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Department of Professional and Occupational Regulation
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Board for Barbers and Cosmetology
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Board for Barbers and Cosmetology Rules and Regulations [18 VAC 41 ‑ 20]
Action Amendments to Barbering and Cosmetology Regulations 2012
Stage NOIRA
Comment Period Ends 3/14/2012
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Previous Comment     Back to List of Comments
3/13/12  9:23 am
Commenter: Smooth Day Spa *

NOIRA
 

$7.92 is the average wage of a nail technician in Virginia.  It would be extremely unfortunate if the Board chose to raise taxes in the form of licensure fees on this group of largely working-poor females.

 

While unsure of the Board's regulatory scope, as owners of a day spa located in Virginia, we would like to recommend that the Board focus any changes on improving the health and well-being of the general public at nail salons and day spas by promoting and enforcing more stringent regulations in reference to sanitization procedures.  Anecdotal and physical evidence from clients of some nearby salons and spas indicate fungi and bacterial promotion because of a lack of proper sanitization specifically in using shared files and unclean foot baths.

 

We also recommend promoting and enforcing regulations that reduce the use of toxic chemicals in the workplace.  This reduction would not only benefit the general public that has a short-term exposure, but more importantly, serves to protect the typical worker that has a 40 to 60 hour-a-week long-term exposure.  Occupational exposure to these toxic chemicals are known to cause chronic disease.

 

Lastly, we request that the Board review the apprenticeship program.  We think that the program in general is beneficial to both individuals interested in entering the career, and to businesses that have pinpointed specific people that they feel would work well in their business setting.  The open-ended nature of the program, however, fosters a situation where some employers use the apprenticeship program to employ an apprentice with no intention of such apprentice ever gaining licensure.  This fosters an atmosphere where an employer can keep an apprentice working in their business at a very low wage and no incentive to advance the apprentice to licensure status.  Ultimately this shackles a low-wage worker to an employer and reduces the quality of the labor and the safety of the general public because the apprentice is never actually forced to pass an exam.  This is a valuable program of which we are a part, but in its current form it benefits employer's bottom lines at the expense of the worker and health of the general public.

 

We sincerely hope that the Board will not raise a licensing tax on working-poor females, but instead work toward improving the health and safety of nail technicians and their clienteles.

 

Thank You,

Johnna Lea Backus

Dave Backus

Smooth Day Spa




* Nonregistered public user