The Laser Safety Officer's Importance to Laser Safety

====1 THE EFFECTIVE LSO GETS OUT AND WALKS LASER USE SPACE

This section describes a number of laser safety officer (LSO) duties and how to accomplish them. For an LSO to do the job well, he or she must want the position and be allowed the time the job takes. Let us more clearly define the position of the LSO.

Where class 3B, class 4 and nonvisible-beam class 3R products are used, there is the need to appoint an LSO. It may also be appropriate to involve an LSO in risk assessment for the use of class 1M and class 2M laser products.

In the research setting laser safety cannot be achieved and maintained with out an LSO. In addition, the LSO must have clear authority to perform his or her role. Without authority and management support, no safety program can survive.

The level of training required by this individual will depend on the nature of the laser application. If the situation is static, that is, the laser application remains the same and is operated day by day, then the LSO may only need to recognize when the risk assessment is no longer valid, either because of changes to the laser application, because the application has entered a different part of the life cycle, or because something has gone wrong. The need for immediate assistance may depend on the critical nature of the application. If you are involved with a 24/7 process, then expert help may need to be on hand all of the time. If time were not critical, then it would be possible to rely on external assistance.

In some countries, general safety legislation requires the appointment of people with the necessary safety expertise, but no legal requirement to have someone with the title laser safety officer. This is why defining the role is important. Collecting an LSO badge will do little to ensure that laser safety is effectively managed unless the appointee knows what he or she is supposed to do and is competent to carry out the task. Using the LSO title may introduce problems in some cultures, and it may be more appropriate to appoint a laser safety manager, recognizing the more general need for the individual to be a good manager, rather than relying on the historical and perhaps defense-oriented officer term.

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Above: Fig. ====1 Laser inventory form.

Laser Identification Laser Specifications Direct eye Exposure Diffuse eye Exposure Skin exposure ID # Type Make & Model Comments Class Wave length Mode Beam Size Divergence Power CW Pulse Energy Pulse Length Pulse Rate Time MPE Min.

OD Time NOHD Min. OD @ MPE for 10 s (nm) (mm) (mrad) (W) (J) (ns) (Hz) (s) (mW/cm^2)(s)(m)0.5m(mW/cm^2) 1 Nd:YAG C - 3b 1062 cw ~2 >0.35 1- - -105.0 600 1000 2a ND:YLF A - 4 1062 Pulse 1 > 0.35 .2 4. 20 10 10 600 2b Diode array D -- 4 810 Pulse 3 200 - 41 20 20 10 600 xHeNe, diode Various Several 2-3b 400-700 cw ~1 > 0.42 15 - - - 0.25 2.5 1.2 600 < 0.1 0 200

SPECIFIC COMMENTS:

WAVELENGTH: at which the laser is operated or capable of operating; UV <400 nm, VIS 400 to <700 nm, IR 700 nm, (near-IR 700 to <1400 nm, far-IR 1400 nm).

LASER SPECS: typically listed for the smallest accessible beam size, highest power or pulse energy, shortest pulse length, and highest rep-rate.

EXPOSURE TIME: MPEs depend on the length of exposure. Use the actual pulse duration for single pulses; use the following (or greater) for CW or rep-rated pulses: direct eye exposure: UV - 10-30,000 s (i. e. 8-hr work day) (depends on expected exposure time and assumes 2 successive days exposure); VIS - 0.25 s (i. e. blink response time) or at least 1/Hz; all IR -10s diffuse eye exposure: UV - 600-30,000 s (i. e. 8-hr work day) (depends on expected exposure time); VIS or near-IR -600s; far-IR -10s skin exposure: all wavelengths -10s.

MPE: Maximum Permissible Exposure for unintentional, intrabeam (direct) exposures for the listed duration - typically in mW/cm^2 for CW or rep-rated( 1Hz)beams and mJ/cm2 for single pulses at < 1 Hz. Purposeful direct viewing is not permitted unless authorized specifically in an OSP.

OD: minimum Optical Density eyewear (at the designated wavelength) for full protection to MPE levels, typically at a distance of 0.5 m from a source. Optically aided viewing with telescopes, microscopes, cameras, etc. may require higher OD. Note: "alignment eyewear" for visible beams 400-700 nm may be used with an OD reduced by as much as 1.2 than specified in the "Min. OD" column (OD 1.2 is the equivalent to reduce a 15-mW HeNe to MPE level). Employ caution to avoid direct and stray beams. Since there is no aversion response to diffuse light, don’t go below the OD level specified in the diffuse "Min. OD @0.5 m" column without LSO or OSP-documented approval.

