Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Barbers and Cosmetology
 
chapter
Barbering and Cosmetology Regulations [18 VAC 41 ‑ 20]
Action Lower Cosmetology Training to 1,000 Hours
Stage NOIRA
Comment Period Ended on 10/12/2022
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44 comments

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9/12/22  2:29 pm
Commenter: LaFarn Burton

Change in cosmetology hours
 

The deduction in cosmetology hours should also include the deduction in subject matters under cosmetology.  I suggest that nails (150 hours), wax/threading (115 hours), makeup, and eyelash extensions be removed from the curriculum. Cosmetology should include hair only for the proposed 1000 hours.

Thanks.

CommentID: 128553
 

9/14/22  8:44 pm
Commenter: Stephanie J Smith

NOIRA
 

I do not agree with lowering the Cosmetology hours to 1000.  Cosmetology is the umbrella that house all disciplines and changing the hours  to less than 1500 would not do our industry any justice.  If we were to eliminate disciplines from the cosmetology program ie. nails, wax, facials, etc.,  yes it would be more conducive; but still not to 1000.  

Barbering has been reduced to 1100 hours and that is strictly hair with no chemicals.  So you are wanting to make Cosmetology less hours than Barbering?, where Cosmetology is able to work with chemically treated hair ie. hair color, permanents and relaxers.

Again I do not agree with the changing of Cosmetology hours to 1000.

CommentID: 128644
 

9/18/22  4:13 pm
Commenter: Cian

Cosmetology Hours
 

Cosmetology in the state has a much wider curriculum than the barbering license has at this time. The number of hours required would be lower than their license if this change were to occur. In order to allow for proper and complete understanding of all content required to prosper as a cosmetologist in this state the hours required should not be lowered. 

CommentID: 128870
 

9/18/22  10:54 pm
Commenter: Zachary Ramsey

Do not reduce hours
 

Our industry is already inundated with newly graduated cosmetologists who are unable to perform basic haircuts, color, and texture services. I am a manager of a franchise salon, located within the nation's largest retailer; and I see these cosmetologists regularly. When they enter the work force, the onus falls to us to complete the basic education of new graduates. Frankly it is unsafe, and uneconomical.

I do not say this lightly. Our industry is suffering from post-pandemic scarcity. It is difficult to find stylists who are willing to risk taking a commission-based job in the current economic climate. But to license under-educated people would, to me, be unwise indeed. 

The 'Milady' textbook is comprehensive, but students are seldom given the opportunity to practice the theory they've been taught. As a result, they exit school perfectly able to pass the PSI nonsense exam, but are woefully unprepared to service actual clients. 

If any new regulations are passed, it should be to increase the practical education of cosmetologists and barbers. Reducing hours will pile additional burdens on an already struggling industry.

CommentID: 128871
 

9/19/22  11:48 am
Commenter: Geraldine Burgess

Cosmetology
 

Do not reduce their hours.  If that is done you are risking their Education and proper training. Essentially you are setting them up for FAILURE. WAY TO GO TRUMPKIN

CommentID: 128873
 

9/19/22  4:32 pm
Commenter: Kristina NeCollins

Vote No
 

Reducing the hours for Cosmetology instruction is a disservice to the industry.  There are so many students that come fresh out of school needing another 6 months to a year to learn the hands-on chemical and technical things for just hair services, let alone the nails, waxing, and facial portions. It's not going to help by reducing the hours of education. We see more people leave the industry because they are not technically adept and able to build a clientele. Quality education requires time, if anything there should be an apprenticeship  requirement prior to full licensing.  

CommentID: 128881
 

9/20/22  7:38 pm
Commenter: Jodi Gist

Negative Vote
 

There are many professions who are currently understaffed, however, lowering education requirements only means we have a more difficult time finding a qualified hair dresser.  I do not think that people who want to become licensed are not doing so because of the 500 hour time difference.  Vote no.

CommentID: 128895
 

9/21/22  12:09 pm
Commenter: Tabbitha Bowler

Hours requirement for cosmetology
 

Good day, the required hours for cosmetology should not be lowered, contrarily more hours should be required. I also think that continued education be required with each renewal. The scope of practice for cosmetology deems the need for more hours. Barbers are required 1100 hours with a very limited scope of practice. That is absolutely ridiculous. It is obvious that the ones proposing these changes have no idea as to what we as professionals or educators have to know in order do our chosen practices. This decision should definitely be reconsidered and overturned. This is not acceptable and it makes a mockery of those who have paid their dues and set the foreground for up and coming professionals. 

