Cosmetology Licensing Review

The Office of Professional Licensure Review was established to review Utah’s occupation licensing laws and make recommendations for their improvement. The office evaluates licensing laws according to legislatively-mandated criteria that include public safety and financial well-being, economic opportunity and burdens to entry, and consumer access to services.

As part of the office’s 2024 review, OPLR has been reviewing the licensing laws for cosmetology and related professions. Throughout the year, the office has engaged in extensive research through stakeholder interviews, school site visits, surveys of current licensees, a study of available related literature, and a review of the regulations in other states.

OPLR had four main objectives in the review of cosmetology licensing policies:

Maintain and/or improve consumer safety
Decrease student/licensee burden (time and money)
Increase student flexibility and choice
Increase transparency for consumers

As a result of this research, the office has identified several problems with current cosmetology licensing policies and has settled on recommendations to address them. More information regarding these recommendations can be found below.

Recommendations
FAQ
Past Presentations
Stakeholder Engagement
What’s Next?

Recommendations

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 more narrow-scope licenses (micro-licenses) to give consumers clearer information. The new cosmetology license will be focused on hair-related services, while the master esthetics license will be more focused on skin. The only point of overlap between the two will be eyebrow and eyelash services. In addition, with more micro-licenses such as the facial and body hair removal license, 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 narrow licenses (‘micro-licenses’) that will allow Utahns to begin safely performing the services they want to as quickly and affordably as possible. Utah already has some narrow-scope licenses, such as the nail technician license and the eyelash/eyebrow technician license. This recommendation would be an expansion of this idea. With a micro-license structure, a person who wants to offer waxing services would only have to get a face and body hair removal micro-license, which will likely be much less than the 600 hours currently required for a basic esthetics license.They will no longer be required to spend time and money learning services they don’t want to offer. For those who want the broader training and scope of practice, the full licenses of Cosmetologist (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 micro-license and for both of the remaining traditional 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 hours be equal.

We are 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.

FAQs

Based on multiple conversations with the Utah System of Higher Education, the proposed full licenses of Cosmetologist and Master Esthetics should be eligible for federal financial aid, including Pell grants. This is based on the required hours. Licenses with required hours above the threshold required by the federal Department of Education are eligible.

Micro-licenses 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.

Micro-licenses are optional: for students and for schools. They can choose the full, ‘bundled’ license, or one or more micro-licenses 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. It is likely that getting the education for all of the micro-licenses would cost more than pursuing the ‘bundled’ license outright. If students feel they want the whole scope of practice, getting one of the traditional licenses will likely be the right choice. For students who want to practice in a narrower set of services, the micro-license provides that option.

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 micro-licenses, along with the cosmetology and master esthetician licenses, 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.

Someone holding the new cosmetology license will likely need to add the nail technician and the face and body hair removal micro-licenses in order to port their license to another state. 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.

Cosmetology licensing varies state-by-state. Most states, including Utah, currently have some micro-licenses (e.g., Barber, Nail Tech). While Utah would be the first state to fully embrace the micro-license idea, other states have some narrow scope licenses. For example, three states (NY, VA, and WV) have a wax technician license ranging in training hours from 75 to 125, and Georgia has a cosmetic laser practitioner license.

A few states (AK, MN, OR) have state-required minimum practical service counts.

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 micro-licenses and for the full, traditional licenses. Apprenticeship supervisors for micro-licenses can either be licensed with that specific micro-license or with the full license that includes the scope of that micro-license.

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, micro-licenses will not be required. They are simply another licensing option. For those who want a broader-scope license, the cosmetology and master esthetics licenses will still be available. These traditional 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, micro-licenses may be the right fit.

OPLR understands that these recommendations would 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 micro-license programs or they can choose to offer only a few. They can package micro-licenses 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 micro-licenses, it will likely be cheaper and faster to get programs approved by DOPL.

Past Presentations

Stakeholder Engagement

7 meetings with private beauty schools
7 meetings with public schools representatives
3 site visits
Surveyed all 56,000+ licensees, received responses from 5,200+
Talked with 35+ students in focus groups
Engaged with 50+ licensees in focus groups
Held an information webinar attended by over 400 licensees

What’s Next?

Business and Labor Committee - Wednesday, November 20th, 1:15 pm - Senate Building Room 120
- There will be time allotted for public comment before they vote.
- NOTE: The vote in this meeting is NOT the final vote on this bill.
- Legislators may continue to change, update, and amend the bill until final vote during the legislative session.

Legislative Session - January 21st - March 7th, 2025