DIFFUSE EXPOSURES: based on 100% Lambertian reflection at normal incidence from a non-specular surface at a nominal arm-length distance of 0.5 m.

NOHD: Nominal Ocular Hazard Distance beyond which laser viewing is safe without eyewear (listed for fiber output and occasionally for unaided viewing of diffuse beams if warranted).

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In some establishments it may be appropriate to have a number of each responsible for an area or application. In order to ensure consistent the opportunity to learn from incidents, it would then be appropriate to a one of the LSOs as the senior LSO or some similar title. There should opportunity for the LSOs to meet periodically. The senior LSO may be the central safety committee but at least should have the opportunity to communicate effectively with the committee.

Before an LSO or senior LSO is appointed, consideration should be g the responsibilities, power, and accountabilities of the position. Will the LS advice to managers or supervisors in the work area or will he or she have the to change things? In some places where we have given advice, the LSOs have given the power to stop laser work if they consider that laser safety is not adequately managed, with the full support of the senior executives in the organizations Where the laser application is relatively static or there is a need for add expertise beyond what could reasonably be expected from the on-site LSO it may be appropriate to appoint an external expert. There is no internationally agreed-upon title for this expert, but laser protection adviser and laser adviser have been used. The term adviser recognizes that, as an external or body, they cannot have executive power over the organization. They ca advice and, if they feel the advice is not being taken up, either terminate contractor, in exceptional cases, notify the regulatory authority of their con When appointing an external organization or person to act as an advise important to clarify the role you wish them to undertake.

Above: Fig. ====2 ANST style warning sign, C and/or Class 4.

====2 LASER SAFETY COMMITTEE

If you have several LSOs, they can meet periodically. Even with a single LSO, it may be worth considering a laser safety committee. This would allow principal laser users to meet and discuss common issues. It would also allow the LSO to inform users of any changes to legislation and standards. The frequency of the meetings will depend on the complexity of the laser applications and how far along the road to successful laser-safety management the organization is. It’s likely that at the start of laser use, it will be necessary to meet at least monthly and perhaps weekly. As the laser application matures, meetings every three or six months may be adequate.

The committee membership needs to contain a representative of management, safety (LSO), and laser users. The laser safety programs at many R&D institutions have been successful without a laser safety committee. In these cases communication between the LSO and users is always active. At times a committee may be formed for a specific short-term goal, such as updating the laser section of the safety manual or for an incident investigation.

====3 INVENTORY

Knowing what types of lasers and wavelengths are in use is critical to developing control measures. In the case of an inventory trap, the name of the laser does not indicate what wavelength it’s being used. An Nd:YAG laser is capable of many wavelengths, not just the traditional 1064 nm, but also 532 nm and 266 nm.

How should you obtain inventory data?

1. Consult with your property management group (this might be the best approach and least time intensive).

2. Have the LSO be part of the approval chain or at least get copies of approved purchases.

3. Request an inventory from each department.

4. Perform on-site audits.

5. Have a summer student or intern perform on-site inventory counts.

For many years the most important task anyone involved with laser safety did was count the lasers. While we have moved on to appreciate that just knowing how many lasers you have won’t protect you from laser incidents, inventory may still have a part to play in managing laser safety.

In the days when all lasers were either very large, extremely expensive, or both, it was not too difficult to identify where they all were. With modern lasers getting smaller and smaller, and also costing less, we may reach a point where just counting the lasers would be a full-time task. Imagine being in a research laboratory with a bin of 10,000 laser diode chips. Keeping track of them all is not an easy task, nor is it warranted.

We need to keep the purpose of the inventory in mind. Is it for stock control, for security, or for safety management? We will only consider an inventory for safety management purposes, but you may find that this can meet all three requirements. The level of the inventory will depend on the level at which we are managing laser safety. The corporate safety office of a large organization may be interested in the types of lasers and their applications, whereas a single laboratory may need a lot of detail, probably including the following:

1. Laser type

2. Model number

3. Serial number

4. Laser class during normal use

5. Laser class during servicing

6. Date of installation

7. Location

Other information will be useful for managing laser safety and will form part of the information required in Section 1 of the laser-safety management program:

1. Laser medium

2. Means of excitation

3. Initial beam diameter

4. Beam divergence

For some laser products, this information will need to be repeated for each individual laser. To complete the information and to make the record useful for an audit, it’s recommended that a brief outline of the laser application be added to the inventory. It’s also helpful to include photographs.