 

CommentID: 128920
 

9/21/22  7:32 pm
Commenter: Amanda Pickering

Cosmetology Hours
 

Good evening,

As being a stylist and an instructor for years 1500 hours just gets stylists to pass theory and practical exams. Stylists still need more education when coming into the salon to become better at there craft.  Lessening the hours for students would be difficult with all material and practical work that is needed to be an industry professional.  The students already feel they don’t learn enough in 1,500 hours when leaving school.  At 1,000 hours students will feel uneducated in certain areas of the field, unconfident in their work, have more customer complaints and not to mention law suits that these stylist can’t afford to pay for.  So, lowering the cosmetology hours to 1,000 should not even be a topic of discussion.

CommentID: 128924
 

9/21/22  10:03 pm
Commenter: Roman’s Hair Empire & Beauty Academy

No change in Cosmetology hours
 

As a Instructor I don’t think it would be wise to lower cosmetology hours.  I feel we are already moving quickly just to make sure everything done before 1500 hours! Lowering the hours will be a mess for many schools and instructors. Please take the advice of the front line workers and DO NOT DECREASE COSMETOLOGY HOURS! 

CommentID: 128926
 

9/22/22  1:56 am
Commenter: Sajer Guy

Lower hours
 

Please lower the hour requirement to give young workers better opportunity to enter this field without paying onerous fees to schools.  Allow the marketplace to decide if their skills are adequate rather than setting a state requirement.

CommentID: 128927
 

9/22/22  8:57 am
Commenter: Sharpen Your Skillz Continuing Education And Salon LLC

Cosmetology Training Hours Need To Remain At 1500
 

The training hours to obtain a license in cosmetology needs to remain at 1500 hours. Currently students and graduates have consistently given feedback verbally, and shown in their lack of proficiency in their knowledge and practical skill set that they are not prepared to work in the industry. Lowering the initial training hours will make this current problem even worse. Future cosmetology professionals who are not adequately trained hurts not only the industry but most of all the general public.

CommentID: 128928
 

9/22/22  12:27 pm
Commenter: Fusions School of Cosmetology

No Reduction in Hours for Cosmetology Training
 

Students need the 1500 hours of training to complete not only the Theory portion of the training, but also the Practical training required to work in the industry.

As it currently stands, students are required to perform 525 performances in order to become proficient as licensed Cosmetologists. 1000 hours is not ample time to complete these performances. 

Students need to be prepared to work in the industry upon graduation, practice hours makes them more prepared when they graduate. 

CommentID: 128931
 

9/22/22  2:43 pm
Commenter: Bonita Pines

Do not lower the Cosmetology program
 

I do not agree with the lowering of the cosmetology hours from 1500 to 1000 hours. Some students need additional practice and training upon completion of the cosmetology course. By lowering the hours The program will be rushed and students will not be fully prepared in their area of expertise. Also grants will have to be altered to accommodate lowering the hours.  As an educator/owner alot of work and preparation is required to teach the students. I do not want my staff to curtail the curriculum and feel rushed preparing the students.  

CommentID: 128936
 

9/22/22  3:09 pm
Commenter: Shamecca Sawyer

Cosmetology hours
 

As a student I think the hours should change.  I see a lot of comments speaking on practice with chemicals but most schools work with mock product which to me is not my idea of real practice anyway it seems that actual experience will help more plus lots of the comments against it seem to be from school representatives and of course it’s hard to believe there ultimate goal is not to make money. More hours more money.  If that’s not the case please prove me wrong by reducing tuition cost please.  Lots of people drop out of beauty school because of money issues.

CommentID: 128937
 

9/22/22  5:54 pm
Commenter: Julie Garcia

Separate Hair Stylist program
 

Rather than reducing the training hours of cosmetology license, I think it will be more  efficient  if we have separate hair stylist license like Maryland state. Many of my friends study cosmetology to become hair stylist, but they all think they waste time and money learning uninterested nails and skin together.

