Phone call to the CDRH - surprising results!

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Ray Condo

unread,
Oct 6, 2004, 11:16:06 PM10/6/04
to
Disclaimer: Long-winded post follows. I do not work for the CDRH. I
have no hidden agenda to either praise or pan the government. I am
not a laser expert. Do not read post while operating heavy machinery.
Not intended for children under the age of 3. no deposit, no return.

Now then: With all the discussion about CDRH rules concerning lasers
in schools, laser shows for demonstration purposes, etc, etc, etc, I
decided to try calling the CDRH directly. (Insert ominous music here)
I called 1-800-638-2041 and got transferred to Walter Snefko at
extension 120. Unfortunately, he was unclear on several of my
questions, and admitted that the real laser device gurus were only
reachable by dialing the non-toll-free number. (Figures…)

So with no concern for daytime long distance rates I took his
suggestion and dialed (240) 276-0120. Having been primed with
information from Walter, I then asked for Jerry Dennis at extension
135. Jerry was available, and was *AMAZINGLY* helpful. We spoke for
about 15 minutes, and he encouraged me to call again if I had further
questions. He also said that two others in the office, Dale Smith
(extension 147) and Frank Mackson (extension 145) were even more
familiar with CDRH rules as they applied to laser shows. He said that
Dale Smith, in particular, was a very valuable resource.

Ok – here's what I asked:

1) If a laser show has less than 5 mw output power, do you have to
have a variance? (I know, we've talked about it here before, but
since I was at the horse's mouth already it seemed a good time to
ask…)

Answer: No. If you are under 5 mw you do NOT need a variance and you
can do what ever you want. (This was correctly pointed out by others
here on Alt.lasers before; I was really just warming up with this
question.) However, he *DID* caution me to remember that 5 mw can
still be an eye hazard. Basically he said to avoid sending static
beams into the audience. I pressed him about scanned beams and the
like, and he temporized. I gather that he knew that they really don't
have jurisdiction here because of the power level, but he wanted to
discourage blatantly stupid behavior nonetheless.

2) If a laser puts out more than 5 mw, but through the use of a beam
splitter, diffraction grating, filter, or other device the resulting
beams that exit the projector are EACH less than 5 mw, is the show
still considered "under 5 mw" and thus exempt from a variance?

Answer: Yes. As long as the beams that exit the device (projector,
housing, etc) are each less than 5 mw, and the beams are separated far
enough apart such that it is not possible for multiple beams to enter
the same pupil, then the entire device is exempt. Thus, you can have
a 20 mw laser putting out, say, 8 beams from a diffraction grating,
and as long as none of the beams are over 5 mw the entire setup is
exempt.

As an aside, he went into considerable detail as to how these beams
would be measured for intensity. The basic standard is to use the
standardized pupil diameter (listed in the CDRH main document – I
forgot to write it down) and measure the power at a minimum distance
of 20 centimeters (!) from the apparent source of the laser light.
(ie the window on the projector housing, the aperture of the scan
head, or the output coupler of the laser if the other two do not
apply.) The pupil size used for the calculation changes if the
environment is such that it would be likely that audience members
would be using binoculars. (Binoculars?!? I asked…) "Yeah, like in a
large arena – folks typically bring a set to make it easier to see the
stage…" He floored me with that one, but it makes sense if you think
about it.

3) How are laser demonstrations - especially in classrooms - handled?
Are they subject to CDRH rules?

Answer: No. The CDRH deals with commercial products only: either
laser systems that are assembled to be sold to the public, or laser
shows that are created (designed) to be "sold" as a "product" to an
audience. Laser shows that are not part of a commercial endeavor are
NOT subject to CDRH rules, no matter what power levels are involved.
This was AMAZING to hear as it runs counter to just about everything
I've read here and elsewhere, so I questioned Jerry at length about
it.

Basically, he said that there are white areas, black areas, and grey
areas. The white would be what you do in your basement for you and
your family, friends, or neighbors. This includes classrooms (see
below). The black would be when you set up a show at a local
auditorium and charge admission. The grey area is when you have a
show that could be considered commercial in nature, even if you choose
not to charge admission. Examples include doing a laser show for free
at some other event, when it would normally be customary to pay to
gain admittance to that event. However, he did make it clear that in
order for the CDRH to have legal authority, the situation must involve
COMMERCE of some sort. Thus, volunteering to show off your class IV
lasers in the church basement after the service is over (call it your
Sunday afternoon laser club?) would be an exempted laser show.