No matter how tightly any organization tries to implement their laser safety policy, it can still fall into the trap of inadvertently acquiring a laser product. This could happen because a product includes a laser as an "extra." One example of this is an infrared thermometer. Such products tend to have a sighting laser to show the user what surface the infrared is being detected from. If you just specified a thermometer, you may not have expected a laser with it. Also, a number of infrared remote controls for use with computer presentations have lasers fitted in them.

It’s also possible that researchers could order a piece of equipment to carry out a specific task, completely ignorant of the process. As far as they are concerned they are buying a scientific tool. Some equipment may contain one or a number of lasers (i.e. gene sequencer, flow cyctometer). It could be argued that the supplier should have informed the researcher before the equipment was ordered, but realistically, that won’t always happen. To be fair, such equipment normally presents no risk from the laser beam during normal use or even during user maintenance operations. What happens, though, when the service engineer arrives, removes all of the covers, overrides the interlocks, and starts shining laser beams all around the laboratory? Sometimes that is the first time the user realizes there is a laser in the equipment.

A handy tool for laser inventory is to include a list of the lasers that make up or are found in each standard operating procedure (SOP). The inventory matrix in Figure ====1 not only lists the laser, but also allows the LSO to perform a safety eyewear analysis of each. A sample form is shown at the end of this section.

====4 TRAINING

While the LSO need not perform user training he must assure that it’s accomplished (see Section 7 for a full discussion). The way most people tackle laser safety training is to look around for available courses and make a decision based on cost, location, or scheduling convenience. Sometimes the course meets their needs perfectly and sometimes they come away dissatisfied, but more likely they only realize they don’t have the necessary tools to move their laser-safety management forward when they try to get things done. This is not to suggest that all laser safety courses are bad. It’s more a case of trying to ensure that you get the training you need for whatever role you are intending to undertake. To use the industry jargon, you need to carry out a training needs analysis. In order to do this you need to be able to step back and think through what the task is.

Unfortunately, this can be difficult because you may find that you don’t know enough without going through a training course to specify what the task will be.

A formal training course may not be the best option. Tutorial-type sessions are available where an external consultant will spend time analyzing the training needs. The LSO may be able to gain enough information during that tutorial to meet his or her own needs, especially if the situation is relatively static and external assistance is available.

Training for laser users tends to be in two parts: the training to undertake the task plus an appropriate level of laser safety training. The appropriate level is important here. Not everyone has an in-depth interest in laser physics and many switch off their attention the moment electrons and energy states are mentioned.

Forcing them to sit through several hours of theory would be a complete waste of time. However, there are practical issues that do need to be covered and, of course, these may go beyond any risks presented by the laser beam.

When an organization has a group of people who are going to work with the laser, the most effective laser safety training can be provided around the equipment. It will be reassuring for the workforce to hear how the laser-safety issues in their particular work areas are being addressed. The laser-safety management program can be a useful tool to help with this.

Whatever training everyone receives, a record should be maintained. It’s also useful to record whether the effectiveness of any training has been assessed, and how. This could be formal tests or examinations at the end of a course, but it may also be implementation of the material after the course. Again, the production of an applicable laser-safety management program is very effective at demonstrating how competent someone is.

====5 SIGNS

Signs can be a very visible form of administrative control. The trouble is that they soon become "wallpaper." They are an important aspect of laser-safety management because they are very easy to audit, especially by regulatory authorities. (Quick hint: see Section 5, Laser safety tools.) There are national requirements for safety signs in areas where some laser products are used, as well as requirements under laser safety standards for equipment to be labeled. They are only effective if people notice them, read them, and take some action based on what they have read. Here the term read is used in its widest sense since may signs will include some form of pictogram.

Some federal regulations require that you display particular signs. However, these signs should only be displayed when they are relevant. This can be achieved by either covering signs when they are not relevant or turning them over. Signs falling into this category could include a warning about the laser and the environment, that is, whether it’s a laser controlled area, some kind of prohibition sign, such as "authorized persons only," and perhaps a mandatory "laser safety eyewear must be worn" sign. It may be appropriate to display information about the laser products contained within the room, but usually this is not important.

