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STATE OF MICHIGAN  
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS  
BUREAU OF PROFESSIONAL LICENSING  
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PUBLIC HEARING  
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TUESDAY, MAY 2, 2023  
AT ABOUT 9:00 A.M.  
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OTTAWA BUILDING  
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611 W. OTTAWA STREET, UL-5  
LANSING, MICHIGAN  
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RE: Barber Examiners - General Rules  
(MOAHR #2022-29 LR)  
Cosmetology - General Rules  
(MOAHR #2022-19 LR)  
- - -  
17 HEARING FACILITATOR:  
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DENA MARKS  
Bureau of Professional Licensing  
611 W. Ottawa Street  
Lansing, Michigan 48909  
ALSO PRESENT: Kerry Przybylo  
Stephanie Wysack  
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23 REPORTED BY: Lori Anne Penn, CSR-1315  
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I N D E X  
2 Opening Statement - Dena Marks  
3 COMMENTS:  
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PAGE  
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NATASHA LAWSON - Douglas J  
DEMETRIA WILLIAMS - Michigan College of Beauty  
CHRISTINA NEWMAN - Multi Media Makeup Academy  
ASHLYN ALEXANDER  
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THERESE VOEVODSKY - BeauBien Holistic Care  
JESSICA ABFALTER  
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PAUL CHIRCO - Alisa Marie Brows  
DAVID DAGENAIS - Michigan College of Beauty  
SUSAN KOLAR  
NEKEYTA BRUNSON - Uncovered Beauty Studio  
DeANNA HUIZINGA - Grand Pearl Spa  
SYDNEY SHAW  
MEAGAN McCOMBER - The Babe Company  
ERIN DRESSER - Skin Deep Day Spa  
DARYN PACKER - Face Foundrie  
THERESE VOEVODSKY - BeauBien Holistic Care  
JAMIE BURNS  
SUSAN KOLAR  
DARYN PACKER - Face Foundrie  
NICOLE MAYNARD - Skin Deep Day Spa  
JESSICA ABFALTER  
CARLI HOLSTAD  
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I N D E X  
2 Opening Statement - Dena Marks  
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Lansing, Michigan  
Tuesday, May 2, 2023  
At about 9:00 a.m.  
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MR. MacINTOSH: Good morning. My name is  
Dena Marks, and I am a Departmental Specialist in the  
Boards and Committee Section within the Bureau of  
Professional Licensing in the Department of Licensing and  
Regulatory Affairs, and I will be conducting the hearing  
today.  
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This is a public hearing on proposed  
administrative rules entitled "Barbers - General Rules"  
and "Cosmetology - General Rules". We are conducting  
this hearing under the authority of the Administrative  
Procedures Act, Public Act 306 of 1969, on behalf of the  
Department of Licensing and Regulatory Affairs, Bureau of  
Professional Licensing.  
We are calling this hearing to order at  
9:00 a.m. on May the 2nd, 2023, at the Ottawa Building,  
UL-5, 611 West Ottawa Street in Lansing, Michigan.  
Publication of the notice of public hearing was in the  
Flint Journal and the Grand Rapids Press on April 9,  
2023, and the Mining Journal on April 14, 2023. These  
papers are newspapers of general circulation. The  
notices were also published in the Michigan Register,  
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Issue #7-2023, on May 1, 2023.  
We are here today to receive comments on  
the proposed rules. If you wish to speak, please make  
sure you have signed in and indicated you wish to speak.  
You may use the cards provided for this purpose. If you  
would like to speak and have not yet signed in, please do  
so now. For those of you who do not wish to sign in with  
a card, you may speak once we have exhausted all of the  
cards that have been submitted.  
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If you have comments, please make sure  
they relate directly to the proposed rules. If you have  
questions about the rules, please include your questions  
as part of your testimony for the Department's review.  
If you have suggested changes to the proposed rules,  
please include the specific reasons why the changes would  
be in the public interest. Please note, if you have  
already submitted comments to the Department in writing  
or by email, those comments will be considered in the  
same manner as the comments made during the public  
hearing today.  
For those making comments today, please  
clearly state and spell your name for the record; and if  
you are speaking on behalf of an organization, please  
identify that organization as well. So everyone has the  
opportunity to speak, please limit your comments to three  
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to five minutes. If you have additional comments, they  
may be submitted in writing by emailing  
BPL-BoardSupport@Michigan.gov.  
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The Department staff -- I'm sorry, I've  
lost my spot.  
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If you have written comments, you may  
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submit them directly to me. The Department will also  
accept written comments postmarked or emailed until 5:00  
p.m. today.  
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The Department staff from the Bureau of  
Professional Licensing attending today's hearing are  
LeAnn Payne, Kerry Przybylo, Stephanie Wysack, and me.  
At this time, we will begin with comments  
concerning the "Barber - General Rules." Are there any  
comments concerning that rule set? (No response.)  
Seeing none. Then we will now take  
comments on the "Cosmetology - General Rules". And the  
first card I have, is for Natasha Lawson.  
NATASHA LAWSON: That is me. So after  
reviewing the --  
MS. MARKS: Would you please introduce  
yourself and spell your name. Thank you.  
