation (AAE) 2 Nm from Runway Ends & Centerline 3 Nm Extension 5,000’ Wide, 2,500’ Along Either Side of Extended Runway Centerline Irradiance Energy Level Not To Exceed 50nW/cm²

27. Airspace Flight Zones, cont. Laser Free Zone Runway Runway (ARP)

28. Airspace Flight Zones, cont. Laser Free Zone 10NM 10NM AIRPORTREFERENCEPOINT (ARP) LASER FREE ZONE 50nW/cm2

29. Airspace Flight Zones, cont. Critical Flight Zone: Surface to 10,000’ AAE 10 NM Radius From the Airport Reference Point (ARP) Irradiance Energy Level Not To Exceed 5 µW/cm²

30. Airspace Flight Zones, cont. Critical Flight Zone CRITICALFLIGHT ZONE 5µW/cm2 10NM 10NM AIRPORTREFERENCEPOINT (ARP)

31. Airspace Flight Zones, cont. Sensitive Flight Zone: AirspaceAnywhere Within a Normal Flight Zone but outside of a Critical Flight Zone containing Known, At-Risk Aircraft Operations Not Necessarily Associated with a Landing Facility Location(s) and Dimensions Determined by Local FAA (AFS) Irradiance Energy Level Not To Exceed 100µW/CM²

32. Airspace Flight Zones, cont. Sensitive Flight Zone SENSITIVEFLIGHT ZONE 100µW/cm2 10NM Examples: Glider OPS Parachute Jump Area Etc. 10NM AIRPORTREFERENCEPOINT (ARP)

33. Airspace Flight Zones, cont. Normal Flight Zone: Anywhere in the NAS that is not a LFZ, CFZ or SFZ that may contain Impromptu Aircraft Operations A NFZ Will Normally Surround Other Flight Zones Irradiance Energy Level Not To Exceed 2.6 mW/cm²

34. Airspace Flight Zones, cont. Normal Flight Zone NORMALFLIGHT ZONE 2.6mW/cm2 10NM 10NM AIRPORTREFERENCEPOINT (ARP) NORMAL FLIGHT ZONE 2.6mW/cm2

35. All 4 Airspace Flight Zones, Plan View CRITICALFLIGHT ZONE 5µW/cm2 VFR Flyway SENSITIVEFLIGHT ZONE 100µW/cm2 10NM Normal Flight Zone 2.6mW/cm2 Normal Flight Zone 2.6mW/cm2 10NM AIRPORTREFERENCEPOINT (ARP) LASER FREE ZONE 50nW/cm2

36. SENSITIVE FLIGHT ZONE AIRCRAFT OPS MAY BE SUSCEPTIBLE 100µW/cm2 ** ** CRITICAL FLIGHT ZONE 50µW/cm2 8000’ 8000’ 2000’ LASER FREE ZONE 50nW/cm2 2000’ 3nm 2nm 2nm 3nm ** ** * 10nm 10nm AIRPORT REFERENCE POINT (ARP) Airspace Flight Zones, Profile View Elevation Normal Flight Zone 2.6mW/cm2 Normal Flight Zone 2.6mW/cm2 * Runway length varies per airport. AGL is based on published airport elevation. ** To be determined by local FAA evaluation and/or local airport operations.

37. Examples of Airspace Flight Zones, Profile View Normal Flight Zone Laser Beam with 100 Elevation Angle Sensitive Flight Zone Critical Flight Zone Laser Free Zone Runway ARP

38. Information Needed To Conduct AFS Safety Analysis 1. Location of the proposed laser operation (Lat / Long, elevation), and beam direction from FAA Form 7140-1, Worksheet, Items 2 & 4, and topographical map if provided by applicant. 2. For visible lasers, the laser NOHD, SZED, CZED and LFED for the proposed laser operation from FAA Form 7140-1, Worksheet, Item 5. 3. Known civil landing facilities, aircraft routes / flyways, etc. in the proposed area of the laser operation. 4. Known civil aircraft operations not associated with a landing facility potentially affected by the proposed laser operation. 5. For visible lasers, the landing facility LFZ, CFZ, and SFZ for all potentially affected civil landing facilities, and SFZ for known potentially affected aircraft routes / flyways, etc..  6. Proposed control measures, procedures, and other mitigations.

