The Responsible Reopening of Cosmetology Services

The cosmetology facility requires operational safeguards similar to most other services opening to the public, with the notable exceptions of consistent but controllable human touching.

This is the most sensitive situation for avoiding risk.

Unlike a retail service, the stylist will be occupationally exposed to a number of clients through daily touching. The client will be touched only by the singular provider of services. Both stylist and client can be safeguarded.

The challenge is to selectively introduce general hygiene practices for the clients and employees while focusing on making certain that only sanitized hands touch a client.

Currently, state, and in some cases local, regulations are evolving about providing haircare cosmetology services during the pandemic. These must be followed precisely. If regulatory directives differ from our recommendations, the regulatory authority guidelines must be prioritized.

Safeguards for staff, cosmetologists, and clients should be introduced, but our understanding of the present pandemic is rapidly evolving. How we address safeguards for COVID-19 and haircare may also evolve. Therefore,
we hope you will consider an ongoing relationship with our nonprofit organization, which has a 47-year history of providing public health guidelines in areas of risk.

We will review three areas of salon operations:
I. Client and Facility Hygiene
II. Haircare Service Safeguards
III. Special Concerns for Cosmetology Services

I. Client and Facility Hygiene

There have been many questions, approaches, and uncertainties around how salon facilities should be managed during this unprecedented pandemic.

We felt it made sense to seek advice from physician/immunologists who had successfully established controls for medical clinics during the pandemic. There are similarities in providing salon services and medical clinic protocols which have proved effective.

A major concern for clinics, as it would be for salons, was the safety of the occupationally exposed service provider. For them it was the physician and nurse who provided direct service; for you it is the stylist who physically touches many clients throughout the day. There also were concerns for support staff, although they have substantially less direct client contact. In both medical and haircare facilities there is a fundamental concern for the patient’s and client’s safety.

The objectives for both patients and clients is to strive to safeguard them while providing a minimally disruptive pandemic-sensitive service. We found medical clinic protective practices, by and large, compatible with
preferred approaches for salons.

The following are clinical related communications and
guidelines that should be considered by salons. All communications should be positive, projecting concern for the well-being of the client and, while explaining changes, assuring a professional and supportive experience. The client should be informed, typically by email and occasionally by phone, prior to their appointment that they should expect and to follow these requirements:

• They should bring a facemask or understand that one will be provided. They will be expected to wear a cloth facemask throughout their presence within the facility. Under some conditions they may be asked to wear a surgical or N95 mask.

• They should wait in their car until shortly before their appointment and potentially telephone the clinic from their car before they enter.

• Their body temperature will be taken with a remote thermometer to assure their health and safety and the safety of others. If they run a temperature of 100.4 or greater (some states have mandated other thresholds), they would not be able to receive service. They should be told that if they have a fever or other compromising health issues they should reschedule their appointment.

• They should provide specific assurances that they do not suffer from symptoms associated with COVID-19 or have been exposed to someone who recently had or appeared to have those symptoms.

• As they enter the facility they may be asked to wash their hands using soap and warm water — remembering to focus on scrubbing their thumbs and the backs of their hands. They may be asked to apply hand sanitizers in addition to or in lieu of washing their hands.

• They should bring their own reading material which should not be shared or left behind.

• They will be expected to follow recommended hygiene etiquette involving distancing from others, use of wipes or elbow if they cough or sneeze, even though they will be wearing masks, and observe and follow posted guidelines.

• They will have been provided pre-appointment information, have information available in brochure form, and as they enter the facility they will pass by a posting describing expectations for the conduct and acknowledging the reality of potential risk. It will be made clear that while there is always a risk of exposure, serious efforts have been undertaken to protect and safeguard them.

If that information is made clear through multiple communication mediums, there should be no need for them to sign an assumption of risk indemnification form. We will later comment in more detail on the legal aspects of indemnification for the cosmetologist/salon and provide model
communications for clients.

• All communications should make the point that changes in operations have been designed to protect them as well as staff. Messages should show confidence and be crafted to put them at ease while acknowledging unavoidable risk.

• Waiting area seating should be adjusted to assure distancing and specialized posting should welcome return to service, describe changes and promote hygiene etiquette. Tissue wipes and hand sanitizing material should be available. Special posting should be placed in restrooms assuring
hygiene. We will provide model postings suitable for cosmetology facilities and restrooms.

• For responding to questions and accepting payments, a masked and gloved staff person behind a somewhat protected, perhaps Plexiglas, counter will respond to questions, oversee the waiting areas, provide necessary client
information, and accept payments. Payments can be passed to the staff person and the salon can consider a sign politely requesting that clients use a credit card if possible. The card processing machine may be placed where the staff person would not touch money or the credit card. They would be asked to use their own pen if a signature is required, or the used pen would be wiped down. There is substantial research documenting that both metallic change and paper currency can transmit a virus. A gloved hand and/or frequent use of hand sanitizer and cleansing is important for those providing receptionist services. They could also oversee the display and sale of products in a manner that discourages the clients touching products before purchase.

In discussing the protocols for the clinics that followed many of the above guidelines, we were informed there had been no detected serious violation of protocol or criticisms regarding the experience. The accepted perspective was that the patient/client envisioned themselves as collaborating with the provider in terms of safely, “getting the job done.” We are hopeful for similar attitudes among salon clients.

One point that struck us as we toured the enhanced pandemic-sensitive clinic settings was that there had been considerable attention paid to the décor, including sensitive lighting, themed artwork, quality posters on hygiene, and always facial photographs of the staff and providers.

In discussing this with the facility managers and managing immunologist they pointed out that since patients/clients were accustomed to seeing
smiling, confident faces, which were now masked, they felt it would be comforting to show genuine unmasked staff faces, typically smiling. That is a reasonable consideration for the salons.