Please come to a reasonable conclusion

CommentID: 128938
 

9/24/22  9:49 am
Commenter: Maggie Marciniak

Keep 1500 hours
 

As a licensed cosmetologist for 16 years and now a Cosmetology Instructor I oppose dropping Cosmetology hours to 1000. At 1500 hours students are just starting to feel comfortable with the idea of getting behind the chair on their own. If they graduated and went behind the chair with only 1000 hours, their speed, technical skills, and business knowledge aren’t strong enough to sustain a livable income, especially with this field being commission based. Many graduates at 1000 hours would need to be hired as assistants, so they would more then likely need to have another part time job in order to live comfortably. If stylists get behind the chair before they are ready then they will end up making mistakes, losing money and confidence and ultimately quit. We owe it to them to give them the proper education to be able to have a sustainable income and a great foundation to build on and 1000 hours will hinder that process. At 1000 hours they haven’t even worked with enough guests to fully understand all client safety, protection, and sanitation. It’s not just about skill, it’s about knowing how to keep their guest safe and protected from chemicals, tools, infection at all times without us watching them and they need the time in a safe school environment to build those habits and knowledge. 

CommentID: 128942
 

9/24/22  5:48 pm
Commenter: Val Pennington

Reducing training hours
 

As  a  licensed nail tech I would’ve lost money if someone had bet me  that the word anus was in my nail tech study guide because I would’ve been wrong having to have learned the 10 systems of the body in order to be licensed it is definitely part of the digestive system . At the time I thought it was silly and not going to make me a better nail tech but 30 years later I realized that it actually probably did make me a better nail tech and more aware of my clients and how important it is to keep their safety in mind when you’re working on them cosmetology has a much broader spectrum and they need to be very very careful using all the chemicals so reducing their training hours to 1000 is absolutely absurd reducing the training by 2000 hours would be tricky enough I say leave it as is and let people get all the training they can get thank you for your consideration. 

CommentID: 128943
 

9/25/22  11:49 am
Commenter: Viktoria Ivanova

Do Not Reduce Hours
 

Cosmetology has such a wide variety of subjects, specialties, and styles. Lowering the required amount of hours from 1,500 to a mere 1,000 would substantially impact the skill level of future cosmetology professionals. Less education is never the answer.

CommentID: 128945
 

9/26/22  1:20 pm
Commenter: Esther Lawson

Keep Cosmology at 1500 Hours
 

Good afternoon 

  I have been an Practicing cosmetologist in Va. For 30 years or more.I feel the hours should stay where it is. This Profession has become very non professional at the hands of the state regulators board. You all never inspect salons. you don’t regulate  licensing of stylists  . and you allow hair to be practiced in residential housing. and allow non- licensed people to advertise on booking sites such as style seat- and Groupon. Further hurting  the industry. The public deserves Qualified and well Educated Professionals to insure a quality product.  Changing the curriculum and hours would not ensure the best Educated Professional ready to  hit the ground running . A prepared stylist need floor hours and proper application techniques. And a high quality of theory hours To Be ready to serve our Public. I feel the process we have in place fits and address the needs  to  Embark  into a successful Cosmetology Career. 

  Thanks 

CommentID: 131031
 

9/27/22  10:43 am
Commenter: Anonymous

Do not reduce hours
 

I did my 1500 hours and realized I could have used more to be better prepared in my field. Many enter the work force still not ready/confident in their skill and do not thrive because of this. I’ve also seen mistakes with chemicals happen because of in experience with actual chemicals on humans. 

CommentID: 146127
 

9/27/22  12:52 pm
Commenter: Edward Timmons, West Virginia University

Trimming Cosmetologist Regulation Will Not Harm Consumers
 

I appreciate the opportunity to comment on the regulation of cosmetologists licensed by the Board for Barbers and Cosmetology in Virginia. I am an associate professor of economics and director of the Knee Center for the Study of Occupational Regulation at West Virginia University. I am also a senior research fellow with the Archbridge Institute.  This comment is not submitted on behalf of any party or interest group. 

My own research and the research of other scholars has shown that licensing restricts entry into professions and leads to higher prices for consumers.[1] The main takeaways of my comments are the following:

  1. More than 100 million residents in the United Kingdom and Spain and half of the member states of the European Union have lived without barber and cosmetologist licensing for decades, and there is no evidence that consumers have suffered as a result.
  2. A recent research paper finds that consumers are much more interested in online ratings from peers than in state-issued licenses when choosing service providers.
  3. Virginia will not be unique if it reduces cosmetology licensing requirements from 1,500 to 1,000 hours.

Occupational licensing is not the only way to regulate a service, but it is the most onerous way.