NATASHA LAWSON: Natasha Lawson, and the  
spelling is N-a-t-a-s-h-a L-a-w-s-o-n. I have two main  
concerns with the proposed laws and rules. The first  
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concern, I do see that unassigned hours have been added  
in, however, it is two percent or less than two percent  
of these students' programs. There are many things in my  
14 years of educating that I have found that don't neatly  
fit into any of these curriculum guidelines that are also  
integral to student success. For instance, shadowing at  
a salon, being able to have an experience where they're  
learning about color maybe from a mindset that's not hair  
related. So these things to me are really important. I  
propose that instead of it being two percent of their  
curriculum for all programs, that it is five percent of  
their curriculum for unassigned hours; that would mean  
that cosmetology would get 75 hours and all the 400  
program, 400-hour programs like esthiology, electrology,  
and manicurists would get 20 hours instead of 10.  
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My second concern is the change in  
verbiage around scope of practice for cosmetology and  
esthiology. I was looking through the Regulatory Impact  
Statement, and there is a statement in here that I would  
just like to point out. I disagree with -- so there's a  
piece that says: Do these rules exceed standards in  
other states around the Great Lakes region? I would say  
that these do not correlate with other states around us.  
For instance, Wisconsin specifically says that you can  
utilize microdermabrasion and chemical peel machines as  
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long as you're only exfoliating the upper surface of the  
skin, where the Michigan state law clearly states that  
you cannot use any sort of microderm or product, so  
that's concerning to me. Illinois, they also allow  
cosmetology and estheticians to utilize chemical peels  
and microdermabrasion within a specific scope of  
practice, and they do not have to be under medical  
license or under a doctor. And Ohio as well also allows  
any chemical, mechanical, or electrical service to  
exfoliate cells as long as they're within those first few  
layers of the skin. So I'm proposing that Michigan take  
some time to really look at those other laws and rules of  
the states around the area and really clearly define what  
is within the scope of practice and without the scope of  
practice for an esthetician. So that's it.  
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MS. MARKS: Thank you for your comments.  
For the next person, we have Demetria Williams.  
DEMETRIA WILLIAMS: Demetria Williams,  
D-e-m-e-t-r-i-a, Williams, W-i-l-l-i-a-m-s, and I am here  
on behalf of Michigan College of Beauty. I really just  
want more clarification on the things that it does say  
where it says cosmetologists or estheticians, because a  
lot of things, even as far as the tinting of the eyebrows  
and rearranging of the hair, it does not say a  
esthetician, it still doesn't that say an esthetician can  
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do it. It just basically says, the way I read it, it  
only falls under cosmetologists, so I would like that to  
be clear on the (inaudible) because as far as the law  
goes, only a cosmetologist can change or rearrange  
anything that has to do with hair.  
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Another one of my things that I was going  
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to ask about was the spelling out of anything that has  
had to do, that a esthetician versus a cosmetologist, and  
then in some of the rules making amendments, so they were  
talking about field trips and how that needs to be  
spelled out, like what can we do as a field trip, what  
those guidelines would go, how many hours would be  
allowed for a field trip outside of school and what it  
would entail; like are they allowed to go to another  
state, does the instructor have to be there, what entails  
a field trip?  
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And then another question that we had was  
about the cosmetologists being able to use a razor to  
like shave hair on the face. So can they use a straight  
razor, because I know a razor is big thing as far as a  
blade goes in this portion? That's it.  
MS. MARKS: Thank you so much. And the  
next person is Christina Newman.  
(Multiple speakers, inaudible comments.)  
CHRISTINA NEWMAN: Hi, I'm Christina  
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Newman, C-h-r-i-s-t-i-n-a N-e-w-m-a-n, on behalf of Multi  
Media Makeup Academy. So my comment is regarding  
verbiage, and I was part of the work group meetings that  
took place at the end of last year, and I think we made a  
lot of headway, but there's still some things that I feel  
are unclear regarding some of the proposed changes.  
Under (j) Performing services that are  
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limited to the scope of practice of a licensed healthcare  
profession regulated under 15 of the Public Code, just  
including, but not limited to microdermabrasion,  
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dermaplaning, hydrodermabrasion, Botox injections, it  
looks like we're trying to eliminate unless he or she is  
performing a service that is delegated under the Section  
162 -- 16015 of the Public Health Code. So I've been  
fielding a lot of comments and questions from  
estheticians in the State of Michigan on social media  
since Friday, believe it or not. There's a lot of  
concern that eliminating that sentence makes it so that  
estheticians who are under the guidance of a licensed  
healthcare professional cannot perform some of these  
services. Yes, they should never perform Botox, but by  
lumping that in with something like dermaplaning, which  
is technically removal of the hair with a razor, people  
are going to be able to lose their livelihood, a large  
portion of us. So I think that needs further clarity.  
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And then I had a couple laser hair  
removal techs reach out to me because they see just user  
possess a laser or an ultrasound for any purpose, and  
that needs clarity. If you are working within a  
facility, again, under a licensed healthcare professional  
and you've been properly trained and you're under the  
guidance of them, I don't understand why that would be  
worded like that, so more clarity on that.  
