Scope of Practice and Delegation at a New Salon
Your esthetician license is current, and you have just been hired at a new six-station salon in Ridgeland that opens Friday. The owner, Dana, is a cosmetologist. The front-desk hire, Kelsey, has no license. On Thursday afternoon, Dana asks you to do three things: perform a 'medical-grade 30% TCA peel' on a client who had a lighter peel at a dermatology office six weeks ago; let Kelsey apply brow tint and lash extensions because 'it's basically makeup'; and skip covering the hard-wax pot and reuse one spatula for the rest of the day to save time. You also see that the only hand-washing sink is in the restroom and that there is no covered waste container at the wax station. Dana says the Board 'never visits new salons.'
1. How should you respond to Dana's request that you perform the 30% TCA peel, and how do you determine whether a service is within Mississippi esthetician scope?
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I would decline the 30% TCA peel and explain the reason without arguing in front of the client. Scope is not set by what the salon owns or by what a client requests; it is set by Mississippi statute and Board rule. Estheticians generally provide cosmetic care - cleansing, superficial exfoliation, makeup, hair removal, and similar services - while medium-depth chemical peeling with TCA at 30% is a medical service that can cause scarring and requires physician oversight. Before accepting any new service, I would check four things: the Board's current scope rule, the manufacturer's directions and training requirements, whether the service is intended to treat disease, and my professional liability coverage. If a superficial peel is permitted and appropriate, I could offer that, but not the 30% TCA. I would document the refusal, the reason, and the referral to the dermatology office in the client's record, and ask Dana to put her request in writing so the boundary is clear.
2. Can Kelsey apply brow tint and lash extensions under your supervision? Explain the legal and practical issues.
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No. Kelsey cannot perform brow tinting or lash extensions under my supervision. A license is held by an individual and cannot be loaned or delegated; supervision does not make an unlicensed act legal. Brow tinting uses chemical dye near the eye, and lash extensions involve adhesive, isolation, and potential eye injury - both are regulated services in Mississippi and require the appropriate license. Kelsey may handle reception, scheduling, retail, laundry, and cleaning of non-critical surfaces, but not services on a client's skin or lashes. I would explain this to Dana privately, document my objection, and ask her to confirm the instruction in writing. If she still insists, I would not participate, and I would consider reporting the situation to the Board. The salon's insurance may also exclude unlicensed services, which puts everyone at risk.
3. List the sanitation deficiencies you observed and the specific corrections you would make before opening. Explain the risk of each.
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- Uncovered wax pot and a shared spatula. Hard wax is not sterile after use; re-dipping can transfer blood, skin cells, and organisms. Correct by using a new spatula for each client, never re-dipping, covering the pot, and discarding wax contaminated by blood.
- No covered waste container at the wax station. Soiled gloves, tissues, and single-use items must go into a lined, covered container; blood-contaminated waste needs the proper biohazard stream.
- Sink only in the restroom. Board rules require an accessible hand-washing sink in the service area; staff cannot wash hands between clients without leaving the treatment room.
- Earlier bleeding incident. That was an exposure; tools should have been removed, the area cleaned, and implements disinfected with an EPA-registered hospital disinfectant. Before opening I would correct each item, set up a disinfection log, and walk the salon as if an inspector were due. Opening with these gaps teaches the whole team that speed matters more than safety.