The Expired Establishment License and the Plasma Pen
A newly licensed esthetician has been working three weeks at a small salon. The owner mentions that the establishment license expired 10 days ago and that the renewal is 'in the mail.' The receptionist books a client requesting a lash lift, brow tint, and a 'plasma pen eye lift.' The esthetician completed a manufacturer's lash-lift class and a brow-tinting class; she has never used a plasma pen. The owner bought the device online and says, 'It's just a wand-cosmetologists do it all the time.' A coworker who holds a cosmetology license offers to run the plasma pen on the client while the esthetician watches. The individual esthetician license is current and posted.
1. May the esthetician perform each of the three requested services? Explain your reasoning for each.
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Lash lift and brow tint: generally within esthetician scope when the esthetician is trained, uses products according to manufacturer directions, performs a patch test where required, and stays on the hair and skin surface. Confirm insurance and Board guidance if a product is new.
Plasma pen: no. A plasma pen delivers an electrical arc that creates controlled thermal injury-a burn-to the skin. That is a medical-type procedure, not a cosmetic esthetic service, and it is outside both esthetician and cosmetologist scope in California. The fact that it was bought online and that 'cosmetologists do it' does not make it legal. The esthetician should decline the service and explain the scope issue to the client.
Do not 'just watch' or assist: assisting is still participation. The client should be referred to a physician or licensed medical provider for any skin-tightening procedure.
2. What should the esthetician do about the expired establishment license?
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An individual license does not authorize practicing in an establishment without a current establishment license. The owner is responsible for the establishment license, but the esthetician's own license is at risk if she performs services there.
Steps: (1) ask to see the current license; (2) verify status on the Board's website rather than relying on 'it's in the mail'; (3) tell the owner in writing that you cannot perform services until the license is current; (4) reschedule or move clients; (5) document dates and communications.
If the owner insists, the esthetician should refuse. Unlicensed establishment operation can lead to citations, fines, and license discipline, and it may void liability insurance.
3. How should the esthetician respond to the coworker who offers to run the plasma pen?
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Do not participate. The coworker's cosmetology license does not add plasma-pen scope; the procedure is outside both licenses. The esthetician should not book, prepare the client, apply numbing cream, or 'supervise.' She should tell the coworker and owner what she knows about scope and document the conversation.
If the salon continues, she should decline involvement and consider reporting to the Board; at minimum, she should not let her license or name be connected to the service. Client safety and the esthetician's own license come before salon politics.