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And then I'm also proposing under (r) Use  
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any color, tint, or chemical preparation on the eyelashes  
or eyebrows of a patron that is intended to last longer  
than six weeks after application, or use any color, tint,  
or chemical preparation on the eyelashes that -- or  
eyebrows of a patron that is not specifically intended  
for that use, I think there's some extra ambiguity there  
by having the or statement in the front of that. You  
could potentially have anybody use any sort of  
demi-permanent hair color on lashes because it lasts less  
than six weeks and it's not necessarily meant for the  
brows and lashes, that needs to be eliminated and it just  
needs to state plainly, use any product that is not  
intended for brows and lashes according to the  
manufacturer's label. And that was it.  
MS. MARKS: Thank you. Ashlyn Alexander.  
ASHLYN ALEXANDER: Hi. My name is Ashlyn  
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Alexander, A-s-h-l-y-n A-l-e-x-a-n-d-e-r. I am a State  
of Michigan esthetician, licensed esthetician. And my  
two biggest concerns would be, first off, I feel like  
this is an attack on women in our livelihood. It's sad  
to be a Michigan woman today. As lots of estheticians,  
most of it, as a woman-dominated industry, we are able to  
provide for ourselves without the help of anyone else by  
providing these services and helping out our public.  
Taking away of lot of these services that we provide  
livelihood for ourselves would put us in a far better or  
worse situation as far as the economy goes and finances  
and taking care of ourselves. We're already dealing with  
a tough situation with the economy right now, and then  
this is going to further push us below. This is not  
helping lift women up today, and that's disheartening to  
have to say right now.  
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So to the State of Michigan, I would  
really want to add two questions. Are you able to  
provide and prepare for that lost income that tens of  
thousands of women are probably going to face when these  
services would be taken away from if that does carry  
through? So I have a question. How would that impact  
our economy?  
And then our biggest thing, too, is that  
we deal with -- the skin is a largest organ, which is a  
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regulatory system; taking away these services that we  
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help people with with this organ, which is our first  
defense to the world, diseases, illnesses, you're taking  
away providers that can help with causes of the public  
health. So that would be my comment. Thank you.  
MS. MARKS: Thank you. Therese, I  
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apologize ahead of time, Vouvodsky.  
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THERESE VOEVODSKY: Hi, I'm Therese  
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Voevodsky, T-h-e-r-e-s-e V-o-e-v-o-d-s-k-y. I represent  
BeauBien Holistic Care in Grand Rapids, Michigan, I'm the  
owner and managing partner. I feel like I was remiss in  
not learning about this until a couple days ago, but  
quite honestly, it totally freaked me out when I read it.  
I spent all day yesterday on it, and I read all of the  
regulations, I read the Regulatory Impact Statement, I  
really tried to understand this. But it looks to me as  
if you are taking away an entire class of services from  
tens of thousands of women in this State, and thousands  
of women-owned businesses are going to go under because  
of this.  
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And I'm getting a little upset because,  
like I said, I just learned about this yesterday. And  
the way that this is written, this even includes -- so  
anything that takes away any layer of skin, that takes  
away exfoliation, peels, it takes away everything.  
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There's no way -- we might as well close up shop, because  
if my estheticians can't even do an exfoliation or a  
peel, we're done.  
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I have four estheticians, two doctors,  
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and a nurse that work for me. The doctors and the nurses  
are not going to want to provide these services, and  
they're not trained in it. So not only will we be taking  
away the livelihood of thousands of women, we'll be  
putting it on doctors and nurses that are already  
overloaded, and essentially no one is going to be able to  
provide these services anymore. They don't know how to  
do this. We'll have more injuries, if there are any, and  
that was my first point in my email that I sent. Show me  
the studies that people are getting injured, that  
Michiganders are getting hurt by training licensed  
professionals providing these services. I just, I don't  
understand it. So you have my written comments.  
MS. MARKS: Thank you for your comments.  
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Jessica Abfalter.  
JESSICA ABFALTER: Hello. My name is  
Jessica Abfalter, spelled J-e-s-s-i-c-a  
A-b-l-f-a-l-t-e-r. First, I'd like to echo all the  
statements that have come before mine. Everything these  
women have said, I completely agree with.  
There are many issues that I have with  
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these proposed changes, including, but not limited to,  
there's contradiction regarding the use of sanitation of  
makeup brushes, vague language, like the word  
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beautifying, elimination of the word chemical from the  
esthiology curriculum, lack of clarity with regards to  
the use of exfoliant products, and lash and brow dye, and  
unnecessary regulation of blades, clippers, and scissors  
that potentially disallow estheticians, barbers, and  
cosmetologists from simple acts like trimming eyebrows or  
cleaning up a neckline. And while those are many issues,  
what I find the most concerning is the transfer of some  
advanced esthetic treatments to the realm of the  
physician, specifically microdermabrasion,  
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hydrodermabrasion, and similar treatments like chemical  
peels.  
