Do I need a laser safety officer for a cleaning laser?

That answers the first question quickly. The second one is harder: what this person actually does, what expertise they need and which duties remain with the employer despite the appointment is regularly mixed up in practice. A laser safety officer is not someone responsibility can be handed off to.

This article sets out when the obligation applies, what the role covers and which steps come before the first start-up. It replaces neither legal advice nor a risk assessment for your particular workplace — the circumstances of the individual case decide.

Why the question is usually already settled for cleaning lasers

Cleaning lasers remove rust, paint or oxide layers by bringing energy onto a surface in a highly concentrated form. The power levels required for this typically range from a few hundred to a few thousand watts on mobile machines. Such machines are assigned to laser class 4 under the classification.

Class 4 means the radiation is hazardous to the eye even as a diffuse reflection, can injure the skin and can start fires. A hand-held machine also cannot sensibly be fully enclosed — the very mobility that makes it useful for maintenance work rules out structural shielding.

With a cleaning laser the question of a laser safety officer therefore does not really arise as a question. It arises as a matter of timing: the appointment should be in place before the first start-up, not after it.

From which laser class the obligation applies

The relevant rules are set by the regulation on the protection of workers from artificial optical radiation. It requires the employer to appoint a laser safety officer for the operation of laser equipment in classes 3R, 3B and 4.

Below these classes the obligation to appoint does not apply. That does not mean no protective measures are needed — the duty to carry out a risk assessment exists regardless of class. It only means the regulation does not require a specifically named person for those machines.

The decisive factor for the assignment is the manufacturer's classification under the applicable product standard. It appears on the rating plate and in the operating instructions. Anyone taking over a used machine or importing one should check whether such marking exists at all.

What a laser safety officer actually does

The laser safety officer supports the employer. They monitor the safe operation of the laser equipment and contribute to the protective measures. In practice this means:

• Contributing to the risk assessment for the laser activities
• Defining and checking the laser area, its demarcation and marking
• Checking that the personal protective equipment suits the machine and is actually worn
• Observing whether technical protective devices are effective
• Reporting defects to the employer
• Contributing to the instruction of employees

What is not on that list matters just as much: the laser safety officer does not decide on investments, does not order operations to stop and does not carry liability in place of the employer. The role is advisory and supervisory.

What expertise is required

Only someone with the necessary expertise may be appointed. This expertise is usually acquired by attending a corresponding course and has to be refreshed at regular intervals.

The content covers the physical fundamentals of laser radiation, classification and exposure limit values, protective measures and the applicable body of rules. Depending on the provider, a course takes one to two days.

What matters is the fit: the expertise has to match the type of laser equipment in use. Someone who has attended a course on show lasers is not thereby qualified for a cleaning laser in production.

What stays with the employer

This point is the one most often misunderstood. Appointing a laser safety officer does not shift responsibility. The employer remains obliged to:

• carry out and document the risk assessment
• define the protective measures and verify their effectiveness
• provide the personal protective equipment
• instruct the employees
• grant the laser safety officer the necessary time and resources

The last point is where things fail in practice in smaller businesses. Naming a person but giving them neither time nor access to the decisions satisfies the form and misses the purpose.

The risk assessment comes first

The order is unambiguous but is often reversed: first comes the risk assessment, then the measures follow — and those measures include who monitors them.

For a laser activity this covers not only the radiation itself but the accompanying hazards: the particles and fumes produced during ablation, possible fire loads in the vicinity, reflections from bare workpieces and the electrical safety of the installation. With a cleaning laser, extraction and filtration are therefore regularly part of the picture.

The assessment must be drawn up before work begins and updated whenever something material changes — a new machine, a new material, a different workplace.

How the appointment works

The appointment is made in writing. It names the person, the scope and the duties transferred. A verbal arrangement or a note in the minutes is not enough.

It makes sense to combine the appointment with three things: proof of expertise, a description of the scope (which machines, which areas) and a commitment as to how much time is available for the task. Without these, the appointment remains a piece of paper.

The person has to agree. A laser safety officer cannot be named against their will.

One officer for several machines and sites

One person can be responsible for several laser installations as long as they are actually able to carry out the task. The yardstick is not the number of machines but whether supervision remains practically possible.

With several sites this quickly becomes difficult. Someone working in one location and expected to supervise a laser area two hundred kilometres away cannot fill the role. In such cases one person per site is the cleaner solution.

With changing places of work — for instance mobile maintenance at a customer's premises — defining the laser area is part of preparing each individual assignment. That is more effort than at a fixed workplace and should appear in the costing.

What applies to service providers and hired machines

Where cleaning is bought in as a service, the provider brings their own machine, their own staff and their own laser safety officer. That does not release the commissioning business from responsibility: it has to provide the area in which work may take place and keep its own employees away from it. Where work is carried out on other companies' premises, the activities have to be coordinated with one another.

With a hired machine the situation is different. Whoever rents a machine operates it themselves — with all the duties attached to that. Appointing a laser safety officer is one of them, even if the hire runs for only two weeks. This is one of the points overlooked on short-notice projects, and it can upset the schedule.

Instruction is a duty in its own right

Appointing a laser safety officer does not replace instructing the employees. Anyone working at or near the installation must be instructed before starting work and at regular intervals thereafter.

The content covers the hazards, the protective measures, the correct use of the safety eyewear and how to behave in the event of a malfunction. The instruction has to be documented — not for its own sake, but because otherwise, in case of doubt, it did not take place.

The laser safety officer contributes to this. Responsibility for it remains with the employer.

What should be in place before the first start-up

Anyone who has ordered a machine and knows the delivery date can work through the following points in parallel instead of starting them one after another:

1. Begin the risk assessment for the planned activity
2. Decide who takes the role and register them for an expertise course
3. Plan the laser area: demarcation, marking, access
4. Procure safety eyewear matching the wavelength and power of the machine
5. Clarify extraction and filtration
6. Schedule the instruction of employees
7. Draw up the appointment in writing as soon as the expertise is in place

The expertise course is the item with the longest lead time. Anyone who starts it last has the machine on site and is not allowed to switch it on.

Sources

• OStrV — German regulation on the protection of workers from artificial optical radiation — Obligation to appoint laser safety officers from laser class 3R, risk assessment, instruction.
• TROS Laser Radiation — Technical rules on the regulation — Gives the regulation concrete form: assessment of hazards, measurements and calculations, measures to protect employees.
• DGUV — FBHM-139 "Blasting work — cleaning and decoating with laser radiation" — Edition 06/2024. Sector-specific guidance on cleaning and decoating.

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