How do you deal with beam alignment? For many laser applications this process is carried out by service engineers; in others it’s carried out by the user, especially in research environments. One of the most effective ways of displaying a sign is to get a piece of flip-chart paper and put it on the door with an explanatory, clear, written message such as "Laser Alignment in Progress until 3 pm today [insert today's date]. Please don’t enter." This type of sign works for two reasons. First, it’s big and new. This means there is a higher probability that people will notice it. Second, it’s time bounded; that is, you have given a finish time. If it looks as if the work is going to go beyond the stated time, then it’s better to alter the time than to put up a new notice. If this notice is always displayed on the door and the researcher is known to be in the coffee lounge or on a week's vacation, then the respect for the notice will be lost.

====6 WARNING LIGHTS

Warning lights can be an improvement on signs, but the message must be clear and the lights must be located where they can be seen.

Fitting illuminated panels above doorways is not effective unless the lights flash.

There has been a reluctance to fit lights to the sides of, or on, doors because they often present a risk of being bumped by passersby - perhaps even resulting in injuries. However, modern ultra-thin display panels are becoming cost-effective alternatives. They can display warning signs and any other safety information.

They can be made to flash if required and usually can be mounted in any appropriate position.

It’s important that any light be labeled so that all who need to know are aware of the meaning.

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TABLE ====1 Specific Instructions for the Formatting of Laser Area Warning Signs

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====7 AUDITS

Without the performance of audits, an organization will never have assurances of laser safety. The purpose of the laser safety audit is not to check up on users, but to determine if policies and controls are being followed. If the policies and controls are not being followed, an audit can determine if the neglect is willful or if policies are out of step with the users' needs. In addition, visiting user sites to conduct a laser safety audit allows the LSO to see the space and find out what activities are happening at the institution. One of the values of seeing the space is to determine if the space is right for the work going on. Is there sufficient clearance around optical tables? Are there windows that should be covered? Are there temperature problems in the area? The LSO will never be aware of these issues if he or she never leaves the office.

ANSI Z136.1 Safe Use of Lasers references the LSO's duty of performing audits in several sections: "The LSO shall be responsible for hazards evaluation of laser work areas." "The LSO shall ensure that the safety features of the laser installation facilities and laser equipment are audited periodically to assure proper operation." "The LSO will survey by inspection, as considered necessary, all areas where laser equipment is used." Therefore, it’s safe to say that audits for laser safety compliance are expected to be conducted for facilities using class 3B and class 4 lasers. The composition, frequency, and rigor of that audit rests in the hands of the LSO. A common practice is for institutions to develop laser audit checklists or survey forms. In many institutions, a sole LSO or a number of deputy LSOs perform these audits.

Some institutions request users to perform a self-assessment audit.

Many items on the common audit list and its findings are subjective because they are based on the experience and interest of the LSO or auditor in particular items on the checklist. Beam block usage is an example; to one set of eyes, it might be completely adequate, but to another, inadequate. Possibly, experimental considerations prevent additional beam block placement.

Following is a rationale for some of the audit items and a sample audit form.

Interlock log: SOPs that require interlock checks need to be current.

Current means one check per quarter (no more than 90 days between checks is the goal). These checks are generally operational performance checks. For complex systems, for the tester is required to follow a written procedure and note problems. The preference is a written procedure for all labs to follow. This ensures consistency between checks regardless of who in the lab performs the check. If problems are noted, follow-up action and documentation of resolution are required.

Alignment procedure: At a minimum, there should be a section in the SOP binder that gives general laser alignment guidance. Whenever possible, laser use-specific alignment procedures should be developed for the different laser activities. System start-up procedures could go in this section.

====7.1 POSTING AND LABELING

Hazard communication poster: Laser hazards need to be on a hazard communication poster. Check the poster to see that it represents all hazards in the room, not just your work.

Laser sign: Laser use areas with class 3B or class 4 lasers are required to be posted with a laser warning sign. The sign should accurately convey the wavelengths in use and any laser protective eyewear requirements.

The sign needs to be on all accessible entrances to the laser use area.

Emergency contact: Many lab doors have emergency contact information posted. It must be readable and accurate.