Don't misunderstand; I love doctors,  
they're the reason I'm able to be here today, but that  
doesn't change the fact that I can personally attest to  
the fact that adding an M.D. to a spa does not make it  
safer. On the contrary, what I and other colleagues in  
the medical esthetics field have observed is that many  
so-called med spas don't have their doctor on site, and  
even more are operated by physicians who do not  
specialize in anything related to skincare. Even worse,  
some of these doctors do not hire estheticians to do this  
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work. While it may seem logical that requiring medical  
supervision over advanced treatments would improve their  
safety, this rule change does nothing to protect the  
public. Given the chance to choose between a licensed  
esthetician and a medical assistant who was trained on  
the job, I'm going to choose the esthe every single time.  
The policy also takes income from a  
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highly specialized group of professionals and puts it in  
the hands of physicians who already have high earning  
potential, and possess a greater degree of risk to the  
public because of the reasons I have already mentioned.  
Not only that, this rule change takes the  
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power of regulation away from the Board of Cosmetology  
and puts it in the hands of doctors and the Public Health  
Code. We have seen an influx of medical spas and  
doctors' offices offering anti-aging therapies over the  
past 10 to 15 years, and skin rejuvenation technology  
will only continue to grow, so there is no doubt that  
regulatory policy will have to change to keep up.  
Personally, I would like to see the governing body of our  
industry do more to protect our interests than those  
of -- and not those of physicians who already have their  
own representation. Thank you.  
MS. MARKS: Thank you. Paul Chirco.  
PAUL CHIRCO: Hi. Paul Chirco, P-a-u-l  
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C-h-i-r-c-o. I'm here on behalf of Alisa Maria Brows.  
My objection is to paragraph (r), which has a six-week  
limit on a tint, color, or chemical prep on eyebrows and  
eyelashes. The six weeks, in my opinion and many  
opinion, is that this is arbitrary, pulled out of a hat,  
it's not based on any kind of science. By setting this  
arbitrary number, you're subject to constitutional  
standards. A reg can't be arbitrary or capricious.  
Numerous products specific to the eyebrows last 6 to 8  
weeks, can last up to 12 weeks. These products are safe  
and effective. No health professional will perform these  
services because, as was pointed out before, estheticians  
have been doing this service for many years. You're  
potentially taking away the livelihood of hundreds of  
women on a number pulled off of a hat.  
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My question is, what is your objection  
of -- objections -- on what are your objective on this:  
Is it permanency? Is it invasiveness? Is it health and  
safety? None of these apply or are changed by the  
six-week limitation there. I would ask to change this  
limitation to 12 weeks since most of the products that  
are out there, if not all, last less than 12 weeks.  
MS. MARKS: Thank you. David, I'm sorry,  
I'm not even going to try your last name.  
DAVID DAGENAIS: Yes. David Dagenais,  
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spelled D-a-g-e-n-a-i-s. I'm with the Michigan College  
of Beauty, I'm the owner of Michigan College of Beauty in  
Troy, Michigan, it was incorporated in 1973, I'm the  
second generation owner, my son, Drew, is currently being  
trained to be the third generation owner.  
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Michigan College of Beauty has branch  
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campus licenses for approximately 30 years. We currently  
hold four branch campus licenses. In 2018, the  
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cosmetology rules committee started revamping the rules  
that regulated the cosmetology industry. We attended  
these negotiations and were told the statute did not  
allow for the issuance of branch campus licenses. As a  
result, the 2018/19 rules committee agreed to create  
R 338.2127 with language to allow for more than one  
premises, and described the conditions under which the  
existing schools could have not a branch campus, but a  
more than one premises. This was all agreed upon.  
In January 2022, during the school's  
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biannual inspection, the State Board inspector asked me  
if I was planning on renewing my cosmetology branch  
campus licenses, and assured me that she thought it was  
not necessary given the language in the newly amended  
R 338.2127 allowing for more than one premises. In early  
2022, an entirely new rules committee started once again  
revamping the rules pertaining the cosmetology industry.  
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In the spring they decided to eliminate the concept of  
more than one premises because there was no objection to  
removing it and no one on the committee had the frame of  
reference as to why the previous committee had added the  
more than one premises language. The changes to rule  
R 338.2127 will not allow for a school after their branch  
campus license expires to have more than one premises.  
During MCB's summer inspection of  
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August 2022, the inspection notified us that we would not  
be able to use these branch campus facilities after the  
branch campus licenses expired. The news was a complete  
surprise to us as we understood that the concept of more  
than one premises was established and accepted by LARA.  
Upon the news, we began attending each and every new  
rules meeting as we looked into the whole concept of more  
than one premises being removed from the rules. The new  
committee had not -- the new committee, who had not been  
there during the 2018/19 negotiation, had decided with no  
opposition to remove the entire more than one premises  
language.  
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Why does the concept of more than one  
premises need to be reexamined? What would closing four  
out of the five locations that MCB currently operates do  
to jobs, current students, training in the cosmetology  
field, staffing resources for local salon owners who have  
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relied on us for decades, our local economy, and State  
tax revenue? During a time of economic uncertainty, the  
effect would be detrimental.  