Displays in a classroom were one case that I specifically asked about.
I asked about the case of a private citizen volunteering to do a
display for the class, as well as the case of a teacher doing a
demonstration for his class. In either case, because there is no
commerce involved, the CDRH does not have jurisdiction and a variance
is not required NO MATTER WHAT POWER LEVEL LASER IS USED.

Now, before you start thinking that this is a gaping legal loophole,
Jerry did inform me that there is an entirely different set of
guidelines that are normally applied to classrooms.

The American National Standards Institute has released a document
dealing with what are considered acceptable practices for using lasers
in school environments. The standard is ANSI Z 136.5, and evidently
it is available from the Laser Institute of America for a nominal fee.
(No, I haven't checked yet.) Nearly all college environments dealing
with class 3B and class IV lasers are expected to adhere to this
standard according to Jerry.

He also pointed out that compliance with the ANSI standard is not
required by the CDRH. (Though it might well be required by the school
district, as well as local or state laws dealing with lasers) It is
simply an example of what a legal court of law would accept as a
"reasonable standard of conduct" for the safe operation of a laser in
a classroom environment. (Translation: if you do not follow the
standard, no one from the CDRH will shut you down, fine you, or take
you to jail, but if anyone ever gets hurt at your show and decides to
sue you, they have a better chance of winning if you failed to follow
the guidelines set down in the standard.) Short answer is that I'm
going to at least have a look at that standard before I consider
taking any of my lasers into a classroom.

I have to admit that I was a bit concerned about calling the CDRH. I
wondered if they would take the time to talk to an "enthusiast" that
really didn't have much intention of ever going commercial. I was
afraid I'd be accused of wasting their time. I was also a little
afraid that they would read me the riot act for even asking some of
these questions.

What I found out is that the folks there are VERY helpful. I'm not
kidding, this Jerry Dennis fellow sounds like a great guy! He took
the time to answer my questions at great length, and always pointed
out that even if certain circumstances were not under CDRH control it
would still be foolish to ignore the safety precautions they promote.
He really was easy to talk to, and was quite supportive of my hobby.
Despite the fact that he was clearly used to speaking to engineers and
PHD's about laser physics, he was able to speak at my level about
everything we talked about. He also had some good information about
laser safety. (Hey – how about that? A government employee that
actually gives great customer service!) I'll probably call him (or
maybe Dale Smith) again in the future.

Really sorry for the monster-long post (sometimes I just don't know
when to shut up), but I thought some might find it interesting…

spam@frontiernet.net C what I mean

unread,
Oct 7, 2004, 12:14:44 AM10/7/04
to
Ya know.. we all bitch when we don't like something.. I think it is great
when someone takes the time to praise others when warranted.

I too have had great luck with what little contact I have had with the CDRH.

Craig

"Ray Condo" <Cond...@gmail.com> wrote in message
news:9b5a6d4e.04100...@posting.google.com...


> Disclaimer: Long-winded post follows. I do not work for the CDRH. I
> have no hidden agenda to either praise or pan the government. I am
> not a laser expert. Do not read post while operating heavy machinery.
> Not intended for children under the age of 3. no deposit, no return.
>
> Now then: With all the discussion about CDRH rules concerning lasers
> in schools, laser shows for demonstration purposes, etc, etc, etc, I
> decided to try calling the CDRH directly. (Insert ominous music here)
> I called 1-800-638-2041 and got transferred to Walter Snefko at
> extension 120. Unfortunately, he was unclear on several of my
> questions, and admitted that the real laser device gurus were only

> reachable by dialing the non-toll-free number. (Figures.)


>
> So with no concern for daytime long distance rates I took his
> suggestion and dialed (240) 276-0120. Having been primed with
> information from Walter, I then asked for Jerry Dennis at extension
> 135. Jerry was available, and was *AMAZINGLY* helpful. We spoke for
> about 15 minutes, and he encouraged me to call again if I had further
> questions. He also said that two others in the office, Dale Smith
> (extension 147) and Frank Mackson (extension 145) were even more
> familiar with CDRH rules as they applied to laser shows. He said that
> Dale Smith, in particular, was a very valuable resource.
>

> Ok - here's what I asked:


>
> 1) If a laser show has less than 5 mw output power, do you have to
> have a variance? (I know, we've talked about it here before, but
> since I was at the horse's mouth already it seemed a good time to

> ask.)


