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Regulation Action Plan: Understanding Risk

Susanne Schmaling June 2014 issue of Skin Inc. magazine
Regulation Action Plan: Understanding Risk

Part of being a skin care professional is identifying risks, and knowing how to keep your clients and your team safe. Many professionals may have learned about the importance of risk management while in school; in fact, at times it may have seemed most of the curriculum was built around using scare tactics to get students to follow safety rules. The purpose of this article is not meant to frighten you, but to empower you with information to be used for implementing procedures and gathering information to keep you safe and keep your business productive.

What would you do?

Following is a simple scenario that illustrates just how complicated the subject of safety can be.

A skin care professional is performing a modified Jessner’s peel on a client and is on the second layer when the power goes out in the building. Only half of the treatment is completed, and the Jessner’s solution is open and in a dish. There is no window or other light source in the room, but there are some candles that could be lit, and the client wishes to continue the treatment. What would you do?

If you are like many, you would light the candles and keep going. That is an example of increasing the risk in an already-risky situation, because:

  1. There is no ventilation in the room;
  2. Jessner’s solution can ignite if exposed to a flame;
  3. Without adequate light, the risk of harming the client during the treatment is heightened; and
  4. Introducing fire into the room increases the overall risk—in the worst-case scenario—of something else in the room catching fire and leading to a much worse problem.

These are just some of the risks involved in this situation. It doesn’t mean any or all of these things will happen, but it is a gamble that they won’t—a gamble with unsafe odds. There are insurance claim files filled with examples just like this one, in which one or more of those things really did occur. The skin care profession is not immune to safety issues.

What do you need to know?

Following is an overview of key areas that must be addressed to create a functional risk management plan.

Be educated about every service on the treatment menu. If skin care professionals have not been trained on a modality, they should refrain from performing it. Once trained, they should practice several times on live models, as well as experience the treatment once themselves, before performing it on a paying client. This allows for the professional to have first-hand knowledge of what it’s like to receive the service.

Many professional malpractice claims occur due to mistakes that occur during the service, as well as lack of correct follow-up with the client.

Understand Occupational Safety and Health Administration (OSHA) requirements. OSHA standards are not just for factories and hospitals. There are three key standards that every skin care facility owner must abide by.

1. Hazard communication standard.1 This is the standard that covers your requirement to keep Safety Data Sheets (SDSs)—formerly known as Material Safety Data Sheets—in which information on hazardous chemicals used in the facility are communicated in a 16-section format.2 Independent contractors do not have a good chance of OSHA knocking on their door for an inspection, but it is still important to have SDSs accessible for every product you use.

SDSs provide the possible physical, health and environmental health hazards of your facility, as well as safety precautions for handling, storing and transporting chemical hazards. They also inform about the steps required in case of an emergency.

2. Formaldehyde standard.3 Think of this as the ventilation standard. The focus is formaldehyde and materials that release it. In esthetics, exposure may occur when a treatment room is located near other services that include products that release formaldehyde. The bottom line—having adequate ventilation is an absolute necessity.

Skin care professionals deal with many chemicals every day, even when using natural products. Exposure can be cumulative and, considering estheticians may be in the treatment room an average of 6–8 hours a day, this standard is put into place for their protection.

3. Bloodborne pathogen standard.4 Skin care professionals may also know this standard as “universal precautions.” It was created to protect workers from the transmission of bloodborne diseases. This standard addresses how to dispose of contaminated sharps, procedures for decontamination, types of pathogens, modes of transmission, and proper disposal.

Methicillin-resistant Staphylococcus aureus (MRSA), HIV and other pathogens are more common than you may think. Estheticians and clients can be exposed to them without their knowledge.

Create a risk management plan. A good risk management plan includes electrical and fire safety procedures, first-aid procedures and emergency contact numbers.

The phrase “accidents happen” applies here. Is there a fire extinguisher in the treatment rooms, or one that is easily accessible nearby? What about a first-aid kit? Are there multiple extension cords in the room for equipment that may be overloading circuits? These are all issues that can cause a tremendous amount of damage and may harm your team and your clients.

Create a professional safety tool kit. A tool kit is useful no matter the profession. Some examples of items to include are an extractor tool, nitrile gloves, a Wood’s lamp, disposable lancets and a sharps disposal box.

Stay up-to-date on immunizations. This should be discussed with your physician. Getting immunizations is a personal decision, but one which should be looked at closely, based on your health and public exposure.

The recent H1N1 flu virus pandemic is a good example of how valuable a flu shot can be for some. For a person who is at greater risk due to age or other health conditions, immunizations may be mandatory.

Practice stress-reduction. Reducing stress is important for risk management, because chronic stress decreases the ability to think clearly, among its other health effects. Mistakes are more likely to occur when professionals are exhausted and stressed out.

Carry professional malpractice and general liability insurance. Most professional licenses require you to have malpractice insurance coverage. An esthetic license is one of the exceptions. However, even though coverage is not required by law, it is vitally important. When mistakes happen, insurance coverage protects personal and business assets. For the self-employed, a general liability policy is often required by landlords.

Practice personal safety. Taking basic personal safety precautions can help avoid risky situations. For example, when working late nights alone, lock the front door after the last client arrives—and again once they leave—and let someone know when to expect you home.


Now that you’ve built a foundation of knowledge for risk management, it is time to implement as many safety precautions as possible. Use This Month’s Action Plan to start a risk-management checklist. Check the references below for further information and sign up for Associated Skin Care Professionals’ free webinar “Safe Skin Pro—Understanding and Minimizing Risk,” on June 16 for more information. Register at



(All accessed Apr 4, 2014)


(All accessed Apr 4, 2014)

Susanne Schmaling is the director of education for Associated Skin Care Professionals. A licensed esthetician and experienced instructor with more than 15 years of experience, Schmaling is also a member of the 2014–2015 Skin Inc. Editorial Advisory Board.





This Month's Action Plan: Understanding Risk

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