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These locations, which are strictly used  
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for extra classroom space, are not part of the student  
clinic floor, are within a quarter mile of our main  
campus, two of them we actually share a common parking  
lot. We often walk back and forth between the facilities  
daily. There is no language in the statute to indicate  
where a cosmetology training needs to be performed as  
long as it's supervised by a licensed instructor  
following the school's curriculum. The elimination of  
more than one premises would restrict the school's  
ability to quickly, inexpensively, and flexibly expand to  
meet the industry ever-changing needs. This would harm  
both salon owners that rely on schools for newly licensed  
staff and the access that future hair stylists have to  
training.  
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Being a small business, and our schools  
are, it is difficult to stay viable as is. Restricting  
the school's ability to quickly respond to changes and  
demands does not make sense and will inevitably be  
detrimental to the industry. MCB does not believe that  
Governor Whitmer's administration would put into  
regulation laws that would seek to stifle growth in the  
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cosmetology industry and to create job loss. This  
regulation implementation would do exactly that and give  
Michiganders one more reason to seek education, careers,  
and opportunities in other states.  
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In closing, we are requesting to maintain  
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the option for more than one premise as presented in  
R 338.2127 Section 10. Thank you.  
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MS. MARKS: Thank you. Susan Kolar.  
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SUSAN KOLAR: My name is Susan Kolar,  
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S-u-s-a-n K-o-l-a-r. I concur with everyone's comments  
so far. I think the saddest thing is this started a long  
time ago. The rules committee that would be open with  
comments that you could give your ideas. Being a  
licensed for special, and as a retired instructor, I  
stayed abreast of everything because I'm just nosy and  
it's my passion. As I've trained -- I've been teaching  
for over 45 years. I was an examiner for the State of  
Michigan. I've worked for three very good schools. And  
I just -- it's our livelihood that we're overthinking the  
statements in these rules that we're taking away the crux  
of what they do. All right.  
I guess I agree that maybe some of these  
need to be under guidance or, you know, directed by a  
medical licensee, I get some of that, I almost agree with  
that, but to the point where we can't do exfoliation,  
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we're limited to six weeks on a tint, we can't do lash  
lifts, which are intended for that use, I think we need  
to simplify some of the work verbiage and be specific on  
other verbiage, such as the field trips. It used to be  
there, and it was fine, everybody was clear, an  
instructor had to be there, you were limited to so many  
hours, and they took it away. I guess that's pretty much  
it in a nutshell. Thank you.  
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MS. MARKS: Thank you. Nekeyta Brunson.  
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NEKEYTA BRUNSON: My name is Nekeyta  
Brunson, N-e-k-e-y-t-a B-r-u-n-s-o-n. I'm a licensed  
esthetician, I own Uncovered Beauty Studio, which is in  
Lansing. Over the past six years, I became a licensed  
esthetician because I help women who are going through  
hair loss, and even when you lose your hair, we all have  
skin. And so I've gone through school, I completed all  
the requirements, I've paid all the monies to have an  
establishment.  
My comment would be on who's enforcing  
these things, because as someone who's gone through these  
last six years and trying to figure out what we can do  
and what we can't do, it was already very difficult to  
figure out. I want to do what's right to have the  
establishment, have it be done right for these women; it  
was already confusing on who to call, who to say what.  
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I'm calling LARA; they don't know. I'm asking them what  
it's in the scope; they don't know.  
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So as we are doing all these different  
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changes with the wording and the verbiage, the other  
thing that us licensed professionals are having issues  
with is social media and those who aren't licensed are  
already doing these things from home or from their  
places, and so who's protecting us when we pay all the  
money to go to school, we're paying all this money for  
these equipments, these licenses, these insurances, and  
we've done all of that, and then social media, people  
from home can, or from different places can just come in  
and do it, they're not doing it right, nobody's  
regulating it, nobody's shutting them down. There are  
places that are not following the rules that you already  
have in place, and they're not getting shut down. So I  
feel like it's just causing more and more trouble.  
I agree with the professionalism, I agree  
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that these things should be more clear, because we do  
take our industry professionally and we are trying to  
help women in a very safe way, women and men, because  
40 percent of my business is men, they'll just come if  
they want to. But either way, like the goals for the  
people who are following the rules is to follow the  
rules, and we want them to be clear, yes, we want them to  
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be safe, yes, we also want to be protected as a  
professional to say if there are people not following  
those rules, we expect for them to have the, the  
repercussions happen, and we're not, we're already not  
seeing that our industry is being protected in that way.  
So as you update the rules, also update like the workers  
who are going to be able to go behind and find out who is  
not following these rules that there are going to be so  
many people trying to now continue to implement into  
their business to figure out how to continue to provide  
for their families.  
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MS. MARKS: Thank you. DeAnna Huizinga.  
DEANNA HUIZINGA: I was in the other  
room. My name is DeAnna Huizinga, D-e-a-n-n-a  
H-u-i-z-i-n-g-a. I'm representing myself, along with my  
coworkers. I work at Grand Pearl Spa in Grand Rapids,  
Michigan. I have been a licensed cosmetologist for over  
30 years now, I've worked at our practice for 26 years.  
