Comment regarding 18VAC41-20-270(F)(3) and the use of e-files on the natural nail plate

I am a licensed Nail Technician, Nail Instructor, and owner of a Virginia-licensed Nail Technology School. I respectfully ask the Board to reconsider the current restriction in 18VAC41-20-270(F)(3), which states that a nail drill or motorized instrument may only be used on the artificial nail surface.

I fully support regulations that protect clients from improper or aggressive use of electric files. However, I believe a complete prohibition on the use of an e-file on the natural nail plate may unintentionally prevent trained professionals from using certain controlled techniques that can be precise and safe.

For example, an appropriately selected silicone or other gentle bit, used with proper speed, pressure, angle, and training, can assist with removing nonliving tissue that is adhered to the natural nail plate during preparation. This can help provide a clean nail plate for product application without aggressively filing the natural nail itself.

I am not advocating for the use of an e-file to cut, remove, or abrade living skin, including the eponychium. I believe that distinction is extremely important.

Manual preparation should also not automatically be considered safer simply because it is performed by hand. Safety depends on proper anatomy education, the type and size of the implement, pressure, angle, technique, and the technician’s competency.

Rather than prohibiting all motorized instruments from touching the natural nail plate, I respectfully encourage the Board to consider allowing limited and specifically defined e-file use when a licensee has completed appropriate training.

I would support additional education requirements covering:

• Nail anatomy and identification of living versus nonliving tissue
• Approved types of bits for natural nail preparation
• Appropriate RPM ranges
• Proper pressure and angle
• Prohibited aggressive bits or techniques
• Infection-control requirements
• Recognition of contraindications and when e-file use should be avoided

As a Nail Instructor, I believe requiring proper education and demonstrated competency could provide stronger consumer protection than a blanket prohibition. It would allow Virginia schools to teach safe, modern techniques while clearly establishing boundaries that protect the natural nail and surrounding living tissue.

Thank you for considering this perspective as the Board reviews its regulations.

My name is Janett Rivera. I am a licensed nail tech. I have recently been licensed for 2 years.

I am writing to respectfully express my concerns regarding regulations that prohibit licensed nail professionals from using an electric file (e-file) on the natural nail.

As a professional nail technician, I fully support regulations that prioritize client safety, sanitation, proper education, and the protection of the natural nail. However, I believe that a complete prohibition on the use of an e-file on the natural nail may not fully recognize the importance of professional education, proper technique, and the appropriate use of professional equipment.

With comprehensive education and proper training in natural nail anatomy, e-file safety, appropriate bits, pressure, speed (RPM), and technique, a licensed nail professional can use an e-file in a controlled and responsible manner. The potential for damage is often related to improper use, inadequate training, excessive pressure, inappropriate bits, or incorrect RPM settings—not simply to the use of the tool itself.

Rather than prohibiting the use of e-files on the natural nail entirely, I respectfully encourage the Board to consider regulations that establish clear standards for competency and safe use. This could include specific educational requirements addressing e-file operation, appropriate bit selection, safe RPM ranges, pressure and technique, contraindications, and the preservation of the natural nail.

I believe that providing licensed professionals with proper education and clearly defined safety standards would better serve both nail professionals and the public. It would allow professionals to use modern tools responsibly while maintaining the high standards of safety and consumer protection expected within the cosmetology industry.

I respectfully ask the Virginia Board of Cosmetology to consider a regulatory approach that emphasizes education, competency, and safe professional practice rather than an outright prohibition of e-file use on the natural nail.

Thank you for your time, consideration, and continued commitment to protecting the public while supporting the advancement of the professional nail industry.

Respectfully,

Janett Rivera Licensed Nail Professional