I am opposed to an Apprenticeship program in Virginia.

It is essential that an esthetician receives the education needed at a school environment. Within that environment the students are able to get the hands on experience needed to be knowledgeable and comfortable with the proper and all training needed to protect society. I am concerned that apprenticeship students would be working on clients when they are not quite prepared. This is the important.

The second opposition I have is that with the Esthetic pay of an Esthetician being one of the lowest in the country, having an apprenticeship in Virginia will effect the standards of income for them. I was originally licensed in California in 1996 where our base pay in a Spa was approximately 60% of the service being done, If only an hourly pay was done as a payrate it was a minimum of $25.00 an hour. In Arizona when I moved there in 2005 It was about the same if not more due to economy. I moved here to Virginia in late 2010 and started working in 2012. Since working I have been shocked at the low pay being offered to new and experienced Estheticians. The all time low is actually minimum wage with 10% of the treatment amount of service. The all time High I have heard is for a Master Esthetician in a Doctors office is $25.00 per hour given this person had over 20 years experience.Therefor the consequences of having an Apprenticeship program is that salon and spa owners will be not only taking jobs away from just graduated Estheticians to cut down on costs but also lowering the rate of pay to Estheticians in Virginia. With the payrate of an Esthetician already being low it would be a nightmare for this to go lower.

Virginia has done an excellent job of establishing and improving standards of education and training for the esthetics field. To those of us currently enrolled in these programs, it seems like the regulations are constantly evolving and becoming more rigorous.  As students, we are always concerned about meeting these standards and being as educated as possible in an industry that is constantly changing.  I am very concerned that an apprenticeship program would significantly diminish DPOR's ability to ensure consistency in application of educational standards.  Long term, I believe this would greatly reduce, rather than advance, professionalism and industry standards, and greatly increase risk to consumers. 

I support the idea of apprenticeships. On the job training is a time-honored tradition. For many, apprenticeships allow them to learn a trade while still earning money to provide for a family. Not everyone can stop work and spend precious hours in a classroom.

I would like to oppose the addition of Apprenticeship Training to the proposed Esthetics regulations. It is my belief that the apprenticeship training program would lead to a lower standard of education that would eventually affect currently safe, educated, and licensed estheticians in the workplace. The rapid growth and advancements that we are currently seeing in the Esthetics field require educational training in a formal institution. I think there is reason to have concern about the amount of actual hands on practice an apprentice would perform in this type of setting. Unlike cosmetology and tattooing, our services are generally practiced in small private rooms lacking the space required for “training”. I believe these apprentices will end up as cheap labor receptionist and cleaning crews instead of sitting in the private rooms where the services are to be performed. Without the guarantee of a solid academic foundation and proper hands on, ultimately we will see a drop in the quality of service and a drop in pay rates. In addition, esthetics is such an evolving field right now, I believe that we are only going to see more advanced treatments heading our way and we want the ability to offer advanced services and remain relevant within our field. If we lower the standard of education, it is my firm belief that more treatments will be deemed “outside of our scope of practice” and it will tie the hands of responsible estheticians in the state of Virginia. I do not oppose the idea of apprenticeship in general,  I just don’t think it’s the right fit for the esthetics field.

 I oppose the idea of apprenticeship training as an avenue to become a licensed esthetician in the state of Virginia. I believe that it would discredit the formal schooling that is currently required.  There is much more than apprenticing or learning tricks of the trade when it comes to becoming a professional esthetician and then later to become a master esthetician. How could the proper information be put out if it's not regulated?  Who could then confirm the information to be accurate? How could it be confirmed that the apprentice actually worked the hours they document and the same goes for their hands on time. Everything that I have learned as a professional esthetician in a formal school setting was essential to the safety of my clients. There are many basic things that  are taught in school about sanitation, the functions of the skin and the chemistry of the products in relationship to the skin, anatomy,  recognizing and referring medical conditions, and the regulations and the scope of practice of an esthetician...just to name a few. If we take away the formal training and schooling we are taking a step backwards in the esthetic field and we will watch this profession decline in quality and also in the safety of the client. Before become licensed myself I had to undergo many written and practical tests to prove I knew what I was doing and how to do it safely and in a sanitaylry manner. It was only then that I could understand and learn the Requirements for state board. In order to maintain the integrity of our field and the health and safety of our client's skin we need to ensure all individuals lookin. To become estheticians are properly educated.

