As an educator of Estheticians for over 6 years, I should like to address the new VA regulations.  While I am in favor of a good basic program (500-600 hours), I feel it is unjust to expect students to do a further 600 hours for a Master program.  As is currently outlined in draft, an esthetician who would like to practice, ie: Microdermabrasion, would be required to do a full 600 hour program, learning techniques that he/she may not want to include in his/her practice.  This, surely, is unjust, not to mention expensive and time prohibitive for the majority of students.  In fact, it would seem the only people to benefit from such a program would be the people offering a 1200 program.  Also, has the board considered those therapists who are currently offering a few, but not all, of these services?  Are they, too, going to be expected to do a further 600 hours of study?  In fact how are those currently practicing to be grandfathered in?  Moreover, I have read nothing on how the board proposes to grandfather in those who have completed Esthetician training in another country.  It is my view that such a Master's program, as now drafted, would not only negatively affect students' prospects, but would also cause problems of enforcement for the board.

I feel that students would be better served  by allowing them the right to choose the fields of expertise they wish to pursue, and that these adjuncts to their basic training be offered in modular form, with a certain amount of hours fulfilled in practical application.  Moreover, the draft as it now stands, crosses lines into other professions.  For example, manual lymph drainage for the esthetician should be confined to the chest and face.  Whole body manual lymph drainage is infringing on the profession of Massage Therapist.

While I congratulate the board in trying to regulate the profession of Esthetician, it is my belief that in some cases it has been misinformed by persons who only have their own interests at heart.  Therefore, I ask that the board reconsider the 600 hour Master program and, instead, offer continuing education units (already in place for Massage Therapists) in the various disciplines in modular form.

Respectfully,