>
> Answer: No. If you are under 5 mw you do NOT need a variance and you
> can do what ever you want. (This was correctly pointed out by others
> here on Alt.lasers before; I was really just warming up with this
> question.) However, he *DID* caution me to remember that 5 mw can
> still be an eye hazard. Basically he said to avoid sending static
> beams into the audience. I pressed him about scanned beams and the
> like, and he temporized. I gather that he knew that they really don't
> have jurisdiction here because of the power level, but he wanted to
> discourage blatantly stupid behavior nonetheless.
>
> 2) If a laser puts out more than 5 mw, but through the use of a beam
> splitter, diffraction grating, filter, or other device the resulting
> beams that exit the projector are EACH less than 5 mw, is the show
> still considered "under 5 mw" and thus exempt from a variance?
>
> Answer: Yes. As long as the beams that exit the device (projector,
> housing, etc) are each less than 5 mw, and the beams are separated far
> enough apart such that it is not possible for multiple beams to enter
> the same pupil, then the entire device is exempt. Thus, you can have
> a 20 mw laser putting out, say, 8 beams from a diffraction grating,
> and as long as none of the beams are over 5 mw the entire setup is
> exempt.
>
> As an aside, he went into considerable detail as to how these beams
> would be measured for intensity. The basic standard is to use the

> standardized pupil diameter (listed in the CDRH main document - I


> forgot to write it down) and measure the power at a minimum distance
> of 20 centimeters (!) from the apparent source of the laser light.
> (ie the window on the projector housing, the aperture of the scan
> head, or the output coupler of the laser if the other two do not
> apply.) The pupil size used for the calculation changes if the
> environment is such that it would be likely that audience members

> would be using binoculars. (Binoculars?!? I asked.) "Yeah, like in a
> large arena - folks typically bring a set to make it easier to see the
> stage." He floored me with that one, but it makes sense if you think

> laser safety. (Hey - how about that? A government employee that


> actually gives great customer service!) I'll probably call him (or
> maybe Dale Smith) again in the future.
>
> Really sorry for the monster-long post (sometimes I just don't know

> when to shut up), but I thought some might find it interesting.


Skywise

unread,
Oct 7, 2004, 2:41:58 AM10/7/04
to
"C what I mean" <no sp...@frontiernet.net> wrote in
news:Uo39d.6266$pa3....@news01.roc.ny:

> Ya know.. we all bitch when we don't like something.. I think it is
> great when someone takes the time to praise others when warranted.
>
> I too have had great luck with what little contact I have had with the
> CDRH.
>
> Craig
>
> "Ray Condo" <Cond...@gmail.com> wrote in message
> news:9b5a6d4e.04100...@posting.google.com...

<Snipola>

>> What I found out is that the folks there are VERY helpful. I'm not
>> kidding, this Jerry Dennis fellow sounds like a great guy! He took
>> the time to answer my questions at great length, and always pointed
>> out that even if certain circumstances were not under CDRH control it
>> would still be foolish to ignore the safety precautions they promote.
>> He really was easy to talk to, and was quite supportive of my hobby.
>> Despite the fact that he was clearly used to speaking to engineers and
>> PHD's about laser physics, he was able to speak at my level about
>> everything we talked about. He also had some good information about
>> laser safety. (Hey - how about that? A government employee that
>> actually gives great customer service!) I'll probably call him (or
>> maybe Dale Smith) again in the future.
>>
>> Really sorry for the monster-long post (sometimes I just don't know
>> when to shut up), but I thought some might find it interesting.


It has been mentioned many times here in this group by several
of the 'pros' that the folks with CDRH are really helpful people.
This just furthers that conviction.

Also, I vote that this post be the basis of a write up for the LaserFAQ.
It sure answers a lot questions. What do you think, Sam?

Brian
--
http://home.earthlink.net/~skywise711/index.html
*** Website restructured. Old links are no longer valid ***
"Great heavens! That's a laser!"
"Yes, Dr. Scott. A laser capable of emitting a beam of pure antimatter."

Sed quis custodiet ipsos Custodes?

