Web Officers
burt.laura.a1@dol.gov
albrecht.brian@dol.gov
hill.jedd.r@dol.gov
jillings.leeanne@dol.gov

Red Light Therapy Wraps

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. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 28, 2025

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

Dear Ms. Frederic:

Software used to generate Equivalent OSHA Forms 300 and 300A

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. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

April 29, 2025

Lauren Mink, CEM
Veoci, Inc.
195 Church Street, 14th Floor
New Haven, CT 06510

Dear Ms. Mink:

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 request clarification concerning the acceptability of documents generated by software to be used as a substitute for the OSHA recordkeeping forms.

May I use a different form as an acceptable substitute for the OSHA forms for recordkeeping purposes?

Frequently Asked Questions

Question: May I use a different form as an acceptable substitute for the OSHA forms for recordkeeping purposes?

Answer: You may only use a different form if it is an equivalent form. Under paragraph 1904.29(b)(4), an equivalent form is one that has the same information, is as readable and understandable, and is completed using the same instructions as the OSHA form it replaces. Equivalent forms can be maintained in any file format (e.g., Excel, CSV) provided that these requirements are met.