While I feel that it is very important to have the estheticians in this state licensed to protect the public against uneducated individuals providing services that  could harm members of the public, I am concerned to see that microdermabrasion, glycolic, alpha and beta hydroxy peels will be included in a license that costs an extra $11,000.  For the school owners that proposed this regulation to categorize these services with the medical grade services of  Jessner peels, TCA peels, and laser treatments makes me wonder if they truly understand what is being taught at their schools.  Even more alarming is that individuals that are on the board and who proposed this new regulation are the same individuals that will make a fortune off of these services as they are the school owners. 

The public can purchase glycolic, alpha and beta hydroxy products off of the shelves in CVS and a home microderm kit from Rite Aid.  As the regulation is written, as a technician with 600 hours of schooling plus experience, I would be able to perform a microdermabrasion on my longstanding guests on one day and the next day after the law is put in effect, I would not be able to provide her microderm services unless I chose to pay a school additional monies for their certificates?  Unless I chose to give one of the schools an additional $11,000, I would have to inform my long term guests that I was no longer able to provide these services because we missed a deadline unknown to us when we started school (the deadline being, I should have started school earlier).  Who is this law really helping?  As written it is not protecting the public but financially assisting the esthetics schools.

I propose the following:

- there should be licensing for estheticians, 600 hours without question

- glycolic, alpha hydroxy, beta hydroxy and microderm should be part of the basic license

- laser treatments, medical microdermabrasion, TCA and Jessner peels should require more schooling and additional licensing

- anyone who will receive a financial benefit from this new law should remove themselves from the lawmaking process.  It is unethical and a conflict of interest.

Even if those of us with 3 years of experience were to apply to be grandfathered to receive a masters license, we have never performed these advanced medical services so either we will be given a license to perform TCA and Jessner peels that we have never learned or performed or we will have to pay the schools some amount of money to receive credit hours so that we may receive our master's license. 

Thank you for your time.