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.