Sam Goldwasser

unread,
Oct 7, 2004, 7:59:30 AM10/7/04
to
Skywise <in...@oblivion.nothing.com> writes:

Yes, that's my intention. If anyone has anything to add under a heading
like "Comments on CDRH Regulations" or something along those lines, post
here or email me via the Feedback form at repairfaq.org.

--- sam | Sci.Electronics.Repair FAQ Mirror: http://repairfaq.ece.drexel.edu/
Repair | Main Table of Contents: http://repairfaq.ece.drexel.edu/REPAIR/
+Lasers | Sam's Laser FAQ: http://repairfaq.ece.drexel.edu/sam/lasersam.htm
| Mirror Sites: http://repairfaq.ece.drexel.edu/REPAIR/F_mirror.html

Note: These links are hopefully temporary until we can sort out the excessive
traffic on Repairfaq.org.

Important: Anything sent to the email address in the message header is ignored.
To contact me, please use the feedback form on the S.E.R FAQ Web sites.


Steve Roberts

unread,
Oct 7, 2004, 12:44:53 PM10/7/04
to
BEGIN QUOTE:

Answer: No. The CDRH deals with commercial products only: either
> laser systems that are assembled to be sold to the public, or laser
> shows that are created (designed) to be "sold" as a "product" to an
> audience. Laser shows that are not part of a commercial endeavor are
> NOT subject to CDRH rules, no matter what power levels are involved.
> This was AMAZING to hear as it runs counter to just about everything
> I've read here and elsewhere, so I questioned Jerry at length about
> it.
>

Your right it is counter to existing rules and practice.
Yes there is a grey area, but dont expect it to hold up before a judge
or your local Federal Prosecutor. I would not go to my school or
church or temple and cut loose with a class III or IV on a regular
basis.

Sam, I wouldnt put that in the FAQ just yet, I have paperwork that
proves otherwise on some of the statements in the above post. A lot of
it comes from CDRH, including a letter from a former CDRH director,
Dr. John Villeforth, on the 4.95 mW issue after I wrote him a letter
when I was in high school. Short version: 4.95 mW or less as long as
it is not a former medical device and you do not build more then one
or offer its services for trade. CDRH also used to give a package of
questions and answers and ruling interprations along with the varience
paperwork, and a lot of them, run counter to what is said in the above
post.

sling a class IIIb or IV laser around doing a laser display
anywhere in the US and your subject to CDRH. Its authority doesnt just
come from 21 CFR 1040.1 subchapter J, FDA overall has the authority to
do what it needs to do under a catchall clause someplace else in the
law.

The question here is the interpretation of the phrase "Demonstration
Laser Product"

Yes, you can fire up a class IV laser in a school, but guess whom
you have to report it to if something goes wrong? BTW, a licensed
teacher doing teaching is in fact in commercial trade as a professonal
in practice. If they buy the laser for professional use, its trade.

Did you know educational lasers are technically required to be
formally inspected by their user at least once per year and after any
time they are exposed to a environment that may cause damage? (ie
floods, dropped, abnormal line voltage etc.) there are a lot of little
rules like that in effect but not getting much publication right now.

I need to Drive to St Louis right now and wont be able to post untill
tuesday, but I will reply then.

Steve Roberts

@hotmail.com Martin Rost

unread,
Oct 7, 2004, 12:56:31 PM10/7/04
to

"Ray Condo" <Cond...@gmail.com> wrote in message
news:9b5a6d4e.04100...@posting.google.com...
> Disclaimer: Long-winded post follows. I do not work for the CDRH. I
> have no hidden agenda to either praise or pan the government. I am
> not a laser expert. Do not read post while operating heavy machinery.
> Not intended for children under the age of 3. no deposit, no return.
>
> Now then: With all the discussion about CDRH rules concerning lasers
> in schools, laser shows for demonstration purposes, etc, etc, etc, I
> decided to try calling the CDRH directly. (Insert ominous music here)
> I called 1-800-638-2041 and got transferred to Walter Snefko at
> extension 120. Unfortunately, he was unclear on several of my
> questions, and admitted that the real laser device gurus were only
> reachable by dialing the non-toll-free number. (Figures.)