The United Kingdom, Spain, and half of the members of the European Union do not require barbers or cosmetologists to obtain a license to work.[2] Barbers and cosmetologists in the United Kingdom can obtain certification if they choose to do so—it is completely voluntary. Barber and cosmetology schools continue to exist, and the market functions well. There is no evidence that the more than 100 million consumers in the United Kingdom, Spain, and other European nations have been harmed as a result of a lack of occupational licensing.

There are several other services at least as important as barber and cosmetology services whose providers are not subject to licensing. Chefs and waitstaff at restaurants and auto mechanics are not required to be licensed. Chefs and waitstaff are regulated by random inspections and complete basic food safety training, and mechanics can obtain voluntary certification. All service providers are regulated by market discipline—poor-quality providers will not be in business for long.

I have never asked to see my barber’s state-issued license. Instead, I ask my friends or go online to learn about provider reputation and quality.

A recent research paper more formally documents this behavior: on an online platform for home repair contracting services, consumers are much more interested in the online ratings of service providers than in state-issued licenses.[3] Recent research also shows that licensing has no measurable impact on consumer perceptions of the quality of service.[4]

If Virginia reduces cosmetology licensing requirements from 1,500 to 1,000 hours, it will be joining 15 other states that have made similar changes in the last 10 years. New York state, as an example, has required 1,000 hours for decades. There is no evidence of consumer harm resulting from this less burdensome entry requirement. 

Today, it is hard to justify requiring licenses for barbers and cosmetologists in Virginia. The market has dramatically changed since many of these licensing laws were written. This proposed reform is an important first step toward recognizing this fact, but it is also time to more carefully reassess the costs of these regulations.



[1] Edward J. Timmons and Robert Thornton, “The Licensing of Barbers in the USA,” British Journal of Industrial Relations 48, no. 4 (2010): 740–57; US Department of the Treasury, Council of Economic Advisers, and US Department of Labor, Occupational Licensing: A Framework for Policymakers, July 2015.

[2] EU Single Market Regulated Professions Database, “Hairdresser / Barber / Wig-Makers,” European Commission, accessed April 28, 2021, https://ec.europa.eu/growth/tools-databases/regprof/index.cfm?action=profession&id_profession=12019.

[3] Chiara Farronato et al., “Consumer Protection in an Online World: An Analysis of Occupational Licensing” (NBER Working Paper No. 26601, National Bureau of Economic Research, Cambridge, MA, January 2020).

[4] Darwyyn Deyo, “Testing Licensing and Consumer Satisfaction for Beauty Services in the United States,” Kleiner Koumenta, eds. 2022. Grease or Grit? International Case Studies of Occupational Licensing and Its Effects on Efficiency and Quality. Kalamazoo, MI: W.E. Upjohn Institute for Employment Research.

 

 

CommentID: 147062
 

9/27/22  4:33 pm
Commenter: Tamara Lewis Salon Voss, Inc.

DO NOT REDUCE HOURS
 

Reducing hours would not benefit our industry.  We are already struggling to get everything the apprentices need to know taught.  If you reduce the hours even further we are going to have a lot of messed up hair walking around.  You would be doing an injustice to the apprenticeship program.  

CommentID: 148663
 

9/28/22  9:51 am
Commenter: Anonymous

DO NOT REDUCE HOURS
 

Hours need to remain as is

CommentID: 156759
 

9/30/22  11:49 am
Commenter: Staunton School of Cosmetology

Cosmetology Hours
 

The Cosmetology Industry and the reputation of Stylists and Educators has changed through the years to a more professional industry. As a stylist, educator, salon and school owner reducing the hours required would be a serious mistake to our industry.

The students graduating from school are in need of more support than we have ever encountered. Reducing the hours that would give them the confidence to secure a stable and successful future will cause a serious decline in stylists leaving the profession.

Salon owners do not have the time to continue to train students and build their confidence. As a salon owner with commissioned and independent stylist I can say with surety this will not solve a problem. Graduates want to be confident and successful, their greatest fear is not being ready for the salon.  Our school was in operation when the hours were reduced from 2000 to 1500. This did not benefit the salons, or the students. If a student graduates at 1000 hours they will not be able to successfully work independently and salon owners will not be able to employ them and train them to be successful. Our industry should never lower our standards only work to raise them. This reduction will not solve a "workforce shortage". It will create problems for those salons who feel they need to fill their chairs. It will cause a loss of clients, fellow stylists already established that have to invest more time in salon operation and the reputation of the salon will suffer.  A solution for those salons who have a shortage is to implement the apprentice program into your salon, this gives prospective stylists a choice in how they want to be educated. Let your salon leaders be the educators (you will have to employ anyway) if the hours are reduced. It will also give you a different perspective of what is involved in giving a student a good education. 