====7.2 BEAM ENCLOSURES

The goal is to contain the laser beam and any stray radiation to the optical table or intended use area. Enclosures that confine the beam are one of the best methods to accomplish this. This means individual portions of the laser beam can be contained as in a beam tube, or the optical set-up can be contained by means of a barrier around the entire table or portions of it. This barrier can be several inches higher than the intended beam path, open or closed at the top, or with panels several feet high enclosing the entire table.

Total enclosure: This is the preferred but not always possible method.

Panels can be labeled with interlocked or non-interlocked warning labels.

Totally open: While not preferred, in some cases this may be the only workable option. In such a case, use of properly placed beam blocks is critical to safety. A check for stray reflections is required after each alignment or beam manipulation.

Combination: In some cases beams won’t be totally open or totally enclosed, but a combination of both. A combination approach is acceptable and realistic.

Perimeter guard: A guard must be of sufficient height above the intended beam height to prevent a likely stray reflection from rising above it.

Beam tubes: For open distances between optics over 2 feet, it’s recommended that beam tubes be mounted. It’s preferred but not required that the tube be made of a material opaque to the laser radiation. Keeping hands out of the beam is the major goal.

====7.3 OPEN PATH WALKWAY

At times the laser beam may need to pass from one optical table to another across an open walkway space. In such cases the level of controls can vary depending on the hazard presented by such a beam. If the beam is below MPE, the user may choose to use administrative means, that is, signs.

Permanent beam tube: This is the preferred control, but it may present emergency or traffic control problems.

Removable method: To avoid the problems presented by a permanent beam tube, a removal tube may be the best solution. In such cases, a control must be in place to prevent the laser radiation from crossing the open space without the tube or awareness of users in the lab. Some approaches: removable tubes; tubes, bars, or swing arms; chains across the area; and swing gates.

====7.4 PROTECTIVE EYEWEAR

Laser protective eyewear is a critical part of laser safety for the individual. Chiefly, it relies on the user to wear the proper eyewear and take care not to abuse the eyewear. All laser users need to know they have an obligation to make sure everyone in the laser lab wears the proper eyewear when a laser radiation hazard is present.

Full protection: This type is designed so that the optical density of the eyewear will absorb all the laser radiation from a direct hit for a period of up to 10 sec. Intrabeam or direct viewing of the laser beam is strictly forbidden. Don’t stare into laser with remaining eye.

Alignment: Use of alignment eyewear is allowed for visualization of visible beams for alignment activities. The NIF LSO grants approval of such eyewear.

Labeled: The labeling required is the optical density (OD) and wave lengths the eyewear is designed to provide protection from. Labeling on some common styles of eyewear can wear off. All eyewear needs to be labeled and readable; otherwise it must be removed. Labeling can be self adhered.

Quantity: The quantity on hand must be sufficient for the expected number of daily users and anticipated visitors. Visitors should be limited to full protection eyewear only.

Condition: Laser eyewear must be in good condition, free from scratches, abrasions, and burns in critical vision areas. The LSO needs to be contacted to determine if the eyewear still provides the level of protection required.

Correct OD: The OD on eyewear must meet the limits set forth in the laser table for the laser application.

Prescription age: Because of the cost of prescription laser eyewear, the user may use a pair with a prescription several years old. A consult with health services is required to determine if a new set of eyewear is required.

Storage: Eyewear must be stored in a manner that preserves its condition.

Storage can be outside the laser use area or inside. Each has advantages and disadvantages.

Holder: The storage of laser protective eyewear will have a direct effect on its useful lifespan. The practice of eyewear being thrown in a drawer or left on tables at the end of the day is unacceptable.

====7.5 BEAM CONTAINMENT

Beam blocks: These should be made out of a noncombustible material for the power output expected to strike the block. They must not transmit the wavelength in use. Cardboard may be suitable for some applications, while metal will be required for others. The block should not be reflective for the wavelengths being used. All active beam blocks must be secured to the optical table (unless foot print stops tip over and are approved by the LSO). The size of the blocks must be sufficient to block the beam diameter and possibly a misaligned beam. A label on the block indicating that it’s a beam block and not to be moved is recommended but not required. Such labeling is considered a good practice to help locate any beam blocks that might be misplaced or knocked over.

Path to door blocked: There should not be a direct path from the laser use area to a door leading outside the laser use area. Blockage of this path can be provided by a curtain, a partition, or a barrier on the laser table.

