Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Barbers and Cosmetology
 
chapter
Esthetics Regulations [18 VAC 41 ‑ 70]
Action General Review 2014
Stage Proposed
Comment Period Ended on 12/18/2015
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Previous Comment     Back to List of Comments
12/18/15  9:02 pm
Commenter: Concerned citizen

Oppose apprenticeship
 

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. 

CommentID: 46043