To address the cost of educating a student: there are few that know the expense that it takes for operating a school. The school has many required fees and certifications that impact the cost of a students education. Schools must maintain high standards to operate and the standards and regulations have increased. The purpose of these standards is to make sure we give the students what they are paying for, a good education and to become successfully employed in the industry. I question, why would we want to lower standards for those entering our profession? This reduction will not make a students education more affordable. A students funding (Pell & Grants) would be impacted and it would increase the out of pocket expenses to the student therefore making it impossible for some students to come to school. The result of reducing the hours will be:  FEWER STUDENTS who can afford to come to school and FEWER STUDENTS to help fill the "workforce shortage" and MORE GRADUATES leaving the industry because of lack of training and confidence.

CommentID: 182131
 

9/30/22  1:24 pm
Commenter: Anonymous

do not reduce hours!
 

Virginia is already one of the lower required hour states for cosmetology! Please this is a safety hazard to have poorly trained individuals!

CommentID: 182263
 

9/30/22  2:18 pm
Commenter: Anonymous

Do not reduce hours
 

The current number of hours required is adequate to ensure proper training. By reducing the training, especially by such a significant amount, providers may not have the appropriate level of skill to safely provide for their client's needs.

CommentID: 182354
 

10/1/22  6:54 pm
Commenter: Anonymous

Do No Reduce Cosmetology Hours
 

I began earning my cosmetology license when I was in my junior year of high school. I finished my licensure in my senior year of high school, and was able to find a career at a local hair salon. Yet, I do not feel I was trained enough, even with the 1,500 hour minimum, especially with chemical processes! Please do not add stress on educators/staff who are still being burden by COVID. Please keep the number of hours the same for cosmetology at least! 

CommentID: 183426
 

10/4/22  1:36 pm
Commenter: Anonymous

Cosmetology training hours
 

Do not reduce hours

CommentID: 185065
 

10/5/22  7:13 pm
Commenter: Ms. Williams

I am against the reduction of Cosmetology Hours for a Cosmetology License in Virginia
 

As a part time Cosmetology Student, I feel that the hours should not be reduced from 1500 to 1000. It is necessary for each student to be properly trained on  procedures , how to safely execute chemical services, cutting, infection control, salon business and how to handle electric instruments. If I were a customer, I would be concerned about my stylist having the proper training to execute the salon services requested. 

While there is a  great need for additional cosmetologists in the field, competency should be the focus as opposed to producing a revolving door of improperly  trained students through various cosmetology schools.  Those improperly trained students will then be serving the public. This puts salons at risk as this could be a liability issue.The reduction of the hours will  not benefit the salons, stylists, consumers or the industry as a whole.

CommentID: 185809
 

10/6/22  9:58 am
Commenter: J. Jones

I Support a Reduction of Cosmetologist Regulation/Hours Contingent that Public Health is Not at Risk
 

I am grateful for the opportunity to comment on the regulation of Barbering and Cosmetology Regulations which are licensed by the Board for Barbers and Cosmetology in Virginia.

My understanding of this policy is limited to information found online and within public forums. However, it appears that a reduction of hours would not have a significant impact on consumer satisfaction nor the health of the public. Additionally, more hours can result in higher prices for consumers. Although 1,500 hours appears to be the normal hours across several state requirements, there are states that are already set at 1,000 hours. Virginia would not be “paving” the way for less Cosmetology requirements. I was not able to find ant research that would suggest that the services provided in New York are any less of quality than in Virginia.

Many of the comments on this thread focus on the concept of “hair styles.” Styles have changed over the years and will continue to change. The state does not require these cosmetologists to return and retrain on “styles” so why have such an emphasis on training for style. Let the independent organizations hiring stylists train them on how to “style” hair. My main concern is for the state to continue to focus on training that revolves around the health and safety practices involved with cutting hair.

Additionally, other countries, such as the UK, do not require a governmentally issues license to cut hair. It is optional. While researching this topic, I was not able to find any research that suggested that the quality of services were any worse due to the lack of governmental licensing for cosmetology.

