Pennsylvania House Bill 2575 seeks to exempt niche beauty services from licensure requirements in Pennsylvania. ASCP and AHP have serious concerns with this bill because the consequences of deregulating eyelash extensions pose serious public safety repercussions. We discuss why we oppose the bill in our letter to the bill sponsors and committee members below.
May 20, 2022
TO: Representatives Aaron Bernstine, David Rowe, Dawn Keefer, Francis Xavier Ryan, James Cox Jr., Joseph Hamm, Mike Jones, Robert W. Kauffman, Seth Grove, Tina L. Pickett, David Hickernell, Frank Burns, Wendi Thomas, Joe Emrick, Lynda Culver, Gary Day, Mindy Fee, Keith Gillespie, Aaron Kaufer, John Lawrence, Zachary Mako, Tom Mehaffie, Steven Mentzer, Michael Peifer, Todd Polinchock, Curtis Sonney, Donna Bullock, Danilo Burgos, Manuel Guzman, Bridget Kosierowski, Anita Kulik, Brandon Markosek, Kyle Mullins, Peter Schweyer, and Dan Williams.
RE: Opposition to House Bill 2575
VIA EMAIL
Associated Skin Care Professionals (ASCP) and Associated Hair Professionals (AHP) provide professional liability insurance, business resources, professional publications, and legislative and regulatory advocacy for nearly 41,700 members nationwide, with almost 900 members in Pennsylvania.
ASCP and AHP are responding to House Bill 2575 (HB 2575), which seeks to exempt niche beauty services from licensure requirements in Pennsylvania. We have serious concerns with this bill because the consequences of deregulating eyelash extensions pose serious public safety repercussions.
HB 2575 creates a new definition for eyelash extensions and characterizes the service as “distinct from the practice of cosmetology and esthetics,” essentially creating a carve-out and deregulating eyelash extensions. This concerns ASCP and AHP because deregulating eyelash extensions creates tremendous public health and safety risks. Eyelash extension application is much more in-depth than gluing on strip lashes. One eyelash extension appointment is a painstaking two-hour process during which a trained professional adheres individual false lashes onto the natural lashes lash by lash. Are lash extensions safe? Absolutely—when the service is performed properly by a trained and licensed professional. ASCP and AHP intend to discuss the safety risks associated with lash extensions below.
Eyelids are delicate, and an allergic reaction, irritation, or other injury in or around the eye area can easily occur to a client in the hands of an untrained individual. For example, the untrained individual may not know the ingredients of the glue they’ve selected—is it nail glue? Does it contain formaldehyde? If an untrained person does happen to choose an appropriate glue, they must still be concerned with causing serious infection or swelling of the eyelid, infection of the cornea, temporary eyelash loss, and cross contamination of parasites to the lash line. Being educated and understanding necessary sanitation procedures are paramount when working so closely to the eye. Untrained individuals may even cause eye irritation directly from contamination in the lash room: Reusable tools such as tweezers must be disinfected, nonreusable tools such as lash wands must be disposed of after each client, and all workstation surfaces must be properly sanitized after each client.
While safety and sanitation standards must be upheld, it is also important to know which candidates are suitable for eyelash extensions before a lash service even begins. A trained professional knows to turn away consumers who have alopecia, are undergoing chemotherapy/radiation, or have an inflamed or irritated eye.
Finally, it is necessary to discuss liability concerns because deregulating eyelash extensions may put untrained individuals performing eyelash extension services at financial risk should they harm a client. Unfortunately, as detailed above, there are plenty of opportunities to injure a client if one is not suitably educated.
In conclusion, ASCP and AHP cannot support deregulating eyelash extensions and strongly oppose HB 2575 unless this is removed or safety protocols are put in place, as the threat to public health is much too high. We firmly suggest you reconsider the implications of deregulating a specialized service that requires specialized training. It is a disservice to the public and consumer safety to allow this service to be performed by uneducated, inexperienced, and unqualified individuals. Eyelash extensions require a large knowledge base of infection control procedures to ensure cross contamination is avoided and infectious diseases are not transmitted. Less regulation could create further problems down the road because unlicensed individuals and their establishments, under this bill, will be exempt from sanitation and health regulations enforced by licensing boards.
Thank you for considering our opinions. Please contact ASCP and AHP Government Relations Director Laura Embleton at laura@ascpskincare.com or by phone at 303-679-7645 if you have comments or questions.
Sincerely,
Laura B. Embleton, Government Relations Director
Associated Skin Care Professionals
Associated Hair Professionals
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