Grandfathering

I have many concerns in regard to the proposed esthetics regulations, especially in regard to protecting the clinicians currently in the workforce. There are many skilled estheticians in Virginia who are performing treatments at the level of master esthetician. An esthetician should not be denied a master license because an element might be missing from their education and/or work experience as stated in the definition of a "master esthetician." These proposed regulations will hurt many clinicians who have worked very hard to open a business, build a clientele and earn a living.

What is the definition of a spa? If the esthetics facility is a single entity with no other employees and does not offer spa services (i.e., hydrotherapy, body treatments, etc. that are traditionally performed by "spas,") how will they be classified? Why should a single esthetic practitioner have to pay a "spa" fee since they are already required to have a license (plus a fee) to practice?

Prorating of Fees

If someone opens a spa in the last quarter of a cycle, their fee should be pro rated. Otherwise, the licensee will have to pay full fees twice within months of establishing their business.

At present there is only a handful of schools that offer the master esthetics program. If schools are not presently offering a master program, there will be a shortage of instructors available to teach the master curriculum. These school instructors will see themselves having to go to those schools that currently offer the programs. How will this be addressed?

The curriculum as stated in the May 1st draft will seriously hurt many estheticians, spas/salons and schools if these regulations are adopted at 1200 hours beginning July 1, 2007. I am for two-tier licensure and 1200 hours but feel strongly that 1200 hours should be our ultimate goal and not our starting goal. Many states are in the process of increasing their hours but have done so incrementally over many years. With Virginia having had no regulations and to start with 1200 hours will cause a hardship to those with less than 1200 hours and severely impact their right to work. If these proposed regulations are implemented, many spas, salons, and independent skin care businesses may have to close their doors. I am sure this is something the Board wants to avoid.

All schools should be allowed to offer the master esthetician program in modules to allow estheticians currently in the workforce the ability to obtain their master licence. Estheticians who are currently working will find it difficult to go back to school. There are a few schools that are prepared to offer the modules and these charge exorbitant fees.

My recommendation for establishing hours is as follows:

July 1, 2007 Basic Esthetician Licensure – 400

                    Master Esthetician Licensure – 300

July 1, 2009 Basic Esthetician Licensure – 600

                    Master Esthetician Licensure – 300

July 1, 2011 Basic Esthetician Licensure – 600

                    Master Esthetician Licensure – 600

The curriculums as stated in the proposed draft are too specific and should be written globally. Writing in too many specifics (i.e., equipment to be used, types of chemical peels and microdermabrasion crystals to be taught) should be left to the individual schools. Products and equipment vary and schools should decide which to choose as long as adequate theory and practical hours are taught. Many schools may wish to approach a topic as theory knowledge (i.e., dermaplanning) versus having actual practical sessions to reduce their liability and insurance costs.

There was no mention of continuing education in the proposed regulations. The esthetics industry is growing at a rapid pace and it should be mandatory that estheticians keep their skills at top level.