The whole reason why I am concerned is I  
work with a group of plastic surgeons. I am a  
cosmetologist, so there are occasions where physicians  
say we work under their medical license, but I'm not  
risking my cosmetology license for anyone. So I worked  
really hard to get where I am, continue education,  
continue going to classes, and I'm not going to have  
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somebody come in and say you can't do that now because  
these rules and regulations are not clear and clarified.  
I agree with everything that everybody  
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has said here, everybody has definitely proved their  
point; but in my case, I look forward to going to work  
every single day, otherwise I wouldn't be there for 26  
years. I am a previous breast cancer survivor, and if it  
wasn't for my coworkers exfoliating my skin and giving me  
facials, I wouldn't have the confidence to come back to  
work. If it wasn't for them exfoliating my breasts after  
radiation, I wouldn't have the confidence to actually  
show people. I'm proud of my breasts now. So for me, to  
have that ability to then do that to someone else, I'm  
proud of that. So for you guys to have that ability to  
take that away from me and my coworkers is really  
disheartening.  
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And how am I supposed to pay my bills if  
you take that away from me? I am in a large amount of  
debt, and now you're going to take this away. I won't be  
able to dermaplane somebody, I won't be able to do a  
hydrofacial, I won't be able to help somebody. That's  
just ludicrous, and I just feel like you are taking such  
a big chunk of benefit away not just from us providers,  
but from people that come in and want to feel better and  
feel good about themselves.  
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So my public comment is you have to make  
the wording more accurate, more specific, and you also  
have to make a difference between medical spas and what's  
at cosmetology locations, hair salons, and schools,  
because there is no clear definition to what you can do  
at a medical spa versus what you can do at a hair salon  
versus what you can do at a medical practice. And if it  
was me, I'd rather have somebody that has 26 years' worth  
of experience treating skin than somebody that was just  
trained as an MA.  
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I mean like they they've always said to  
me, there's somebody that came in last at medical school  
and there's always somebody that barely passed the bar in  
law school; who do you want working on you, the one that  
graduated top of their class or the one that barely  
passed? So that's my public comment.  
MS. MARKS: Thank you.  
DEANNA HUIZINGA: Sorry for being  
emotional.  
MS. MARKS: No problem. Sydney Shaw.  
UNIDENTIFIIED: Congratulations.  
DEANNA HUIZINGA: Thank you.  
SYDNEY SHAW: My name is Sydney Shaw  
S-y-d-n-e-y S-h-a-w. I've been a esthetician for over  
six years now.  
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I'm for these changes in the cosmetology  
setting, but I'm not for these changes within a medical  
setting, especially with the medical team on site. I  
certainly don't agree that Botox should be administered  
by an esthetician or a cosmetologist; that is just  
unethical, in my opinion. We should be able to  
dermaplane and perform these services with blood-borne  
pathogen annual training and certification. I certainly  
believe there should be more regulation on the  
certifications that are required, but we should be able  
to laser, hydrofacial, chemical peel, et cetera, with  
proper certification and training, which the verbiage is  
unclear whether these rules are pertaining to  
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estheticians or cosmetologists. Because as an  
esthetician, our governing board is the Board of  
Cosmetology, it is unclear whether -- who these rules are  
pertaining to exactly, because from my understanding,  
this is essentially limiting people even if they have  
medical oversight.  
So my question is, are you trying to rule  
out these services in salons, because, in my opinion, on  
behalf of the opinion of many others, with medical  
oversight and continued hours of education on these  
services, excluding injections, should be allowed under  
specific circumstances in medical facilities? My biggest  
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concern is clarity on what is pertaining to  
cosmetologists and estheticians, and what services will  
be taken away and what will be continued to be performed  
with direct medical supervision? Thank you.  
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MS. MARKS: Thank you. Meagan McComber.  
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MEAGAN McCOMBER: Sorry, I'm very new to  
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this process. My name is Meagan McComber, M-e-a-g-a-n  
M-c-C-o-m-b-e-r. I'm a licensed esthetician, I'm  
representing The Babe Company, a licensed skincare  
facility.  
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I have spent countless hours that have  
been dedicated to my continuing education and learning  
and making me an expert in my profession of skincare.  
Many of the services in question, such as general  
exfoliation, is extensively covered in esthetic school  
where we also learn to provide proper skin analysis and  
make treatment recommendations, however, I understand  
that many of the services that I offer and provide for my  
clients on a day-to-day basis in my esthetic studio,  
which I own and operate, are not covered in the general  
education required by the State of Michigan to obtain a  
esthetics license, however, I, like many of the other  
estheticians that are concerned about the possibility of  
these new prohibitions to be put into effect have gone  
above and beyond the general requirements. I've spent  
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plenty of time taking -- plenty of time and money taking  
courses and training outside of my general education,  
making me knowledgable and proficient specifically  
regarding dermaplaning, microneedling, chemical peels,  
lash lift and tint, eyebrow laminations and tint,  
hydrodermabrasion, and permanent makeup, dedicating  
myself, just like our license requires us, to be of good  
moral character to provide these services. Many of these  
services people would attempt to provide for themselves  
in their own home settings and will continue to do so,  
especially if we are not permitted to perform them -- for  
them in a professional and regulated setting. Most all  
of the materials required to perform most of the services  
that the State wishes to prohibit are readily available  
for the general public to purchase and not regulated by  
any markets to be sold only to professionals.  
