One of the topics starting to really be brought up is human trafficking in service trades. By removing the requiring of the disclosure someone is an apprentice several things can and will happen. Scummy spa owners will charge clients full rates for student level work devaluing out industries workmanship. Some may even still charge student rates and without the disclosure that is student pricing, clients will always go for cheapest options so risk of devaluing the market. The biggest distinguishment between a $30 facial and $120 facial is experience. If you have worked in your field 15-20 years would you want to be making the same as the interns do? Apprentices are effectively interns, they are not intended to be paid positions and are an education alternative. Out of my inital class of 18 only 6 completed their program. We already deal with the massive increase of self taught, unlicensed individuals flooding and devaluing our industry. Clients expect if you offer a treatment that you a trained, insured, and within your scope. There needs to be more protective measures in place for the client.

We have a local massage school that also employees its graduates. When you call to make an appointment they will ask, "student or therapist". The student cost is more than half the cost of the therapist because they aren't paid since it goes towards practicals to graduate. This is the proper way and should continue. 

Earlier I mentioned human trafficking, so let me paint you a picture of what would happen. We already have several local spas that have been shut down both for sex and human trafficking. One had 6 locations under a single business license. What would stop a "family owned" business from having a single licensed individual and 6 unpaid, preforming treatments "apprentices"? Often these people are leaving one nightmare into another. They are brought from their country, but no one, can't get a real job of their own, and are forced to work unpaid for years until they can find a way often back to the country they were trying to leave. Part of why we are required to have our licenses in public display is to show we are a licensed professional. Apprenticeships have their place in our industry just as internships do for most others. You wouldn't let a nurse in their residency preform open heart surgery without having the patient/patient's family aware and consenting to have it performed by a glorified student. Clients wont do their research, and ty people will cut every corner you allow them the opportunity to. 

I hope you strongly reconsider potentially removing the requirement for spas to disclose apprenticeships, thank you for your time.