Policy No. 06-01
The Board of Registration of Electrologists voted at its August 18, 2006 meeting to adopt the following policy guidelines. These policy guidelines are intended as a recommended protocol for the profession to follow. The Board utilizes these and other guidelines as an internal management tool in formulating decisions that relate to the Electrology industry.
To provide guidance to licensed electrologists who also provide laser hair removal services.
Policy: LASER HAIR REMOVAL DOES NOT FALL WITHIN THE SCOPE OF AN ELECTROLOGIST'S LICENSE. ACCORDINGLY, LICENSED ELECTROLOGISTS WHO PERFORM LASER HAIR REMOVAL SERVICES MUST DO SO IN AN AREA SEPARATE AND DISTINCT FROM THEIR ELECTROLYSIS TREATMENT ROOM.
Electrolysis is "the method of removing hair from the human body by the application of an electrical current to the hair-papilla by means of a needle or any other instrument or device to cause decomposition, coagulation or dehydration of the hair papilla and thus permanently remove the hair." G.L. c. 112, 87EEE. Laser hair removal procedures do not involve the "application of an electrical current to the hair-papilla" and therefore do not constitute "Electrolysis" as defined by the statute. Accordingly, laser hair removal services do not fall within the scope of an individual's license to practice Electrology. ( Nurses, aestheticians, and cosmetologists are not authorized to perform electrolysis in the Commonwealth, unless they hold a valid electrology license).
Although laser hair removal does not fall within the scope of an electrology license, the Board recognizes that licensed electrologists are specifically trained in histology and hair structure, basic dermatology, physiology, and bacteriology, sterilization and hygiene. It is in the public interest that the licensed electrologist be able to offer the consumer an informed and objective choice of which hair removal/reduction procedure is individually appropriate.
A Massachusetts licensed electrologist who meets all state and federal requirements to provide laser hair removal and is insured to provide laser hair removal services to the public may do so, provided they keep their Electrology practice separate and distinct from the laser hair removal services. Each service is a separate entity and the electrologist is expected to follow certain guidelines:
- Laser hair removal services can be performed only in an area separate and distinct from the licensee's Electrology office. To be separate and distinct, there must be a full wall dividing the two areas and a sign informing customers that the practice of laser hair removal only is being performed in that specific treatment room. The door in such room shall be closed during laser hair removal services. The electrologist must fully disclose to the customer, by posting a wall sign in the room or on the door, a statement that laser hair removal services are not regulated by the State Board of Electrology.
- A licensee cannot portray him/herself as a "licensed electrologist" while performing laser hair removal services. This means that the licensee shall not post his or her Electrology license in the laser hair removal treatment area of their business or refer to their Electrology qualifications while performing, promoting or advertising laser hair removal services.
- To avoid misleading consumers, the price list for Electrology services should be separate and distinct from the price list for laser hair removal services.
- It is recommended that a formal training course in laser hair removal and safety precautions with a certificate of completion be posted in the laser hair removal treatment room in view of the consumer.
- Directory, newspaper and all other advertising for laser hair removal services must be kept separate from advertisements of Electrology services. Any directory advertising for each service has a designated area. Electrolysis has a designated heading that falls in the "Electrolysis" section and "Laser Hair Removal" has a designated heading such as hair removing or laser hair removal. The two together are not to be combined in one advertisement.
Regulation by other agencies:
The Board of Registration in Medicine regulates the practice of medicine and has opined that laser hair removal constitutes the practice of medicine. Please refer to its website at www.massmedboard.org for information on procedures that it regulates as the practice of medicine and other requirements.
The Department of Public Health, Division of Health Care Quality, regulates the operation of medical clinics and has issued a policy on Medical Spa Services. Please refer to its website at www.mass.gov/dph/dhcq for further information.