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Client Brings a 30% TCA Peel From an Online Seller

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Client Brings a 30% TCA Peel From an Online Seller

A 41-year-old client arrives with an unlabeled amber bottle and a printed online listing that says '30% TCA Chemical Peel - professional strength.' She wants a full-face application for acne scarring and says she will sign any waiver you provide. You are an Ohio-licensed esthetician with two years of experience, working in a salon without a medical director or physician on site. Your scope includes superficial esthetic services, but you have not been trained or authorized to perform medium-depth peels. The client says a friend used the same product at home and 'only peeled for a week.' She has already paid a deposit and is asking you to start within the next 20 minutes.

1. Analyze the scope-of-practice and liability issues. Can the client's waiver make this service acceptable?

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No. A 30% TCA peel is a medium-depth chemical peel that can cause significant injury, infection, scarring, and pigment change. It requires medical judgment about indication, depth, and aftercare that exceeds superficial esthetics. An Ohio esthetician may not expand her scope by having the client sign a waiver. A waiver does not authorize an unsafe or out-of-scope procedure, and it does not transfer the esthetician's professional and legal responsibility to the client. Using an unknown, unlabeled product from an online seller adds product-safety and labeling problems. Performing the service could expose you to Board discipline, civil liability, and loss of insurance coverage.

2. What should you do with the product and the appointment, and how do you explain the refusal?

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Do not apply the product, and do not store it in your treatment room. Return the bottle to the client and explain that you cannot use a product whose strength, labeling, and intended use you cannot verify. Tell her plainly: 'This is a medical-depth peel, and it is outside what I am licensed and trained to do in this setting. I can't apply it safely.' Refund or credit the deposit. Offer a superficial service only if it is within your scope and the client understands it will not treat scarring. Refer her to a dermatologist or physician who can evaluate the scarring and perform or supervise an appropriate peel.

3. What documentation is appropriate, and what should you avoid writing?

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Document the product name and stated concentration, that it was client-supplied and unlabeled, the requested service, and that you refused. Note the refund or credit, the referral, and the client's response. Avoid writing that the product was 'fake' or making a medical judgment about her scars. Do not record that you would perform the peel if a physician were present unless that is actually true and within your training. Keep the record factual and concise. If the client becomes angry, note only observable behavior and any statements she made. Good documentation shows that you protected the client and stayed within Ohio scope rules.