As a tattooist of 25 yrs and one of the people who helped on the fact finding for the regulations I feel I must STRONGLY object to the idea of turning tattooing and piercing apprenticeships over to a “school”.  Learning the crafts of tattooing and body piercing is not a time set event, the amount of knowledge and information gained in the one on one experience of apprentice and master is not replaceable by a classroom setting.   What you are, to all appearances trying to do is create a climate of low standards for licensure that you already fail to enforce.   I see ads everyday on Craigslist and even a guy driving around in a pickup offering tattoos out of a house, unlicensed, and you do nothing.   You have also changed the testing center for tattooing and made it almost impossible for people to get in touch with anyone regarding the test.   Essentially what you are trying to do is remove yourselves from responsibility for this.  You have never wanted to deal with tatttoing and piercing and know nothing about it, you wish to encourage these “schools” in part so someone can make money and in part so you no longer have to deal with it.   This will cause an increased risk in health and safety to the public.  It simply will because without the one on one educational process of tattooing and piercing how can you possible say that a person is trained?  Hair grows back, so a botched haircut is easily repaired, you also have a very minimal risk of infection and disease with most other trades represented by the board who operate in a “school”  both tattooing and piercing to have that risk and no matter what you have seen on TV there is no way for the sterile practices required to tattoo or pierce safety to be drilled into a individual to the point of muscle memory without that one on one experience.  How you ask?  Ask an apprentice how often they set up our work stations before they are ever allowed to touch a person.  This one on one critique of their set up is How they learn that process, it is how it becomes memory.  You can NOT get this in a classroom.   You are also going to create a means for people with no experience other then “school” to suddenly open a shop legally, this would also create ANOTHER influx of shops.  Shops owned and operated by individuals with no real world experience in tattoing or piercing, and again I point out the overal cost to the public between a bad tattoo and a bad haircut.  If you do this, it will directly effect not only the legally operating shops, but also the health and safety of the public, all because you would prefer a simple answer and let someone make money by owning a school, so you didn’t have to deal with it.