Red Light Therapy – Retrofitters Beware

Red light therapy (RLT) isn’t widely offered by American tanning salons; however, the service is quickly gaining momentum – both nationally and globally – as consumers continue gravitating toward products and services in the anti-aging category. (RLT is said to boost collagen production.)

In the spring of 2010, JK-North America introduced the ultimate in RLT – the Beauty Angel. This unique stand-up booth combines visible red light (non-UV) wavelengths with pre-programmed platform-based vibration exercise technology, offering the potential benefits of total body skin rejuvenation and muscle toning. The Beauty Angel – and other major league RLT equipment – is priced accordingly, thereby keeping this niche on the “wish list” for many salons.

Because of the investment new equipment requires – not to mention the desire to test something out in a market before committing on a larger scale – some salon owners have opted to “create” their own RLT units, usually by retrofitting one of their less-frequently used base beds with RLT lamps. This is largely uncharted territory in the industry, and it’s raising quite a few eyebrows.

For starters, when a salon owner repurposes a UV unit, he or she assumes the role of the bed manufacturer. With all the regulations governing tanning units, proper labeling, certification, inspections and signage, this certainly seems ill-advised. Beyond this, business professionals also exceed the limitations of their equipment warranties and insurance coverage when tampering with a unit’s original intent.

We’ve heard from salons in several states (Texas and Iowa to name a couple) that are already running into challenges with state inspectors. In fact, salon owners in North Carolina recently received the following letter:

TO: All Tanning Registrants and Tanning Service Providers

FROM: Tanning Program Manager

REF: Red Light Therapy Lamps and Units

Radiation Protection Section is issuing this notice to provide information regarding red light therapy. At this time, The FDA has not approved the use of red light therapy lamps in tanning units. The use of such lamps in a tanning unit creates an unapproved “medical device,” therefore, potentially creating a misbranded or unlicensed product.

Please Note:  Until further notice, inspections will be performed on tanning beds/booths as intended for the purpose of cosmetic skin tanning. Lamps in use must adhere to the sunlamp standard as stated on the unit label. Therefore your prompt attention is needed to either remove the red light therapy lamps from these units or remove this unit from service.

We appreciate your cooperation in complying with this corrective action. Facilities that fail to comply will be issued a violation. Please consult your lamp distributors for further clarification regarding any red light therapy lamps you may have received. You can also contact the FDA with further questions on red light therapy. We will also post any updated or acquired information this topic on our website.

Food & Drug Administration

Office of Communication, Education & Radiation Programs

Center for Devices & Radiological Health

Food and Drug Administration

10903 New Hampshire Avenue

Building 66, Room 4661

Silver Spring, MD   29093-0002

Phone:  (301) 796-2471

FAX:  (301) 847-8502

SharonAMiller@fda.hhs.gov

The argument has arisen, however, that once you remove the UV lamps from a tanning unit, it is no longer under the jurisdiction of the FDA (or various state inspection agencies). And we thought the tan tax was confusing!

We’re going to continue researching to see what else we can find out. You can also visit the Light Therapy section on TanToday.com to see ongoing discussion about this and other RLT-related topics. One thing’s for sure; right now there are a whole lot more questions than answers.

We’d love to hear your input via the comments feature below.