The Mane Spa

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DECLARATORY RULING OF
THE ALABAMA STATE BOARD OF MEDICAL EXAMINERS
On July 17, 2025, the Alabama State Board of Medical Examiners (“the Board”)
considered a request submitted by
“The Mane Spa,” (“Petitioner”) for a declaratory ruling pursuant to Ala. Code § 41-22-11 and
Ala. Admin. Code r. 540-X-1-.10, concerning the use of red light therapy sources by non-
physicians under Ala. Admin. Code r. 540-X-11.
FACTS PRESENTED
Petitioner presents the following factual background1:
I, [Petitioner], on behalf of the Mane Spa, a licensed salon am petitioning this Board to
help define the rule as relates to [LED] light sources that are non-laser, non-pulsed and non-heated
light devices. I am requesting a review of the information I have received when contacting the
Board about whether or not as a salon with [LED] red light non-pulsed, non-laser, non-UV and
non-heated light falls under this regulation posted. I was told that by looking at [y]our website I
do fall under this regulation however when asked what nanometer doesn’t fall under this regulation
the corresponding individual had no answer and asked that I petition the board for an answer. I
will include the information I provided to her so that we are clear on nanometer of [LED] light. I
want to state that my LED lights are non-laser, non-pulsed, non-UV and non-heated. as you can
see below dangerous [LED] light is the 200-425 nanometer range that allows for “tanning” it
clearly burns the skin, causes damage to the skin and potentially causes cancer. It is non-regulated. . .
1 A complete copy of Petitioner’s petition is attached as Attachment A.
1
It's important to note that many red light therapy devices emit light in the 600-1000nm
range and are considered safe for various applications. Red light therapy wavelengths which lie on
600-700nm and 800-1000nm ranges of the light spectrum are by nature non-heating. We do not
use heated [LED] lights. Our lights are adjustable from the 450-1000 range and we can control the
strength. All of our staff are red light certified and light spectrum certified. These are non-UV
ranges and what we use at the salon. If the use of lasers and other modalities applies to those of us
using non-UV, non-heating and non-laser red and blue [LED] light therapy we will most likely
have to close our business as it is a low-cost item to consumers and would not substantiate hiring
a medical director or MD/DO to cover our spa for one service. It will also affect most gyms, salons,
estheticians, cosmetologists, tanning salons and day spas. . .
In conclusion, I am asking the board to exclude [LED] light therapy in the range of 450-1000
nanometer that is non-laser, non-pulsed, non-UV and non-heating from the use of lasers and other
modalities section of law.
QUESTIONS PRESENTED
(1) Whether a LED red light device emitting non-pulsed, non-laser, non-UV and non-heated
light in the 450-1000 nanometer range is a laser under Ala. Admin. Code r. 540-X-11?
(2) Whether a salon offering services utilizing such a device is performing non-laser skin
rejuvenation under Ala. Admin. Code r. 540-X-11 such that it must be used by or under the
supervision of a person licensed to practice medicine or osteopathy in Alabama?
2
ANSWER
(1) Any LED red light device that emits energy affecting living tissue, including skin below
the stratum corneum layer, is considered an LLBD or laser and light/energy-based device under
Ala. Admin. Code r. 540-X-11 if it is applied for a surgical, therapeutic, or cosmetic purpose.
(2) Any person or business offering the utilization of devices to revise, correct, alter, or treat
living tissue are subject to Administrative Rule 540-X-11, Guidelines for the Use of Lasers and
Other Modalities Affecting Living Tissue, which requires physician supervision to perform services
utilizing said devices.

I wanted to clarify why we have removed Red light therapy from our spa. If any facilities provide Red Light without full medical records and a licensed provider on staff they are violating the medical board.