>
> So with no concern for daytime long distance rates I took his
> suggestion and dialed (240) 276-0120. Having been primed with
> information from Walter, I then asked for Jerry Dennis at extension
> 135. Jerry was available, and was *AMAZINGLY* helpful. We spoke for
> about 15 minutes, and he encouraged me to call again if I had further
> questions. He also said that two others in the office, Dale Smith
> (extension 147) and Frank Mackson (extension 145) were even more
> familiar with CDRH rules as they applied to laser shows. He said that
> Dale Smith, in particular, was a very valuable resource.
>

{Major Snip}
Thank you Ray for calling and for posting this information. It wasn't
long-winded at all. The information is very good.
Martin


Mike Poulton

unread,
Oct 7, 2004, 2:34:59 PM10/7/04
to
ost...@akrobiz.com (Steve Roberts) wrote in
news:86dacd49.04100...@posting.google.com:

> BEGIN QUOTE:
>
> Answer: No. The CDRH deals with commercial products only: either
>> laser systems that are assembled to be sold to the public, or laser
>> shows that are created (designed) to be "sold" as a "product" to an
>> audience. Laser shows that are not part of a commercial endeavor are
>> NOT subject to CDRH rules, no matter what power levels are involved.
>> This was AMAZING to hear as it runs counter to just about everything
>> I've read here and elsewhere, so I questioned Jerry at length about
>> it.
>>
>
> Your right it is counter to existing rules and practice.
> Yes there is a grey area, but dont expect it to hold up before a judge
> or your local Federal Prosecutor. I would not go to my school or
> church or temple and cut loose with a class III or IV on a regular
> basis.
>
> Sam, I wouldnt put that in the FAQ just yet, I have paperwork that
> proves otherwise on some of the statements in the above post.

<snip>

Remember, everyone -- government agencies are NOT bound by incorrect
staements of their employees! Even if the head of the FDA tells you in
writing that you can do something, you may still be prosecuted if it turns
out to be in violation of the written rules. Only the written rules
matter. Even if they seem unclear (or are genuinely non-logical), there is
NO PERSON in the agency who is authorized to make a truly binding
interpretation to clarify it for you. Their statement can only be used as
a guide to help you understand that particular person's thinking on the
matter. Granted, this can be very useful, and a letter like that would
probably keep you from being punished significantly for anything you did on
their advice, but it is NOT BINDING. Only a court of law can make a
binding interpretation of those rules. If you really want to know if
something is permissible or not, the only way to find out for sure is to
file for a declaratory judgment on the matter. Not a practical option in
most cases.

Skywise

unread,
Oct 7, 2004, 4:22:13 PM10/7/04
to
Mike Poulton <mpou...@mtptech.com> wrote in
news:Xns957B8B2C075CBm...@129.93.1.40:

<Snipola>


> If you really
> want to know if something is permissible or not, the only way to find
> out for sure is to file for a declaratory judgment on the matter. Not a
> practical option in most cases.

<soap box>
Do I need a declaratory judgment to take a dump in public toilet?

Sheesh, it's a wonder anything gets done in this country. And to
think we used to make fun of the Soviets and all their beaurocracy....

It's getting to the point that one should assume it's illegal unless
there is a law saying it's legal.
</soap box>

Ray Condo

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Oct 8, 2004, 12:09:12 PM10/8/04
to
"Martin Rost" <rostmartin @ hot mail . com> wrote in message news:<2slam6F...@uni-berlin.de>...

> "Ray Condo" <Cond...@gmail.com> wrote in message
> news:9b5a6d4e.04100...@posting.google.com...

> > Disclaimer: Long-winded post follows.

> {Major Snip}

> Thank you Ray for calling and for posting this information. It wasn't
> long-winded at all. The information is very good.

Thanks Martin!

I wanted to be sure I included all the information, and that made for
a long post. Glad to see I didn't put anyone to sleep...

BTW, I do have a confession to make to everyone. "Ray Condo", and the
associated "condoray(AT)gmail.com" address are both pseudonyms that I
came up with to thwart the e-mail harvesting spam bots on usnet.
(Though the gmail address *IS* a valid address.)

Some of you have already figured this out, but for those that haven't,
my real name is Adam Burns. (For more info, do a google search for
"Buffo Laser Site" and hit "I'm feeling lucky". You'll find my
homepage - complete with my regular e-mail address - though I'll warn
you that the site is almost 2 years old and *REALLY* needs to be
updated.)

