July 28, 2025

Lori Frederic, CMT, CSCS
Balance Biomechanics
6908 South Hill Street
Littleton, CO 80120

Dear Ms. Frederic:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding the recordkeeping regulation contained in 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses. Specifically, you asked whether the use of LED (light emitting diode) red light therapy and red light therapy wraps constitute first aid for purposes of OSHA recordkeeping regulations, and also whether this technology could be added to the list of first aid treatments under section 1904.7(b)(5)(ii).

In your letter, you state that LED red light therapy wraps use red (660nm) and near infrared (850nm) technology to promote circulation and cellular energy production. To support your claim, you attached a brochure from the company you use explaining the technology. According to the brochure, red light and near infrared light therapy works when light penetrates the skin and alters cellular behavior by increasing the energy production of mitochondria within the cells. This cellular stimulation has many benefits, according to the brochure, including reducing pain and inflammation.

In response to your inquiry, based on OSHA's review of the information you submitted, the LED red light therapy and red light therapy wrap technology you ask about does not constitute first aid for purposes of OSHA's recordkeeping regulations. First, as you know, LED red light therapy, such as the technology you describe, is not included on the list of first aid treatments in section 1904.7(b)(5)(ii). As you are aware, section 1904.7(b)(5) of OSHA's recordkeeping regulation requires employers to record work-related injuries and illnesses that result in medical treatment beyond first aid. Under Part 1904, medical treatment does not include "first aid" as defined in section 1904.7(b)(5)(ii). Section 1904.7(b)(5)(iii) goes on to state that the list of first aid treatments in section 1904.7(b)(5)(ii) is a comprehensive list of first aid treatments. Any treatment not included on the list is not considered first aid for OSHA recordkeeping purposes. See also, OSHA's January 19, 2001, Occupational Injury and Illness Recording and Reporting Requirements, final rule, published in the Federal Register at 66 FR 5916, which established the list of first aid treatments, including OSHA's discussion of that list at 66 FR 5984, and OSHA's October 9, 2019, Letter of Interpretation to Kate Frank.

Additionally, we note that section 1904.7(b)(5)(ii)(E) states that hot and cold therapy is considered first aid treatment for purposes of OSHA recordkeeping. See, 66 FR 5989-90. Based on the brochure you provided and a review of the publicly available literature on LED red light therapy, light therapy is distinct from hot therapy. According to this information, light therapy accomplishes health benefits via photons of light interacting with cellular macromolecules. It is the light itself that penetrates the skin and alters cellular behavior, not the heat from the light. Therefore, OSHA concludes that the use of LED red light therapy wraps is a medical treatment and not hot therapy or other first aid treatment as defined in section 1904.7(b)(5)(ii).

Regarding your question whether LED red light therapy could be added to the list of first aid treatments for purposes of OSHA recordkeeping under section 1904.7(b)(5)(ii), any addition or modification to OSHA's Recordkeeping first aid list would need to be accomplished through notice and comment rulemaking. The list of first aid treatments in section 1904.7(b)(5)(ii) has not been modified since it was established through rulemaking in 2001. As discussed in the preamble of that rulemaking, OSHA found that adopting a single, all-inclusive list of first aid treatments provides clarity for employers when determining which work-related injuries and illnesses to record. See 66 FR 5984-5994. OSHA finds that this approach also contributes to the consistent recording of similar injuries and illnesses over time and improves the accuracy of occupational injury and illness statistical data. Accordingly, at this time, OSHA does not plan to initiate rulemaking to add LED red light therapy to the first aid list.

We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules.

Sincerely,

Lee Anne Jillings, Director
Directorate of Technical Support and Emergency Management