| Action | Board for Barbers and Cosmetology Schools Amendment (Licensure of Piercing Schools and Revisions to School Standards) |
| Stage | NOIRA |
| Comment Period | Ends 10/7/2026 |
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My name is Janett Rivera. I am a licensed nail tech. I have recently been licensed for 2 years.
I am writing to respectfully express my concerns regarding regulations that prohibit licensed nail professionals from using an electric file (e-file) on the natural nail.
As a professional nail technician, I fully support regulations that prioritize client safety, sanitation, proper education, and the protection of the natural nail. However, I believe that a complete prohibition on the use of an e-file on the natural nail may not fully recognize the importance of professional education, proper technique, and the appropriate use of professional equipment.
With comprehensive education and proper training in natural nail anatomy, e-file safety, appropriate bits, pressure, speed (RPM), and technique, a licensed nail professional can use an e-file in a controlled and responsible manner. The potential for damage is often related to improper use, inadequate training, excessive pressure, inappropriate bits, or incorrect RPM settings—not simply to the use of the tool itself.
Rather than prohibiting the use of e-files on the natural nail entirely, I respectfully encourage the Board to consider regulations that establish clear standards for competency and safe use. This could include specific educational requirements addressing e-file operation, appropriate bit selection, safe RPM ranges, pressure and technique, contraindications, and the preservation of the natural nail.
I believe that providing licensed professionals with proper education and clearly defined safety standards would better serve both nail professionals and the public. It would allow professionals to use modern tools responsibly while maintaining the high standards of safety and consumer protection expected within the cosmetology industry.
I respectfully ask the Virginia Board of Cosmetology to consider a regulatory approach that emphasizes education, competency, and safe professional practice rather than an outright prohibition of e-file use on the natural nail.
Thank you for your time, consideration, and continued commitment to protecting the public while supporting the advancement of the professional nail industry.
Respectfully,
Janett Rivera Licensed Nail Professional