I apologise if anyone is offended by this. But I *REALLY* detest
spam, and my ISP won't let me post to usnet with anything other than
my real e-mail in the header. (Which is why I post from Google
Groups!) I will continue to use the Condoray ID, but I wanted you all
to know the real score.

Adam Burns aka...
The Buffo Mounie

Or Ray Condo... ;)

Ray Condo

unread,
Oct 8, 2004, 10:30:40 PM10/8/04
to
ost...@akrobiz.com (Steve Roberts) wrote in message news:<86dacd49.04100...@posting.google.com>...
> BEGIN QUOTE:

> I have paperwork that
> proves otherwise on some of the statements in the above post. A lot of
> it comes from CDRH, including a letter from a former CDRH director,
> Dr. John Villeforth, on the 4.95 mW issue after I wrote him a letter
> when I was in high school. Short version: 4.95 mW or less as long as
> it is not a former medical device and you do not build more then one
> or offer its services for trade. CDRH also used to give a package of
> questions and answers and ruling interprations along with the varience
> paperwork, and a lot of them, run counter to what is said in the above
> post.

Steve;

Thanks for the input! How long ago did you receive the letter you
mentioned? Would you mind posting the relevent parts? (Probably lots
of typing - I know...) Also, do you still have the list of questions
and answers you mentioned? That sounded very usefull; it might make a
good addition to the FAQ...

> The question here is the interpretation of the phrase "Demonstration
> Laser Product"

Well, in that regard, if you are a hobbyist then you are not
demonstrating a product or even a potential product, are you? You are
simply showing off your toys.

Playing devil's advocate for a moment here; to classify your equipment
as a demonstration laser product I think they (the CDRH) would have to
prove that your equipment was built with the intent of selling it,
right? And I just don't see how they can do that. I mean, how can
they arbitrarily classify my laser equipment as a "Demo" version of a
product if I have not declared myself as a manufacturer of laser
products, or even applied for a business license? Who are they to say
that my volunteer work is a business?

Nearly all of my equipment was purchased on the surplus market. Parts
have been cobbled together to achieve various effects, but to call
this hodge-podge collection of junk a "product" is really a stretch.



> Yes, you can fire up a class IV laser in a school, but guess whom
> you have to report it to if something goes wrong?

Probably lots of people, true enough. Though even so I think the big
worry here would be from the plaintiff's lawyer, not the CDRH.

I'm not trying to knock the CDRH. And I also don't want to appear as
if I'm encouraging unsafe behavior. Far from it. But the fact is
that there are some places where it just is not possible to adhere to
all the CDRH rules, and yet it doesn't make sense that lasers can not
legally be used in those places. (Classrooms, for example.)

> BTW, a licensed
> teacher doing teaching is in fact in commercial trade as a professonal
> in practice. If they buy the laser for professional use, its trade.

Well, this exact circumstance was explicitly exempt according to
Jerry. He said that the ANSI Z 136.5 standard is normally followed by
most schools, but the CDRH has no jurisdiction. I also brought up the
case of a large laser in a college physics lab. Again, he stated
flatly that there was no commerce involved.

Now, Mike Poulton did point out that Government employees can give out
bad advice and still leave you liable for any mistakes... I will
probably call the CDRH again next week anyway with some other
questions, and this time I'll see if Dale Smith is available. (Get a
second opinion...)



> Did you know educational lasers are technically required to be
> formally inspected by their user at least once per year

"Technically required", by whom? The CDRH, or some other body?
(I'm sure the ANSI standard has a section for this, but that's not a
*required* standard...)

For what it's worth, when I was in High School (granted, this is a
LONG time ago) the two hene lasers in the school were never inspected.
In fact, they sat idle for several years until I discovered them in
the closet and started playing with one. (I had a supportive physics
teacher.) They were pretty low power though (Class 3A, about 2mw),
and they soon ended up back in the closet. They're probably still
there...

chris m

unread,
Oct 9, 2004, 11:13:07 AM10/9/04
to
On 6 Oct 2004 20:16:06 -0700, Cond...@gmail.com (Ray Condo) wrote:

> [snip]


>Ok – here's what I asked:

> [snip]

This was an excellent, useful post - and has been added to my
permanent archive. Thanks for taking the time to write this up for
everyone!


---
] chris m
] boulder, colorado

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