If this regulation passes, I would recommend keeping the same amount of training that is focused on the cleanliness of the workplace, sanitation efforts, hygiene, and the health/safety of both the cosmetologist and customer.

This comment is not suggested on behalf of any political party or interest group. 

Thank you.

CommentID: 186991
 

10/6/22  8:24 pm
Commenter: Jacqueline Anderson

Support
 

This change will help the students enrolled in the cosmetology program at Powhatan High School.  I welcome this change.

CommentID: 187472
 

10/7/22  9:22 am
Commenter: Tanya Lumsden

I am against the reduction of training hours for cosmetology.
 

As someone who has just started working in a Cosmetology school I am against the reduction of hours. I have been working as a receptionist and now am in Admissions and I have seen that 1500 hours in my opinion is not enough. We have students that are having trouble getting the required amount of clinicals. I think that it would be detrimental not only to the student but also their clients. Barbers have to have 1100 hours and they do not work with the chemicals that Cosmetologists do. If there is a reduction of hour's it will be very bad for this industry, we will see a decline in capable cosmetologist and open up them and their salons to lawsuits.  Again I am against the reduction of hours!!!!!!!

CommentID: 187611
 

10/7/22  9:32 am
Commenter: James Taylor

I support.
 

I believe the reduction in hours will make it possible for more students to participate and finish while in high school.

CommentID: 187621
 

10/7/22  12:59 pm
Commenter: Kim Hymel

Support
 

More students at Powhatan High School would be able to participate in the Cosmetology Program with this change.

CommentID: 187724
 

10/11/22  11:20 am
Commenter: Joyce Worrall

Do Not Reduce Hours
 

Do not reduce the Cosmetology training hours from 1500 to 1000.

This change would not benefit the Cosmetology student for numerous reasons. Education is valuable in all fields. By taking away education from students/graduates, we are taking away their value and the chance to change the world.  Nelson Mandela said: "Education is the most powerful weapon you can use to change the world." Cosmetology students deserve an education that allows for time to develop not only their practical skills, but also their soft skills.  Cosmetology students want to not only graduate , get licensed, work in the field, but most importantly to make a living supporting their families. By reducing the hours you are devaluing our students education, which we fear will lead to devauled pay, i.e minimum wage paying jobs.

Reducing the hours will impact the ability of our military student/graduate to transfer their license to a bordering state since all are 1500 hours or higher.

For students using Title IV funds, the Pell grant will be reduced by thousands of dollars, therefore increasing the out-of=pocket costs.  Reducing federal aid money will reduce enrollment, leading to a workforce shortage.

The workforce will be impacted by this change as enrollment will be halted as schools seek program approval through DPOR, and SCHEV, then their acceditor, as well as the Department of Education, all of which take considerable time .

Small businesses need and want graduates prepared to work immediately behind the chair.  The Regulatory Advisory Panel was only asked questions about what time is necessary for the safety of the general public, but were not asked about the time needed to be skilled at cosmetology services.  Cosmetology students deserve 1500 hours to learn, and develop their skill in school, so they can be confident & successful behind the chair and remain in this beautiful industry for many years.

DO NOT REDUCE THE COSMETOLOGY HOURS!

 

CommentID: 188886
 

10/11/22  12:00 pm
Commenter: Kristen Kent

A reduction in education is not the answer
 

I do not support this reduction in education for several reasons.

