At this time, any shop or salon holding an apprenticeship program; is required to inform the public if any services are administered by an apprenticeship student. Removing this requirement would be misleading to the public. I strongly feel that the public should be aware that they are not receiving a service by a licensed professional. Without the requirement to make the public aware, the clientele would assume that they are receiving a treatment by a qualified professional with the mandated knowledge of a licensee. This would allow for the shop or salon to charge full price for student services, which would indicate to the public that they are qualified professionals. This would encourage salon or shop owners to offer apprenticeship programs due to the ability to not hire Licensed Estheticians, when the option for students to perform services is more profitable. This could lead to overall public dissatisfaction for what a Licensed Esthetician has to offer and most importantly the potential for client harm. As a Licensed Master Esthetician, I propose that the regulation to openly share apprentice status to the public when performing services, remain in effect permanently. 

Thank you for your time and consideration,

Tiffany McGill, LME

I am against the proposition that apprentices no longer be required to be advertised as such in salons/spas. As a client, I would be reluctant to seek services at a salon or spa, not knowing whether the individual providing the service had been properly trained in safety and sanitary requirements or if the individual had passed state mandated board examination for licensure. How would the board ensure that these unlicensed individuals are being properly supervised and that these individuals don’t cause harm to unsuspecting clients? I feel state licensing regulations exist to promote safety and protect the consumer, and removing the license display requirement would not accomplish that goal.

Additionally, I feel that individuals looking to become licensed Estheticians could be taken advantage of, in being hired for lower pay (due to lack of training/license) but still providing services for their employer at full price. This could also have an adverse effect on licensed individuals, who may encounter greater difficulty in securing employment if salons/spas decide to hire a greater amount of unlicensed individuals for a lower pay rate.   

I strongly disagree with this proposal and would advocate that license display requirements and apprenticeship display requirements remain in effect. 

I disagree with the proposed changes to the verbage for 18 VAC 41-70-260, Display of License. It appears that the changes would no longer require an apprentice wear an identifying badge clearly indicating that that they are not a licensed individual. I believe this change opens the door for apprentices to offer regular price services to consumers without having to disclose that they are still "in training". I believe that the changes to this regulation would only benefit businesses who are looking for cheap labor. That in turn could hinder the employment opportunities for licensed individuals who would deem a higher wage. I don't believe that having licenses and proof of apprenticeship registration in the reception area is identifying enough for the general public to have clear knowledge of who may be performing their service. When an apprentice wears a badge on their person, the is no question about their status and the consumer is made aware that the individual offering service has not yet met the state mandated requirements to receive a license. In the interest of public safety and full disclosure the changes to this regulation simply make no sense. 

This is not okay. This is a public safety issue. It is leaving the public at risk. It’s taking their trust for advantage. They are still learning the in and outs, rights and wrongs and they do not need to be working on the public without disclosing that they are still learning.  It’s dangerous and scary. It can put a lot of people at risk. 

As a Licensed Master Esthetician And Licensed Cosmetologist, I strongly believe that removing the regulation for an apprentice to disclose the fact they are an apprentice, is harmful and misleading to the public. Speaking from experience being a former Cosmetology apprentice, some clients did not want services from apprentices due to the lack of knowledge and experience of a licensed professional. If the regulation results in the public being unaware they are being treated by an apprentice, this could result in unhappy clients, and public distrust of beauty professionals in general. This could also put the public at risk considering all licensed professionals have been tested to ensure they are implementing proper sanitation and techniques in their practice, whereas apprentices must continue to be guided and taught how to do so. This could not only harm the public but also tarnish the career of the apprentice, and other employees at that specific business. I also see this as an opportunity for business’s to hire people that are not capable of performing services safely at a cheaper rate, which would in turn hinder employment opportunities for those that are fully licensed and capable. Keeping this information from the public is simply unethical. 

Virginia’s esthetics program prides it self on providing safe, and proper services for the public. As a consumer, it is distrusting to receive a treatment under a business whose workers/apprentices, are not fully trained but displayed as such. This law is Purposely hiding the fact that the person performing services/and treatments are not certified. Consumers are most at risk because they are not being made aware of their options for receiving professional service or not, yet paying the same price.

