Good morning.  My name is Sharon Painter.  I am the owner of Body Art Tattoo Studio in Berryville, VA.  I very much appreciate the opportunity to comment on the proposed changes to the Guidance documentation for certifying for CPR./First Aid and Bloodborne Pathogens.  

My thoughts and comments relative to the required certifications:  I'd rank the importance or priority of each certification as

1) Bloodborne Pathogens;

2) First Aid; and

3) CPR. 

Of the three, Bloodborne Pathogens is the primary certification as it relates to public health safety relative to the work that we do and is renewed annually. 

First Aid is common sense care and response to injury and has some relevance to the work we do. It is renewed every two years.

CPR is honestly not as important as the other two certifications.  In most cases, in today's age of COVID/Monkeypox, lawsuits, etc., you will not find many willing to provide CPR actions, but rather call 911 as their only response.  

The online courses offered by each of the vendors that your office recommend are sufficient to provide ample understanding in all 3 of these areas of certification. 

I would vote to remove the requirement for any in-person training for any of the 3 certifications and to accept online training/certification.

As an aside, I'd also vote to remove the requirement for CPR certification, or at least make it optional, as an added bonus for any artist who chose to maintain that certification and would be willing to actually do CPR. 

Relative to conventions, yes, for us, it is a hassle to line your certifications up with ongoing conventions and it has become a significant challenge to certify in person by the time your certification expires.   

I hope this helps.

Sharon Painter