Consumers expect that people licensed to perform cosmetology-related services have had actual hands-on experience performing the services they are offering. Without hands-on training, consumers are more likely to be harmed.

Most beauty schools in Utah have service sheets that outline how many hands-on repetitions students should complete for each type of service. However, there is inconsistency in these service counts between schools, and the required counts are not always targeted to public safety. For example, it is possible that a cosmetology student would be required to perform 200 haircuts, which is likely more than is necessary for them to learn to give a haircut safely, while not being required to perform any eyelash extension removals, a relatively risky service that could seriously harm someone’s eye. Consumers are not well served when the service counts are lopsided in this way.

To address this concern, we are recommending that the state establish minimum practice service amounts for each service type. This will ensure that students are getting the right amount of training based on the risk of consumer harm of different services. Overall required hours for each license will be built on these minimum practice service counts as well as classroom hours needed to prepare students to practice safely.

Current cosmetology licenses contain significant overlap in scopes of practice. This can reduce transparency for consumers as they decide where to go for services. For example, there are currently four licenses that qualify someone to do laser hair removal under various forms of supervision. However, it is unlikely that a basic esthetician is getting the same amount of training on laser hair removal as an electrologist. Such information is not clearly conveyed to a consumer by the current licensing structure.

To address this issue, we are recommending a new licensing structure that reduces scope overlap and creates ‘endorsements’–approval to practice a narrow set of services–to give consumers clearer information. The new hair design license will be focused on hair-related services, while the master esthetics license will be focused on skin-related services. The only point of overlap between the two will be eyebrow and eyelash services. In addition, with endorsements such as facial and body hair removal, licensees will get targeted training in a specific subset of services, and consumers will be better able to understand what a person is allowed and trained to do safely.

The current licensing structure requires those wanting to practice a narrow set of services (e.g., waxing) to be trained and licensed in a broad set of services (e.g., esthetics). This wastes time and money for such students. For example, for a person who wants to offer only waxing services, the current licensing structure requires a 600-hour basic esthetics license which covers many services besides hair removal. They would be required to spend time and money learning how to perform services they may have no intention of using in their career. At the same time, they are not guaranteed to get extensive training on waxing.

OPLR proposes grouping related services into “endorsements” that will allow Utahns to begin safely performing the services they want to as quickly and affordably as possible. The scope of practice for both the hair design and master esthetics licenses would be broken down into narrow “endorsements.”

For example, the skills of haircutting and shaving within the hair design license will be grouped into a “barber endorsement”. If a person only wants to be licensed in those skills, they can get a hair specialist license with a barber endorsement. The same will be done with the skin-related services. If, for example, a person wants to perform waxing services, they can get a skincare specialist license with an endorsement in face and body hair removal. This will allow individuals who only want to practice a subset of services to avoid spending time being trained on services they have no intention of using in their profession.

For those who want the broader training and scope of practice, the full licenses of Hair Design (hair), and Master Esthetics (skin) would be available.

The new structure gives the student or licensee the choice, rather than the State making the choice.

OPLR’s review found that a significant number of complaints to DOPL within cosmetology were related to apprentice supervisors and instructors. The following recommendations are intended to address the quality of instruction and consistency between the two pathways.

a. Apprenticeships

OPLR is recommending that the state limit the number of apprentices that a supervisor can contract with to two at a time. This ensures that students taking the apprenticeship path get quality instruction time with their supervisor.

OPLR is recommending that apprenticeships be available for each endorsement and for the remaining full licenses under the proposed licensing structure.

Currently, the apprenticeship path requires more hours than the school path for each license type. We are recommending that required school hours and required apprenticeship be equal.

OPLR is also recommending that the state allow apprenticeship hours to be transferred toward school hours.

b. Instructors

OPLR is recommending that the required on-the-job instructor training time be increased and standardized across all cosmetology licenses. This will help elevate teaching within the profession, leading to more confident and competent practitioners. It also puts Utah more in line with the training required by other states where instructors typically have two to three years of work experience or six months of instructor training.

Based on multiple conversations with the Utah System of Higher Education and private training institutions, the proposed full licenses of Hair Design and Master Esthetics should be eligible for federal financial aid, including Pell grants. This is based on the required hours.

Endorsements will likely not be eligible given that the required hours could be less than the threshold. Note that this is how the current system works as well where some licenses (e.g., Cosmetologist/Barber) are eligible, and other licenses (e.g., Nail Technician) are not.

Endorsements are optional: for students and for schools. They can choose the full license or one or more endorsements over time. The objective is to give all participants in the market more flexibility and options to choose a training and licensing path that is most affordable and effective for what they want to do.

Getting a single endorsement is likely to cost less than the out-of-pocket cost of the current full license at a private training program–even after Pell grants. For students who want to practice in a narrower set of services, the endorsement path provides that option, potentially at a lower out-of-pocket cost.

It is also likely that the training for all of the endorsements separately would cost more than pursuing the full license outright, so for those who want the full scope of practice, the full license would be a better choice.