The esthetics industry is growing fast and with that comes a reputation, that,if not protracted can turn sour due to the public’s opinion with subpar services that were promised from a “unlicensed” professional...

There are no Guarantees that these apprentices are supervised while performing services, which leaves room for sanitation and safety hazards. Which agian turns around and harms our public and overall Reputation.

Changing the wording of this law does more harm than good. At the end of the day we need to protect the safety of our public, and the financial, professional safety for our future esthetician

This regulation change is dangerous. Not only, for the general public; but, also for the apprentice, businesses, and the practice of other esthetician’s. As a Master Esthetician that has been through proper training and education set forth by our state, I would likely come in contact with disgruntled patrons who have not had a proper experience.  This would cause them to have a no faith attitude towards what we do.  Speaking for a patron as well it is completely neglectful to not knowingly let an uneducated individual work on my face.  I hope this is considered as a reason to turn down this change. Thank you

Please do not change this regulation! It poses a risk to the public and does not give them accurate information. From a client prospective i would assume that everyone at a salon or spa is trained appropriately and in accordance with the laws and regulations of the state. As a client i would NEVER go to someone who wasn’t fully trained UNLESS i was told in advance that they are in training and being supervised by a fully licensed individual. From an esthetician standpoint this is also frustrating because we have gone through all of the training and are fully licensed! This is unfair to those who have done all the work! Please do not change this!!! 

As all previous comments, this is asking for disaster. In the perspective of a full time student, I take PRIDE in my clients knowing that I am not yet licensed, why? Because i want feedback being  a LEARNING individual, comments are a way for Esthetician’s to grow and expand their skills, this is how we learn tips and tricks and to provide even better services for other clients! This also gives us the opportunity to build clientele and make connections! 

 Now, as a clients perspective on this proposal, this is a high concern for safety. This proposal would give leeway for mistakes that can be prevented! Please imagine the fury and anger if YOU were a client having a great day and you give your trust to an establishment that takes advantage of this. Imagine this- walking into a well known tattoo parlor for a piece of art that you have been thrilled to get, your artist finishes their work and you end up with an art piece a toddler could draw. As for the Esthetics field- if I were a paying client, and my Esthetician made a bad mistake that should have been prevented due to me knowing at the time of the service that this person is still learning, I would be off the walls. So please do not make the mistake of other people’s well being for their safety. Thank you..

If this proposed new regulation is set forth, the damage/health risk to any future client will be greatly increased. I understand wanting to save businesses money but to take away a clients free will and choice on who can provide a service to them (because, let's be honest, they will be going into any of these services completely unaware that they are being performed by an apprentice) is not only wrong, but seems unethical. I know as a previous student, every client I had was a learning experience and I was not always perfect with my recommendations or treatment. Luckily, I've never hurt a client but just imagine someone performing an aggressive peel on a client without having the proper education. Sure, you may know the steps but to understand why you are doing what you're doing and if it's in the best interest of this client, makes all the difference with obtaining a successful outcome and not causing harm. Imagine having that type of experience in the 'real world' where lawsuits and horrible reviews can end a career or these small businesses. Where you can literally cause serious damage because you didn't understand or know proper technique and safety set forth by the regulating body that the state of Virginia sets forth for licensed individuals.  These owners are essentially paying minimum wage to the apprentice while charging their clients a premium for a service that should be performed by a licensed professional or master Esthetician.  Which in turn, would lead a client to believe they are receiving treatment from knowledgable and licensed individuals. 

It just appears to be a very slippery slope in which more harm than good could come from it. Bottom line, everyone has a right to make the best decisions for themselves based on all the information provided. Removing the law that require the display and removal of ID badge seems not only misleading but deceitful.

Thank you for your time in reading my opinions on this subject. 

Sincerely,

Stacy Hamrick

The public absolutely has a right to know if the person performing a service is fully qualified, and licensed to do so. If the individual performing a service is not fully qualified, and licensed, that needs to be clearly communicated to the client. Transparency with the public matters. The public’s best interest should be the first consideration when changes to regulations are proposed. Very simply, is this proposal in the best interest of the people we service? The answer is, unequivocally no. 

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.

taking away the privilege to teach and share a talent with others would be cruel and unfair. Don’t take this away!