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Can You Survive a Spa Inspection?

By: Regina M. Tucker
Posted: May 1, 2013, from the May 2013 issue of Skin Inc. magazine.

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Although it is important to understand the inspectors’ role, it is equally important to understand what they are not looking for. An inspector is not there to investigate personal matters, such as child support, outstanding parking tickets, or any other personal legal issues you or your employees may be facing. Nor does an inspection mean that clients have filed complaints. State boards receive many complaints, which range from unlicensed individuals employed in a spa to bad chemical peels; unsanitary conditions, to dissatisfaction with the spa’s return policies. It’s determined on a case-by-case basis whether an investigation is required. It is possible when the state board receives numerous complaints on a licensee or particular spa that an inspection might follow. However, it is more likely that the visit is simply routine.

What the inspection involves

Upon arrival, inspectors will let you know they are from the state board and are there to conduct an inspection. Inspectors should always have proper identification. You don’t have to drop everything that you are doing; continue to work on your clients while the inspection is being performed. Inspectors may ask to see valid picture identification to verify the employees or technicians working are licensed. To ensure the spa has its proper authorization, they may ask for relevant business licenses and employee licenses. They will ask to see the manager or licensed employee responsible for unlocking cupboards, doors or drawers within the spa for inspection.

Inspectors also will verify that estheticians are working within the scope of practice for which they are licensed. An esthetician’s scope of practice may vary from state to state, but an individual should always work within the boundaries of their license. (Editor’s note: To ensure you are practicing within your scope of practice, contact your state board. Complete contact information for all 50 state boards can be found at Some states have established different types of licenses that allow estheticians to expand their scope of practice. For example, The District of Columbia Barber and Cosmetology Board offers a two-tier esthetics license: a basic esthetician license and a master esthetician license. The master license allows for a wider scope of practice. Master licensees are able to provide premium services, such as microdermabrasion and advanced chemical peels. If your spa offers laser treatments, Botox, teeth whitening and permanent makeup, be sure your estheticians are appropriately licensed to conduct such treatments. These are the types of issues the inspector will be on the lookout for.

The report

After inspecting the spa, checking for licenses, reviewing proper sanitation practices and ensuring all spa employees are performing duties within their scope of practice, the inspector will likely review an inspection report with the manager and with any individual licensees found to be in violation of their licensing terms. According to the California State Board of Barbering and Cosmetology website, common violations include: incorrect storage of disinfected and soiled nonelectrical instruments, improper disposal of nondisinfectable instruments, and improper labeling of liquids, creams, powders and cosmetics. Examples of individual violations include: failure to have a license, having an expired license and providing services for which an individual is not licensed to provide. For a detailed list of common violations and expectations in your state, contact your state board of cosmetology; complete contact information for all 50 state boards can be found at The process for reporting citations also varies by state.

Some states, such as Ohio, issue citations immediately. Fines, however, are often assessed later by the respective boards of cosmetology. In other states, such as California, a copy of the report will be provided, but the citation with fines will be mailed to your spa after a review. If you do not agree with a citation, you have the right to appeal. In most cases after an appeal request is made, an informal hearing will be scheduled. During the hearing, you will have the opportunity to discuss your case. You may bring appropriate legal representation, witnesses, written documentation or photos to support your case. Also, remember that life is not over if you receive a citation; the most important thing is correcting the violation. If clients inquire about a citation or violation, be honest and share what you did to correct it. Consider it a learning experience for you and your staff, not the kiss of death for your spa. Your team members don’t have to jump ship, and you don’t have to close your spa doors due to minor infractions.

Be prepared