A recent Opinion Letter from the Occupational Safety and Health Administration (OSHA) addressed whether the recordkeeping regulation contained in 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses, requires that LED (light emitting diode) red light therapy and red light therapy wraps constitute first aid for purposes of OSHA recordkeeping, or if it was first aid treatment under section 1904.7(b)(5)(ii). This is important distinction for employers because first aid cases do not get added to the annual OSHA 300 log, and medical treatment cases are recorded. OSHA concluded that red light therapy is medical treatment, not first aid.

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.  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. Hot and cold therapy is considered first aid treatment for purposes of OSHA recordkeeping. OSHA had to determine if red light therapy was like heat therapy, or something else. According to available literature, light therapy is distinct from hot therapy. 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).

At this time, OSHA does not plan to initiate rulemaking to add LED red light therapy to the first aid list (which would need to be done to consider it first aid). OSHA issued this Opinion Letter on July 28, 2025, in response to a request from Balance Biomechanics, Wellness and Therapy company based on Colorado.

How to Request an Opinion Letter from OSHA. A letter of interpretation (LOI) provides supplementary guidance that clarifies how to apply the OSH Act, or a particular standard, policy. Before requesting a letter of interpretation please consult the following agency guidance and material which may address your question. Check here to submit a request.