Overview of Regulations for
Electronic Product Radiation Control
Aspects of Radiation Control Included in Performance Standards
Radiation Controls
- Emission (or leakage) limits; time and spatial limits
- Means to terminate radiation, such as beam blocks or off switches
- Timers and controls for setting radiation parameters - including accuracy
specifications
- Means to indicate when/how much radiation is emitted
- Interlocks and spatial limitations to prevent human access to radiation
areas
- Shields and doors to contain radiation
- Failure modes and factors affecting increased radiation with age or use of
the product
- Definitions of technical terms
Testing
- Radiation parameters to be measured
- Instrumentation specifications
- Measurement conditions, such as time, distance, medium, etc.
- Specifications on accuracy, reproducibility, linearity, and/or variance
Labeling
- Warning labels
- Precaution labels; use labels
- Radiation specification labels (from measurements)
- User manuals: dose/exposure rate information; safe use instructions;
precautions
- Service manuals: safety instructions for installation, replacements (and
compatibility), maintenance, service
- Certification and identification labels
Summary of Specific Performance Standards
Television Receivers, 21 CFR 1020.10
- Applies to receivers and monitors that receive and convert a signal to
display a "television picture"
- Limits radiation at 5 cm from the surface to 0.5 mR/hr during conditions of
maximized user and service controls and a single worst-case component fault
Microwave Ovens, 21 CFR 1030.10
- Applies to ovens for heating and cooking food (household or commercial; not
industrial food processing)
- Limits radiation at 5 cm to 1 mW per cm2 prior to purchase and 5
mW per cm2 throughout useful life under conditions of allowable
door positions and primary interlock failure, or with conducting wire
- Limits access by human body to energy-containing space and to 1 of 2
required interlocks; at least 1 interlock must be "monitored" to
disable the source
- Requires user caution label and user and service manuals
Lasers and Laser Systems, 21 CFR 1040.10
- Applies to lasers, products containing lasers, and products intended to
contain lasers
- Specifies classification and user logotype with precautions based on
radiation accessible during use; limits radiation from viewing optics, ports
and displays to less than Class I; specifies interlocks/labels based on
radiation accessible during maintenance and service
- Requires, based on increasing hazard class, radiation indicators and safety:
aperture label, beam attenuator, emission indicator (some with time delay),
remote door interlock, key control, scanning safeguards, etc.
- Requires user, maintenance and service manuals
Specific Laser Products, 21 CFR 1040.11
- Requires indication of power levels on medical lasers with +/- 20% accuracy
- Limits radiation to less than Class IIIa for surveying, leveling and
alignment lasers
- Limits radiation to less than Class IIIa for demonstration lasers, including
display or entertainment (NOTE: Variances, with extensive human access
limitations, are often granted for laser light shows.)
Summary of Reporting Requirements
Variances; Exemptions, 21 CFR 1010.4, 1010.5
- Manufacturers may request variances (i.e., an individual standard) for
alternate, or equivalent, safety
- Manufacturers may request exemption from a performance standard for reason
of national security, investigations, etc.
Accidental Radiation Occurrences, 21 CFR 1002.20
- Documents any actual or possible unexpected exposure during manufacturing,
testing or use of ANY electronic product
- Reports are due immediately after the event is known (MDR may be
substituted, if applicable)
Product Reports (also Supplements, Abbreviated), 21 CFR 1002.10 – 1002.12
- Applies to products listed in Table 1 of 1002.1 (most are subject to
performance standards), unless excluded by 1002.1 or 1002.50
- Documents information on manner of conformity to standards, labeling, test
instrumentation, test procedures, quality control, etc.; submitted prior to
family of products being introduced into commerce
- Abbreviated reports were added in Oct 1995 to reduce burdens
Annual Reports, 21 CFR 1002.13
- Applies to products as listed in Table 1
- Documents results of testing and user safety concerns; annually or
quarterly updates contain model listings
Notice of Defect or Noncompliance, 21 CFR 1003.20
- Applies to ALL radiation-emitting electronic products
- Documents safety concerns, corrective actions, and information to users
for safe use
Summary of Other Radiation Control Regulations
Certification and Identification Labels, 21 CFR 1010.2 – 1010.3
- Label(s) on each product that is subject to a standard, identifying the
name and address of the manufacturer and date of manufacture
- Label on each product subject to a standard of the manufacturer's
statement that the product complies with DHHS radiation standards or similar
language
Defect in an Electronic Product, 21 CFR 1003.2
- Applies to products not subject to performance standards and to products
subject to standards if the standard does not address the specific safety
issue
- Exists, for products that USE radiation to accomplish the purpose of the
product and emissions are intended, when radiation
- Fails to meet design specifications, or
- Is unnecessary and creates a risk of injury, or
- Fails to accomplish its intended purpose
- Exists, for products that DO NOT USE radiation to accomplish the purpose
and do not intend to emit radiation, when radiation
- Is emitted that creates a risk of injury, or
- Fails to meet its design specifications
Determination of Noncompliance or Defect, 21 CFR 1003.10 – 1003.11
- FDA or manufacturer informs the other of safety concern based on product
testing, inspection, research, or review of reports or other data
- Manufacturer notifies purchasers, dealers and distributors of the hazard
and appropriate use until corrected (per 1003.21)
Exemption from Notification, 21 CFR 1003.30 – 1003.31
- Based on data to show there is no significant risk of injury as a result
of the defect or failure to comply
- Granted by FDA on own initiative or in response to written request from
the manufacturer
Repurchase, Repair, and Replacement, 21 CFR 1004.1 – 1004.3
- Correction of noncompliance or defect which is neither successfully
refuted nor granted an exemption
- Plan, including (draft) notification to users, documented by the
responsible firm and approved by FDA (usually prior to implementation); may
include one or more of the options to repair, replace or refund as needed
Importation Requirements, 21 CFR 1005.3 – 1005.10
- Form FDA 2877 is filed by importer for entry (19 CFR 12.90)
- FDA samples and tests products to verify compliance if necessary
- Products failing to meet applicable standards are refused entry by U.S.
Customs
Bringing Imported Products into Compliance, 21 CFR 1005.21 – 1005.25
- Under a U.S. Customs term bond, importer submits written application
(usually Form FDA 766) for approval by FDA
- FDA supervises activities and the importer pays fees for such supervision
Summary of Compliance Actions for Radiation Control Act Violations
FDA Administrative Actions, 21 CFR 1004.6, 1010.2(c), 1005.3
- Recall products (corrective actions are approved and substantiated)
- Disapprove quality control and testing program (i.e., embargo products)
- Import Alert, Automatic Detention, and Refusal (with U.S. Customs Service)
Actions through U.S. District Courts
- Injunction from shipping in interstate commerce or to require reporting
and certification requirements
- Civil (money) penalties for failure to report, failure to certify, failure
to comply with standards