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If I am not permitted to provide the  
services the State wishes to prohibit for my clients any  
longer, my business will most likely fail, as I  
specialize in skin rejuvenation renewal, specifically  
curing acne. If I have to send my clients to a medical  
specialist for what I normally provide for them, they're  
not going to receive the same standard of care. In my  
experience, medical professionals rarely have interest in  
caring, they will more than likely focus only on  
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treatments, many times with temporary results, using  
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extreme or unnecessary force, never caring to find what  
the root cause of the problem is. More than likely,  
medical professionals will also have little to no  
interest providing services that the State wishes to  
prohibit us from providing, which, as I stated earlier,  
will lead clients to perform the services at home  
themselves, which is extremely dangerous.  
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If the State wishes for a higher  
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education regarding the services they wish to prohibit,  
they should make it a part of the curriculum that the  
State requires to obtain an esthetics license. So many  
estheticians will suffer from client loss, as well as  
loss of income, if the State does choose to go ahead with  
these limitations that they wish to put into effect.  
It is my hope as a well-educated  
professional and as somebody who cares deeply about the  
wellbeing of my clients that the State will reconsider  
what they are about to do. Thank you.  
MS. MARKS: Erin Dresser.  
ERIN DRESSER: Hi. My name is name is  
Erin Dresser, D-r-e-s-s-e-r, and I am a licensed  
esthetician and have been in this industry for 23 years,  
I'm also a medical assistant. I own a spa and have owned  
it for 17 years in, and I do have a medical director that  
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oversees our medical supervision.  
So the part that concerns me is the  
prohibition section regarding hydrofacials,  
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microdermabrasions, chemicals peels. I do agree with the  
Botox being only administrated by professionals, however,  
hydroabrasion, microdermabrasion, chemical peels I do not  
think needs medical supervision; most states don't  
require that. I have been licensed in California and in  
Michigan, so I have a lot of experience with that.  
I also have been a medical assistant, and  
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when I first started this career, I worked for plastic  
surgeons and dermatologists and they would delegate  
chemical peels and microdermabrasions to me with no prior  
knowledge of skincare, so when I did obtain licensed  
esthetician, when I did go to school for that, I did  
learn more about that, and I would much rather have a  
licensed esthetician perform those services on me.  
I think that eliminating this and the  
clarification in the rules is very confusing and it, the  
interpretation of it would only be limited to licensed  
physicians and nurses to perform these services. Our  
healthcare system is already overwhelmed, and I don't --  
a lot of the clients and patients that already get this  
care would not be able to get the care as easily as they  
would need.  
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And I think that the delegation part is  
unclear. I see that that's crossed off, so does that  
mean that licensed estheticians will no longer be able to  
be employed by physicians or to perform these services  
over -- under medical supervision? In this case, I think  
that a lot of estheticians would lose their jobs and  
small businesses would have to close their doors.  
I've personally owned my business for 17  
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years, and the majority of the services that we provide  
are dermaplaning and hydroabrasions and chemical peels,  
so if we were not able to provide these services, then it  
would really have an effect on our revenue that comes in  
from these services. I do employ ten people, five of  
them which are estheticians, they're highly trained. I  
think that a better approach would be to require more  
certifications and more education and put this on the  
curriculum for estheticians to require that to obtain a  
license. And I -- if you are going to eliminate this and  
only have medical supervision, I think estheticians  
should be able to perform these services under medical  
supervision. They are invasive treatment -- they are  
non-invasive treatments, and I don't believe that they  
should be taken away from estheticians to perform.  
Also, I think that this would increase  
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unemployment, estheticians losing their jobs, it would  
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decrease sales tax that the State gets from estheticians  
who retail products. A lot of small businesses have  
invested in equipment, and this equipment is very  
expensive, so they would be stuck with this equipment,  
some of them are still paying on loans to pay this  
equipment off, so it would have a very detrimental effect  
on all business owners who have invested in this  
equipment. Would the State be able to provide  
reimbursement for this equipment and this loss?  
So in conclusion, I don't think  
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eliminating the practice of hydrodermabrasion,  
microdermabrasion, and dermaplaning would be something  
that would be a good effect on our State. Thank you.  
MS. MARKS: Thank you. Daryn Parker.  
DARYN PACKER: Hello. My name is Daryn  
Packer, not Erin Parker. I represent Face Foundrie.  
MS. MARKS: Could you spell the last  
name, please?  
DARYN PACKER: Yes. P-a-c-k-e-r.  
MS. MARKS: And is the first name  
D-a-r-y-n?  
DARYN PACKER: Yes.  
MS. MARKS: Okay.  
DARYN PACKER: I represent Face Foundrie,  
a focused facial bar in Birmingham, Michigan. I went to  
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the University of Michigan, I've spent the past six years  
living in Washington, D.C., California, and Colorado. I  
finally found my way back to the place I grew up to help  
my mother start a business. We opened our business, Face  
Foundrie, in December and we were most recently scouting  
our second location last week right here in Lansing, in a  
place where there have been dozens of storefronts that  
have gone vacant as a result of the COVID epidemic.  
