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.