I oppose! Proper training is needed for the health and wellbeing of any and all clients.

I am opposed to Esthetics apprenticeships. In Virginia, even a school who has not undergone extreme scrutiny through the process of accreditation, is still subject to basic curriculum requirements set forth by the state board. If Esthetics apprenticeship becomes an approved method for bringing people into the Esthetics industry, it will become much more difficult for the state to enforce these basic curriculum requirements. If basic curriculum requirements are not met, the industry as a whole will suffer. Estheticians will not be as knowledgeable and moreover, may pose a safety risk to their clients. Client safety is the primary reason Esthetics licensure was put into place and approving apprenticeships for aestheticians could jeopardize that. 

I oppose apprenticeships for estheticians. I feel that apprentices in the esthetics industry would put the safety of the public at risk from the lack of a regulated curriculum. Additionally, it would harm the reputation of the licensed estheticians who have undergone formal education and training, because there are many parts to the esthetics curriculum formally taught in schools that can not be taught through an apprenticeship program. The esthetics field would only be moving backwards if apprenticeships are approved for this field.

OPPOSED TO APPRENTICESHIP

If this is passed, esthetic training will no longer fall under the oversight of DPOR but will be overseen by the Labor Board.  DPOR regulates the esthetics industry in Virginia and has strict and stringent standards in esthetics training.  If this bill passes, we would expect lower standards under this arrangement which could impact the health and safety of the public.  As standards are lowered and quality suffers the reputation of the esthetics industry will also suffer.

If you do not have the structure of a dedicated classroom environment, in which theory, rules, safety and sanitation are taught and valued, how can you ensure that the public's health and safety isn't jeopardized? In a theory classroom and in the practical classroom, safety and sanitation are taught without regard to commerce. How can you ensure that the apprecenticeship program will not be exploited as a low cost method in which to service clients? The public trusts their government to protect their safety.

I am opposed to an Aprenticeship in Virginia

Under the regulatory agent of DPOR our industry provides licensure and professionalism. How and who will be the ones to offer "apprenticeships"?  Who will be the regulatory agent to vet this folks. How do we know those who offer apprenticeship are qualifed? 

WE WON'T, without a regulatory agent.

This is a terrible hit to our industry. We are just lifting-up  our profession of "licensing professional" of Ethetics and now you are proposiing to take us back.

Big, Big mistake and lacking understanding about our profession!

I oppose apprenticeship programs in esthetics in the Commonwealth of VA. I think formal education in the esthetic field provides crediibility, safety, experience and gives the ethetician the knowledge to educate the public in the many services that it provides.  Clients expect estheticians to know about products, ingrediants, safety, which treatments are best for their skin condition/type and why, I don't believe that an apprenticeship program can adequately train someone for these expectations. I feel that esthetics is much more than putting products on faces and that it should be given the respect by upholding the current laws that the Commonwealth has established.

I support the esthetics apprenticeship. It will give future estheticians a more realistic industry insight that a traditional classroom does not teach:  building clientele, business experience (profit & loss), processing payments, scheduling, marketing, schedule flexibility, front desk, overhead contraints, ordering products, supplies, and equipment, vendor relationships, learning from an experienced professional, and etc... 

I support the esthetics apprenticeship. It will give future estheticians a more realistic industry insight that a traditional classroom does not teach:  building clientele, business experience (profit & loss), processing payments, scheduling, marketing, schedule flexibility, front desk, overhead contraints, ordering products, supplies, and equipment, vendor relationships, learning from an experienced professional, and etc... 

the regulation of the esthetics industry by the DPOR is imperative in maintaining client safety!  It's a 1200 hour program in VA to become a master

esthetican and without regulation the standards will drop and the industry will

suffer along with the consumer.  This will lower the standards of credibility for the industry as well!!!