  1. There are other avenues to licensure in Virginia through the apprenticeship program and the high school program. No one is forced into the school avenue, so why is the school avenue to licensure the one being targeted for reduction? Most students choose a school because they want a higher quality of education. Limiting that education is not fair to the student. 
  2. It will reduce license portability drastically (especially important for military or transient areas and schools close to a bordering state since Maryland, Tennessee, Kentucky, and North Carolina all require 1500 hours and West Virginia requires 1800 hours.). There are only 6 states as low as 1000. Over 40 states are at 1500 or higher. When training hours are not equivalent, most states require proof of work experience or additional school hours to make up the difference. Right now it is fairly easy to transfer to other states since the hours requirement is on par. Dropping to 1000 hours would put Virginia licensees at a disadvantage when attempting to transfer their license.
  3. It limits career options like opening a salon or working in a high-end salon because the likelihood of needing to assist or work for lower wages increases with less training. There is value in education. Removing education will lead to devalued pay and an increase in industry attrition at a time when there is already a workforce shortage. 500 hours can make a huge difference between a graduate working for minimum wage at a chain salon versus starting their career making 35-50% commission. Which one do you think will remain in the industry long-term?
  4. It increases the burden on salon owners to provide education to make up for the missing hands-on training as well as increased cost to fix mistakes from lack of practical experience. Small business owners need graduates who are prepared to work behind the chair immediately. The RAP was not asked what graduates need to be successful, only what is necessary for safety of the general public. However, if a licensed stylist cannot perform a quality cut and color, the industry will see a dramatic increase in attrition, at a time when the industry is in desperate need of more workers due to attrition.
  5. A reduction in hours will not fix the workforce shortage problem or reduce barriers to entry. This profession requires passion, creativity, people skills and long hours on your feet. People don’t enter this profession on a whim. Reducing the program from 11 months to 7 months will not increase the number of people desiring a career in Cosmetology. Less than 1 year is considered short to graduate with a career when most colleges require 4 years.
  6. It will reduce the amount of Pell grant eligibility for students by thousands of dollars, increasing out-of-pocket costs for students by the same amount. Without a change in scope, schools will be unable to lower tuition because they are required to teach the same program in a shorter amount of time, which will increase costs to achieve similar outcomes, especially during a period of soaring inflation.

If, despite the reasons above, the Board continues to move forward with this hour reduction, I urge the Board to consider the following when writing the regulations:

 

  • In order to lower Cosmetology hours to 1000, will there be a reduction in scope of practice? Waxing, nails, skin, and a broad scope of hair services must be taught all in 1000 hours when the barbering program is 1100 with a much lower scope and esthetics is 600 on its own? If no, then will this change the scope of practice for esthetics and barbering? Barbering does not include waxing, nail care, wig care, perming, relaxing, bleaching, or thermal styling. If barbering requires 1100 hours to ensure safety, then the additional of so many chemical services to the cosmetology program, should increase its required training hours, not lower them.
  • Accredited schools should be consulted regarding the time frame for implementation. Updating curriculum and submitting the required documents for such a significant program change to SCHEV, DPOR, the accreditor, and USED all take substantial manpower and time waiting for agencies to approve the new program before moving on to the next step. This can take months to a year. Rushing the timeline for implementation will halt enrollment, which will create barriers to entry rather than eliminate them.
  • Students must be left with the option to choose a program at higher hours to meet their needs. Students should be allowed to decide whether they want more education and hands-on practice in a 1500 hour program, or are content with the bare minimum of training to ensure safety at 1000 hours. Schools must continue to be allowed to offer programs above the minimum state requirement, as is the case now. This is very important and must be written into the language of the new regulations so there is no confusion as to it being allowed.
  • And finally, I urge you to consider adding a Hairstylist license at 1000 hours, rather than lowering Cosmetology hours. This would be in line with many states and would provide options for students without compromising the industry. 
CommentID: 188901
 

10/11/22  3:24 pm
Commenter: Treasure Spinner

Cosmetology hours
 

I support

CommentID: 188972
 

10/11/22  4:21 pm
Commenter: Christina Stocks

DO NOT REDUCE THE COSMETOLOGY HOURS
 

I oppose reducing the cosmetology hours.  I am a former cosmetology instructor and I have seen the benefits of being able to attend school for 1500 hours.  The students get more hands on training, they are not rushed through the basics of their learning and it allows us time to prep them with salon readiness classes.  I am currently in Admissions at a cosmetology school and since the news broke that DPOR would be reviewing the hours for cosmetology, we have had people reaching out wanting to get into school before that reduction.  A question I have also received is if they will be allowed to attend for 1500 hours over a reduced amount of  hours.  I think that speaks volumes!  Not only do our students not want the hours reduced but people wanting to attend cosmetology school are not wanting their education hours reduced.  I greatly oppose the reduction of cosmetology hours in Virginia. 

CommentID: 188998
 

10/12/22  9:54 am
Commenter: Ben Knotts, Americans for Prosperity Virginia

Support
 

AFPVA supports reducing the regulatory barriers inhibiting professionals to earn a living with a skill customers are waiting to trade for. In short, these barriers are largely utilized to keep newcomers from the market who, especially in the cosmetology space, are often practicing on the black market. Lowering the barrier to practice is prudent.