After years spent in other frankly progressive places, I  
was always proud to be from Michigan where I felt  
innovation and entrepreneurship were at the cornerstone  
of our culture. These rules place that in jeopardy for  
thousands of independent estheticians and small business  
owners.  
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At Face Foundrie, our primary goal is the  
accessibility and providing quality skincare services to  
women of all skin types and socioeconomic backgrounds.  
We are licensed and insured, we follow the current  
guidelines and the laws that are in place. All of our  
estheticians are licensed, and they receive further  
training from our corporate partners, and each  
esthetician must have had our services before they are  
able to perform them on clients.  
I want to further emphasize how these  
rules changes are not just detrimental to thousands of  
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estheticians who have spent thousands of dollars and  
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hours to learn and perform services to help people feel  
better about themselves, it's also detrimental to  
thousands of clients that estheticians have helped in  
their skincare journeys. Rules like these present  
barriers to access. Not all women need medical-grade  
treatments. There are dozens of processes that are  
already reserved in the medical field. Individuals who  
need those more invasive treatments are usually  
encouraged to do so by their estheticians.  
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So just as a consumer has to choose what  
food they put in their body or how to treat the common  
cold, they should be able to choose their best path for  
skincare treatment and who provides it to them. For some  
that would mean spending thousands of dollars at a  
medi-spa, but for a great deal of others, it's building a  
skincare plan with an esthetician because it's more  
cost-effective and it might work better for their skin.  
These changes will discredit the professionals that have  
spent their careers perfecting these crafts.  
There are bad actors, every person in the  
room I was just in would probably agree. Any respected  
licensed esthetician would tell you they approve of  
enforcing rules that eliminate bad actors. A nursing  
degree or a medical license does not ensure that there  
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will be no bad actors. I think you all know this. I  
hope you all know this.  
I did not come here to only highlight the  
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problems, I would also like to suggest some solutions  
which I think everybody has kind of already highlighted.  
Modify the process, ensure there's more training in  
schools, cover things more thoroughly like dermaplaning,  
ensure that salons and service providers are adhering to  
the current rules. I mean what good are rules if they  
are not enforced. Making more rules does not ensure that  
rules will be enforced. Slapping more rules into the  
system does not change anything, especially if the  
current rules are not being enforced. Quite frankly,  
it's a joke.  
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I just lived in Colorado and I was on a  
town board, so I know what you guys are sitting here  
listening to, but just adding the more and more verbiage  
and more rules to something does not create a solution.  
I ask you today to do what you were chosen to do, defend  
and properly represent the industry, the professionals  
you were chosen to represent, hear all of these concerns  
and don't let these revisions as they stand go through.  
Thank you.  
MS. MARKS: Thank you. Greg Packer.  
Greg Packer. Doesn't look like he's stayed.  
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Are there any other comments at this time  
about either the "Barber - General Rules" or the  
"Cosmetology - General Rules?  
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THERESE VOEVODSKY: I would like to add a  
few more things. I kind of skipped over everything, and  
everyone else was more prepared than I was. Can I add a  
few more things?  
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MS. MARKS: Sure.  
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THERESE VOEVODSKY: Okay. Therese  
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Vouvodsky, again, T-h-e-r-e-s-e V-o-u-v-o-d-s-k-y. I'm  
owner and managing partner of BeauBien Holistic Care in  
Grand Rapids.  
A couple of the things that I forgot to  
mention are, and I'm not trying to be inflammatory here,  
but I'm wondering whether or not you are taking away  
barbers' ability to use a blade, because, to me, barbers  
and estheticians have both really good training in these  
areas. So if we're not taking it away from barbers, we  
should not be taking it away from estheticians. This is  
institutional, and, again, I'm not trying to be  
inflammatory, this is institutional sexism. If barbers  
can use blades, estheticians should be able to use  
blades.  
A couple of things that other people said  
that I want to highlight again are this is just going to  
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38  
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cause more people to go underground and unlicensed people  
to be providing these services. The honest people will  
follow the rules and go out of business; dishonest people  
will continue to provide these services.  
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And lastly, in your Regulatory Impact  
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Statement, Item No. 32: Explain how these proposed rules  
will impact business growth and job creation (or  
elimination) in Michigan. The rules are not expected to  
have an impact on business growth, job creation, or job  
elimination in Michigan. That's ridiculous. This is  
going to have a huge impact. So that statement needs to  
be redone, and there needs to be a lot more impact  
studies or something to go beyond this. I don't think  
that there was enough research or analysis put into this.  
That's it. Thank you.  
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MS. MARKS: Thank you. Are there any  
other comments at this time about either the Barber Rules  
or the Cosmetology Rules?  
JAMIE BURNS: I do have a quick comment,  
if I could?  
MS. MARKS: Certainly. Can you introduce  
yourself and spell your name, please?  
JAMIE BURNS: Is Jamie Burns, J-a-m-i-e  
B-u-r-n-s. I'm an instructor for a small school out of  
northern Michigan, we are very brand new.  
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