This is indeed a nightmare waiting to happen. Safety and the general well being and honesty that is formed from formal education needs to be applied to the field of Aesthetics.  This would be insulting to all in the field. Thank you for allowing us to voice our opinions.    

I am opposed to the apprenticeship program.  I have spent several hours reading and studying all the documents that are posted.  From what I have read, it appears to me that the DPOR supports the apprentice program.  The argument being that it has no negative economic impact.  My observation after reading the EIA is that it does not address the negative impact the legislation has on the graduates of esthetic schools.  Example, I am a shop owner and I need to hire an esthetician.  Currently my only option is to hire a licensed esthetician and pay them a wage that is much higher than minimum wage.  If the proposed legislation passes I can now hire an apprentice and justify paying them a meager minimum wage under the guise of training them. This puts all graduates in an extremely unfair position!

Apprenticeship in the field of esthetics is logistically different from a cosmetology apprenticeship and holds major obstacles that can’t be overcome.  Spa clients do not want a second person in the room while getting a treatment and the rooms are not large enough.  The cosmetology salon has an open floor concept and affords a “community of teachers mentality” where  apprentices can learn from the whole community, one stylist contributing to the person's education and then another takes over and so on… but esthetics involves one technician and that one technician is working on clients all day in a small dark room.  The end result would be the apprentice serving a cheap slave labor for the spa owner in the form of cleaning, receptionist, washing and folding towels and stocking products.  Unfortunately that is what goes on mostly in cosmetology as well.  Attention to education is seldom.

If you look at the facts, the apprenticeship programs sends the apprentices to designated tech centers for theory and in looking at the pass rates it is dismal for both theory and practical. The Richmond technical center is the largest apprenticeship facility in the state of Virginia and has a dismal pass rate as do other centers across Virginia.  According to Ergometrics testing reports (Virginia’s state board license testing facility), pass rates for licensure after apprenticeship are well below that of formal school training, infact the rates are unacceptable outcomes considering the time invested by the individual in the apprenticeship:

Cosmetology: Written pass rate - 23.08% & Practical pass rate - 66.67%

Barber: Written pass rate - 50% & Practical pass rate - 0%

If you can’t pass both the practical, written you can’t get a license so:  23% of the cosmetology apprentices qualified for a license and 0% qualified for a barber license after over 2 years in the salon getting “on the job training” through apprenticeship.  If this was the success rate of a school it would lose the school license due to state board complaints and low outcomes.  The numbers speak to the lack of success of the cosmetology apprenticeship program in the state of Virginia. Why expand a failing process?

Why would anyone invest their time and manual labor for minimum wage for double the time it takes to go through regular school - only to have a possible 23% or 0% percent chance to gain a license?  These are horrible gambling odds for the person trying to improve their life with a new career in the cosmetology field.

Instead of adding apprenticeship for esthetics, cosmetology should be shut down due to low outcomes.  Why continue to add to a trend that is clearly exploiting individuals who want to enter into the industry for nearly free labor?   

According to the pass rates published by the state, it is a proven fact that apprenticeship is not a viable method of gaining licensure and esthetics licensure.  

If the individuals are unable to pass the licensing exam that provides the public assurance from harm by establishing entry level proficiency into the field, we are really exposing the fact that the practitioners who are actually apprenticing are unsafe and dangerous to the public while apprenticing.  

The board claims that cosmetologist are trained in techniques similar to that of an esthetician such as a cleansing facial, and waxing - yet the cosmetology apprenticeship's high fail rates already demonstrate esthetics has no place in apprenticeship.  

Master Esthetics deals with more technical chemicals that cosmetology does such as chemical peels that can blind, scar and disfigure, in the hands of untrained individuals.  If the cosmetology apprenticeship demonstrates failure in lower level technical skills why would the board risk the safety of the citizens of the commonwealth by allowing a higher level of competency be completed via apprenticeship that are already proven to result in very low pass rates?

Apprenticeship should not move forward because it will pose harm to the citizens of the Commonwealth of Virginia by exposing them to unsafe practices along the way and should not be allowed to proceed.