CommentID: 189174
 

10/12/22  12:16 pm
Commenter: Debra Sawyer

Please support lowering the hours to 1000 hours
 

As a salon owner in Virginia, I fully support lowering the hours down to 1,000 hours. Over the last 16 years, I have hired numerous stylists who graduated from the beauty schools with the 1,500 hours and numerous stylists who graduated from our high school tech schools with only a required 840 hours of instruction. I have found no difference between the level of preparedness to be on the floor servicing clients between the two programs. Furthermore, if I had to pick who was better prepared, I would pick the student who graduated from the high school tech school with 840 hours. 

If a high school student can graduate in 840 hours and take their board exams to get their license, why does a student going to a beauty school have to go almost twice as long to qualify to get the same license? We need to let these students graduate and start earning a living and supporting their family. The extra hours are not needed and only lead to bigger student loans that they will have to repay. 

Please vote to support lowering the hours down to 1,000 hours to allow these students to start their career.

Thanks you!

 

CommentID: 189220
 

10/12/22  2:30 pm
Commenter: Daniel Greenberg

Comment in support of proposed rule
 

I am pleased to hear that the education requirements for cosmetologists may be lowered from 1,500 to 1,000 hours, and I write in support of this rule. In my view, the only justification for cosmetology licensing requirements is the advancement of health and safety for laborers and consumers, and 1,000 hours of training is more than enough to advance these policy goals. Any review of the typical curriculum for cosmetology students will demonstrate that a relatively small amount of instruction is devoted to health and safety concerns as such, while a relatively large amount of instruction is devoted to various crafts and practices intended to improve the beauty of the consumer. Ideally, in addition to reducing the number of hours of education required for a cosmetology license, Virginia regulations in this area will emphasize and increase the portion of content in the cosmetology curriculum that focuses on education in health and safety issues and concerns .

CommentID: 189255
 

10/12/22  5:04 pm
Commenter: Riley Smith (SMIHA) Cosmetology Instructor

Education Cosmetology Curriculum Hours
 

My name is Riley Smith and I am a Cosmetology Instructor of SMIHA. I am responding in reference to the upcoming hour changes for a future cosmetology student. 

My thoughts on the change is that it will harm the cosmetology industry more than help it. I teach courses such as Anatomy, Skin Structure, Nail Structure, Facials, and even Nail Curriculum and my experience with students is that they absolutely want the theory part of the curriculum due to helping with understanding the practical portion. It is already difficult now to engage students into doing practical activities if they don't understand the underlying education. For example, when a student is attempting to do a haircut and I reference a bone on the skull to part at, the student doesn't understand what that is if the underlying knowledge is not taught. 

This industry deserves stylists who are more than happy to perform services with confidence but confidence in this industry comes from not only practice but knowing what you're doing. You can only know what you're doing if you understand underlying education and context clues. 

CommentID: 189305
 

10/12/22  5:19 pm
Commenter: Peter Eriks

Keeping Hours
 

      Excellence in effciancy regarding both mental and tactile education is ideal for an industry that opperates apart of everyone's daily lives. The current wake of understanding that the completion time for Cosmetology Licensure/Education is dropping puts into question the quality of disease control, physical safety (regarding implements, service providers physical ergonomic health, and the recepients safety), and mental knowledge (regarding how to comprehend pathogens, understanding the full body so that it can be operated on from a macro and micro scale, additionally the how and why to educate the public so that a higher standard of life can be acheived). The full understanding and application of the current material requires maxium time possible to master and take into hand the physical ramifications of removing the education time yielding the inability of people to fend for themselves as stylists, colorists, educators, and the like providing a down play in an already booming industry to suffer regardless of "quick fix" or "social media" based models. 

Truly, having educated many student and being in the grind of education with them after working abroad for the past several years immediatly demands that education be not only taught but fostered and administered to a motor skill as the industry provides the removal of physical apendiages and the prevention of diseases to spread. This mastery of information further allows a more uniformed and well educated group of industry workers to build up the economy and provide for the local community stretching onto the national level. Removing the how to's, and concrete facts of the body and science of chemistry in which the chemicals (not just hair dye, or bleach) are applied to another being protects a way of allowing this service to be for all. Removing any aspect will add to the detriment of those who will receive services. Having friends in other countries who do hair in an unlicensed portion of the world, it further shows the needs and quality already established so that all can reveive a suscent and quality service at the risk of damaging the mental or phsycial health of those in the community.

CommentID: 189312