39. AFS Safety Analysis, Overview Use proposed laser NOHD, SZED, CZED, and LFED from FAA Form 7140-1, Worksheet, Item 5. AFS Safety Analysis is based on locally known civil landing facility operations such as departure routes, arrival routes, etc., and other locally known civil flight operations in navigable airspace such as published airways, helicopter routes, VFR flyways, concentrated GA activities, etc.. Determine landing facility LFZ, CFZ, SFZ, and other SFZ as dictated by other known flight operations. Determine if laser irradiance level exceeds limits of the LFZ, CFZ, and any SFZ. Evaluate control measures, procedures, and other mitigations. Report results of the safety analysis evaluation through RFSD to ATO.

40. AFS Safety Analysis Steps • For visible lasers, plot the laser NOHD, SZED, CZED and LFED for the proposed laser operation from FAA Form 7140-1, Worksheet, Items 2, 4 & 5, and topo map if provided. Plot both plan and profile view. • For visible lasers, plot the landing facility LFZ, CFZ, and SFZ for all potentially affected civil landing facilities, and SFZ for known potentially affected civil aircraft routes / flyways, GA activities, etc., both plan and profile view.  • For non-visible lasers, consider the effect of the NOHD on aircraft Note:The LFZ, CFZ, and SFZ need only be considered for visible laser systems. Further, when control measures mitigate all hazards or other issues raised by the safety analysis, irradiance levels may exceed the above levels. • Evaluate any control measures or procedures from FAA Form 7140-1, Notice, Item 6, that may mitigate the effects. • For the proposed laser operation to be non-objectionable to the FAA, the effective irradiance levels listed below shall not be exceeded in the corresponding flight zones. (a) Laser-free Zone is limited to 50 nW/cm2 or less. (b) Critical Flight Zone is limited to 5 W/cm2 or less. (c) Sensitive Flight Zone is limited to 100 W/cm2 or less. (d) Normal Flight Zone is limited to 2.6 mW/cm2 or less.

41. FAA Form 7140-1, Laser Configuration Worksheet, Example

42. FAA Form 7140-1, Laser Configuration Worksheet, Items 2, 4 & 5, Examples

43. xxxxxxxxxxxxxx xxxxxxxxxxxxxx xxxxxxxxxxxxxx xxxxxxxxxxxxxx xxxxxxxxxxxxxx FAA Form 7140-1, Notice of Outdoor Laser Operation(s), Example

44. FAA Form 7140-1, Notice of Proposed Outdoor Laser Operation, Item 6, Example

45. Mitigations for Laser Operations Some examples of physical, procedural, and automated mitigating control measures for laser operations that may be acceptable to the FAA: • Physical beam stops • Beam controls to meet appropriate irradiance levels • Beam direction controls • Shutter or beam termination system • Safety observers Automated systems that detect aircraft and shift or terminate the beam can be used to augment measures above.

46. ATO Letter of Determination (LOD) Objection A determination of objection includes: • Why the proposal is objectionable • A record of any negotiations • Other appropriate information If FAA objections cannot be eliminated, the CDRH variance is not valid.

47. ATO Letter of Determination (LOD) Non-Objection A determination of non-objection includes: • A list of provisions, conditions, and limitations • A reminder that any deviation from the proposal will require further evaluation • A reminder that any state or local requirements must be complied with • NOTAM requirements • AT facility contact information

48. Distribution of Letter Of Determination (LOD) by ATO Determinations are not an approval or disapproval, but rather Non-objection or Objection. Written determination will be sent to proponent. Proponent may be notified via telephone, followed by written response. Copies will be sent to: - ATO, System Operation and Safety, Airspace and Rules - Regional Flight Standards Division - military liaison offices - affected ATC facilities - FDA CDRH

49. NOTAMS NOTAMS are part of the FAA’s safety net to protect users of the NAS from the potential adverse and/or hazardous effects of ground-based outdoor laser operations. ATO will prepare NOTAMs for known laser activities. Regional ATO notifies NOTAM office: - 7 days in advance - May delegate to AFSS/AT facility NOTAM shall emphasize potential hazardous effects.