====7.6 FIBER OPTICS

Container for sharps: If it cuts and slices fibers, a container is required for sharp ends, following standard sharps protocols.

Fiber ends labeled: Near or where the beam exits the fiber, a label is required to make staff aware of this hazard point (unless alternate controls have been approved).

Conduit labeled: Conduits carrying laser radiation levels above class 1 need to be labeled at least every 3 m and at points where they enter or exit a wall.

====7.7 HOUSEKEEPING

Laser work surfaces: The area on the optical table encompassing and directly adjacent to the beam path needs to be free of all nonessential reflective sources. This includes optics, tools, foil, and storage containers. This does not include established alternate beam paths for related experiments.

Related work surfaces/adequate storage space: Space is always of a premium in any laboratory; the more organized the space is, the safer the work area will be. Divisions and programs should make resources avail able to individual labs to aid in this goal. Users have a dual responsibility here: first to remove unused equipment, either to surplus or storage outside the lab, and most importantly to maintain an ongoing effort to organize and put away supplies.

Chemical storage: Chemicals present several hazards to the user as an ignition and combustion source to an irradiant. Their proper storage and use is critical to personnel safety, particularly when laser dyes are in use. In choosing secondary containers, keep in mind that while plastic trays are cheap and easy to obtain, they don’t offer the resistance to fire that metal trays do, nor do they give off toxic chemicals when burning.

High storage: Adherence to seismic guidelines needs to be checked on shelves and on the tops of racks.

Trip hazards: A number of commercial devices are available to protect cords and hoses from tears and prevent people from tripping over them.

The application of these devices needs to be reviewed during the audit.

Emergency lighting: The auditor should make sure emergency lighting is present, working, and located in adequate locations.

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Auditor SOP # Audit Date:

Type of Audit: Annual New Amend Self-Assessment Other Facility Name: Building: Rooms:

Principal Investigator:

Room Contact During Audit:

Classes of lasers in this experiment/rooms: Class 4 Class 3b Class 3a Class 2 Class 1 embedded Posted Documentation and Security Measures

1. Access door interlocks & status panel functional: Key Code; Code Comments: Y N NA

2. Access door signs current format, emergency contact current: Comments: Y N NA

3. Posting on ancillary doors: YN NA

4. Current SOP available: YN NA

5. Eyewear requirements posted: YN NA

6. Interlock check sheet available & current: YN NA

7. Alignment procedure (class 3b & 4): YN NA

8. Interlock check procedures available for complicated systems: YN NA Laser unit safety controls:

9. Laser classification labels present on commercial units: YN NA

10. Protective housings in place: YN NA

11. Beam shutters interlocked & functioning as per interlock check sheet: Y N NA

12. Interlock bypass functioning: YN NA Engineering and Administrative Laser Safety Controls

13. Lasers & optics secured to table: YN NA

14. Beam properly contained (not a hazard to persons sitting or standing): Y N NA

15. Beams enclosed where available: YN NA

16. Noncombustible, nonspecular beam barriers in place: YN NA

17. Adequate controls where beams leave tables or leave enclosures: Y N NA Above: Fig. ====3 Sample Audit Form.

18. All beams attenuated or low power when practical: YN NA

19. Windows/door openings covered: YN NA

20. Beams blocked from open by-passed doors: YN NA

21. Nonessential reflective materials out of beam paths & surroundings: Y N NA

22. Administrative controls employed, barriers demarcated: YN NA

23. Upward directed beams are labeled: YN NA Other Safety Measures

24. Laser eye exams by all personnel (3b and 4 lasers): YN NA

25. Proper eyewear available for all personnel, ODs OK: YN NA

26. Proper storage of eyewear, where? YN NA

27. Proper skin protection available & employed: YN NA

28. Are all current users on training matrix? YN NA

29. Collecting optics used (microscopes, binoculars, telescopes): YN NA Non-beam Hazards

30. High voltage hazards minimized: YN NA

31. Optical tables bonded to building ground: YN NA

32. Optical tables seismically secured (if no, how many?): YN NA

33. Housekeeping fire hazards minimized: YN NA

34. Good housekeeping on optical tables: YN NA

35. Fiber optic use: YN NA

36. Container for fiber sharps: YN NA

37. Fiber ends/connectors labeled: YN NA

38. Fiber conduit labeled: YN NA

39. Other non-beam hazards minimized: YN NA

Comments:

Auditor signature, Date

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