Required hours are made up of theory and safety hours, plus practical hours defined by minimum service counts per service, plus a buffer. OPLR first estimated the risk to consumers of each service based on surveys and focus groups with licensees, then assigned a minimum required service count for each service based on consumer risk (more for higher risk, fewer for lower risk). The service counts were informed by practical training standards in the medical field. Service counts, multiplied by the standard time required to complete the service, gives the total practical hours required for the license. Then theory and safety hours are added, plus a buffer, to arrive at the total hour requirement for a license.

Current licensees will transition into the new licensing structure beginning in 2027. During the 2027 renewal cycle, licensees will be asked to attest to which full licenses and endorsements they have received training for and are equipped to practice. The state will then transition licensees into the new licensing structure. Phasing out the old licensing structure will avoid confusion among licensees and consumers regarding what a practitioner is licensed to do. Those living out of state and maintaining a current Utah license will also be required to transition during the 2027 renewal cycle.

Portability was actively considered during the review. Cosmetology licensing rules vary state-by-state and most states have established ways to accept licensing from other states. This commonly rests on how similar the scope of practice and training requirements are between the state where the person was originally licensed and the state they are moving to.

The new master esthetics license will be portable to almost every state. It has a larger scope of practice than most other states’ esthetic licenses, and the required hours will likely be more than the average esthetics license hour requirements nationwide. Similarly, the proposed hair design license has scope of practice that would be equal to or greater than other states’ hair design, though hours may be lower.

Someone wanting to receive a cosmetology license in another state will likely need to get the hair design license plus the nail technician license and the skincare specialist license with a face and body hair removal endorsement (the typical areas that make up ‘cosmetology’ in many other states).

OPLR has proposed adding language to allow Utah licensees with this combination to use the title ‘cosmetologist’, which could aid in portability with other states. However, each state handles license portability differently, so if you believe you may want to move, please contact the licensing body in your new state as early as possible to understand the process and requirements.

While the required training hours would decrease for many of the cosmetology-related licenses, the minimum hands-on training requirement will serve to target those remaining hours more precisely to consumer safety. This will ensure that the hours are filled with more hands-on training covering all relevant services. Similarly, some topics less related to consumer safety will likely be removed from the curriculum. In this way, licensees get trained quicker while maintaining or improving safety for consumers.

Licensing requirements should be separate from educational programming. Beauty schools may choose to offer additional ‘add-on’ training programs and certifications separate and beyond basic training required for licensure. Students can choose to stop with the training required for licensure or to pursue additional education beyond what is required for licensure. Employers can choose to require training beyond licensure and/or to provide additional on-the-job training. Consumers can choose what level of quality they want in cosmetic services and what they are willing to pay.

In this sense, under the recommended licensing structure, cosmetology would operate more like other industries, where the market determines what level of education and quality meet consumer needs.

While it is common for beauty schools in the state to develop their own minimum practical service requirements, the current system results in significant variation in actual hands-on training students receive. First, there can be a wide discrepancy in what is required between schools for a particular service. Second, there is also wide variation in the number of services students actually do while in school because the service counts are guidelines, and not currently required by the state. Some students may get many fewer repetitions in a service than the service count guidelines. Lastly, the current service count guidelines in schools may not be focused on consumer safety. For example, some cosmetology related students may be asked to do over 100 haircuts, which is a relatively low-risk service, and will not be required to do any eyelash extensions, a relatively high-risk service. It is in the best interest of consumers for every student/licensee to receive a similar amount of practical, hands-on training for each service type that is dependent on the risk of harm to the consumer from that service.

No, the legislature has not voted on these changes yet. The bill will be debated and voted on during the 2025 Legislative Session, which begins in January.

It’s important to note that changes can be made to the bill by legislators throughout this process.

Those doing apprenticeships will be under the same hour and minimum service count requirements as those attending schools. An apprenticeship supervisor will be responsible for ensuring that apprentices perform all required services and both the supervisor and student must attest that they have completed all requirements.

Apprenticeships can be offered for any of the endorsements and for the full licenses. Apprenticeship supervisors for endorsements can either be licensed with that specific endorsement or with the full license that includes the scope of that endorsement.

The hours required for apprenticeships will be equal to the hours required for schooling and will be built up using minimum service counts, theory/safety hours, and a buffer.

No, hair and skincare specialist licenses with endorsements will not be required. They are simply another licensing option. For those who want a full license, the hair design and master esthetics licenses will be available. These full licenses will likely be a better option for those who aren’t sure which services they want to provide or who want a broad scope of practice. However, for those who know they want to offer a few specific services or who don’t have the time or money to invest into a full license, the hair specialist or skincare specialist licenses with endorsements may be the right fit.

OPLR understands that these recommendations could be disruptive for beauty schools. However, it may not be as burdensome as some fear for a few reasons. First, schools can choose which programs to offer. They don’t have to offer any hair specialist or skincare specialist endorsements or they can choose to offer only a few. They can package endorsements in ways that make sense for their students.

Second, OPLR is recommending that the law be changed to allow school programs to either be accredited or have their curriculum approved by the Utah Division of Professional Licensing (DOPL), whereas currently the only avenue for approval is through accreditation. For schools offering endorsements, it will likely be more efficient to get programs approved by DOPL.