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The Expired License and the Exam Candidate

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The Expired License and the Exam Candidate

Two workers at a braiding salon are in trouble. Kim's natural hair styling license expired 60 days ago; she has continued taking clients because the owner said renewal is automatic. Andre has completed 280 of the required 300 course hours and wants to take the licensing exam next week and start earning money by shampooing and braiding under Kim's supervision. The salon's ad says "licensed and insured braiders" and lists Kim. A client asks for a copy of Kim's license before booking. The owner wants Andre to "practice on paying clients" because the exam is "just a formality." Kim has not completed any continuing education this cycle, and Andre has not applied for the exam or paid the fee. Both want to know what they may legally do this week.

1. May Kim continue performing natural hair styling services while her license is expired?

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No. A natural hair styling license must be active to perform licensed services on paying clients. Renewal is not automatic, even if the owner says so. Kim must stop performing services, submit the renewal application and required fee, complete any continuing education required for the cycle, and wait until the license is active again. Working on an expired license is unlicensed practice and exposes Kim, the salon, and the client to risk. The client's request for a copy of the license should be answered honestly; Kim should not display an expired credential as current.

2. May Andre take the exam next week and practice on paying clients in the meantime?

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Andre has 280 of the required 300 course hours, so he is not yet eligible to sit for the licensing exam. He must complete the remaining hours and submit the exam application and fee; the exam is not a formality. He also may not practice on paying clients in the salon. A student may perform services only in an approved school setting under the required supervision, not as an employee or independent contractor earning money. The owner's plan would be unlicensed practice by Andre and aiding unlicensed practice by the salon.

3. Kim offers to "supervise" Andre so the salon can keep booking clients. Does that solve the problem?

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No. A licensed natural hair stylist cannot delegate licensed acts to an unlicensed person as a substitute for that person holding a license. Supervision in the salon does not convert Andre's work into lawful practice if the law requires a license for the service. The ad claiming "licensed and insured braiders" would also be false as to Andre. Kim should correct the owner, refuse to supervise unlicensed paying work, and protect her own renewal. Andre should finish his hours and apply through the proper examination process. If the salon continues, both should expect licensing consequences.