Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Board for Barbers and Cosmetology
Barbering and Cosmetology Regulations [18 VAC 41 ‑ 20]
Action Lower Cosmetology Training to 1,000 Hours
Stage Proposed
Comment Period Ended on 9/15/2023


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9/15/23  10:52 am
Commenter: Jonathan Melloul


Virginia residents should be concerned about the effect the hour decrease will have on the education and professional ability of future students / professionals. Reducing the education will reduce the proficiency of future professionals, which will reduce their earnings.

Furthermore, the reasoning behind the hour reduction bill is in response to a general "regulatory reduction" order and does not support the needs of the professionals or public. There seems to be no consideration for the cosmetologist who relies on this profession to make a living and support their families.

Cosmetology is a trade best learned through practice, repitition and application - which requires time. There is no substitute to the time needed to build good habits (technical & professional) and the time needed to practice the skills to a base level of proficiency in applications & knowledge. 

The cosmetology profession requires more skin-to-skin contact of any profession outside the medical field which is why cosmetology is a licensed profession in all 50 states. Cosmetologists work with sharp instruments, hazardous chemicals, and deal with contagious diseases. There is a universal agreement that licensure requirements are appropriate for occupations that present a harm to the public. Less than 10% of the states in the USA that have an hour requirement for Cosmetology that is less than 1500 hours. It is clear that 1500 hours is the industry standard. The general consensus in the United States is that 1500 hours (or more) is the necessary time to complete a Cosmetology program. Decreasing Virginia’s training requirements below the industry standard stands to harm both cosmetologists and the clients they serve.

Due to the minimum hour requirement of 1500 hours adopted by most states in this country, reducing Virginia standards to anything below 1500 hours will hinder license portability and reciprocity with contiguous states. The hour requirement for Cosmetology in Tennessee, North Carolina, and Maryland is 1500 hours. The hour requirement in Kentucky and West Virginia is 1800 hours. This reduction will affect the ability of students to reciprocate their licenses to any of these bordering states.

Based on placement statistics, the majority of graduates are placed in smaller, non-chain salons rather than chain stores that offer some sort of training program. These small businesses need and want Cosmetology graduates who are prepared to start behind the chair immediately. The 1500-hour requirement ensures that these graduates can meet the needs of the salons in Virginia.

Education creates value in society and opens the door for small business opportunity; this is the only postsecondary education opportunity for most of these students; it is a time for them to learn the technical skills of a trade while also gaining valuable life-shaping soft skills that help them become successful professionals, small business owners, and contributing members to Virginia. Removing this from their education affects their welfare.

Financial Aid Eligibilty creates opportunities for students to pursue education and advance their careers. Reducing the training hour requirement reduces student's financial aid eligibility, creating more of a financial burden on students and creating financial obstacles that will keep students from starting/finishing their education. This affects the public WELFARE. 

Please consider keeping the training hours at 1500 hours - as it as produced over 72,000 licenses cosmetologists in the state. Thank you.

CommentID: 220342