Regarding cleaning protocols, we suggest the facility be thoroughly cleaned in the evening, including wiping down with sanitized wipes of all touchable, impervious surfaces. The facility could be divided into several areas defined by the probability of contamination. The workstations would be cleaned after each use. The common-use areas such as reception areas would be wiped down often during the day depending on traffic. Other more remote areas, such as windowsills and storage areas, would be cleaned only in the evening or during a twice-weekly deep cleaning. During the day there would be more aggressive wipe-downs of often-touched surfaces such as doorknobs, railings, handheld remote controls, etc.

Restrooms should post a list of preferred user behaviors including wiping down all touched surfaces, washing hands with warm water and soap, including the back of hands and scrubbing the thumb. The client would be advised to use a readily available paper towel to touch all surfaces following hand washing. This would include the toilet lever, the faucet,
and the handle of the exit door. The disposal for the paper towel would be outside the door. Throughout the day, depending on usage, staff would wipe down the restroom.

Significantly, at the end of each day, a senior staff person should sign and archive a document indicating that the above practices had been substantially followed. The record would also note any specific concerns or unique occurrences, such as a staff member or potential client having an elevated body temperature. We will provide a template for this process which is important for maintaining supporting legal indemnification. We will discuss this in more depth in commenting on legal liability.

II. Haircare Service Safeguards
(universal precautions/hairdryer/disposable gloves)

A concept in public health called “universal precautions,” essentially means that even if a person seems almost immune from a disease, a standardized hygienic protocol should maintained. In this case, it applies to the stylist. Testing the stylist should be prioritized, and even if the stylist is found free
from COVID-19, the same safeguards and protocol must be maintained. Given both the unsteady interpretations of different testing policies and the importance of clear and consistent protocols, this concept is extremely important.

We reviewed optimal protocols suggested by Beauty Service Industry Regulators (BSIR) with a doctor of immunology and industrial hygienists with extensive experience with workplace safeguards and sanitation. We also met and interacted with a number of salon managers and stylists. We are guardedly convinced that if some basic rules of hygiene are followed,
the potential for toxic exposure is extremely unlikely. However, a guarantee of perfect safety is unrealistic.

Assuming both the stylist and client are masked, the stylist’s hands are the dominant, almost singular, factor with the capacity to cause contamination. If the hands are hygienically washed with soap and warm water and potentially the client’s hair is also professionally washed, as long as hand-face or any other direct hand contact is avoided by the stylists, any risk would be improbable.

To the extent N95 masks are available, they would provide an extra measure of precaution for the occupationally exposed stylist. However, in all cases both the client and the stylist should be masked and sensitive to covering their face over the masks with a wipe or elbow if coughing or sneezing.

Whether or not the client should be required to have their hair washed, presumably by the stylist before the haircare service, would be a decision for the salon or the stylist. It would provide an extra measure of safety for the stylist. However, as long as the stylist’s hands are sanitized and after touching the client and nothing else that was not subsequently wiped down, contamination would be improbable. We would recommend the stylist washing the client’s hair.

The use of rubber disposable gloves would not be necessary. These gloves are designed to protect from blood-borne pathogens, not viruses. There is a line of thought that the use of gloves represents a risk in that there are conscious or potentially unconscious assumptions that the gloves equate with inherent sanitation. The gloves are just as dangerous as an ungloved hand once they connect with viral contamination and should not be considered any safer than a hand. The impaired loss of the sense of touch in a gloved hand also may prevent the realization of inadvertent spreading of contaminants.

If the client feels more comfortable with the stylist using gloves, as long as there is recognition that a gloved hand is not necessarily sanitized, a gloved hand could be used.

If the stylist or other staff use hand sanitizers frequently, a moisturizing lotion should also be used at the end of the day to avoid rash.

III. Special Concerns for the Cosmetology Organization

Over the last few months we’ve collaborated with professionals from medicine, immunology, epidemiology, and industrial hygiene, but most significantly we met with many practicing stylists/barbers/cosmetologists. Their honest input and concerns for their colleagues and clients were invaluable in determining our recommendations for reopening salons.If we have created something of value much of it relates to their support.

Haircare professionals should be back in business and thriving — but we also want them safe. Our understanding of COVID-19 is likely to be enhanced and it’s probable that some aspects of our recommendations for best practices may change. Flexibility in operations for reopened salons may be especially important in the coming months.

We would like to share several general suggestions, some stronger than others, and several relevant observations.

Hygienic Cleaning of Work-Exposed Textiles
We think it may make sense to bundle client exposed fabrics, and of course, cloth face masks, at the end of each working day and launder them separately using mild bleach. There is no published data supporting this, but in a pandemic it seems simply wrong to take clothing that has been exposed to a number of people throughout the day and batch them with family laundry. The protocol used in most dental offices and all medical clinics requires segregation and often professional laundering of fabrics exposed to a number of people. If there is no in-house washing machine, it seems logical that a designated person may take home a bundle of work-exposed fabrics and launder them in a separate load, preferably using bleach.

Refreshments and Condiments
There are established pandemic-sensitive commercial rules for making refreshments and condiments available. They involve making sure cookies, pastries, and candies are wrapped separately and beverages are individualized or drawn from a no-touch container, such as a coffeemaker that does not require touch. The Hamilton Beach Brew Station is inexpensive, and coffee can be obtained simply by pushing a paper cup against a release bar. It seems to us that offering a cup of coffee or some condiment to take out to a car or for a client while waiting in the reception area would contribute toward projecting an important sense of comfort and normality. We see no risk of contamination if some simple hygiene rules are followed. Consider the emotions of the client who has been consistently informed that the human touch of others and even frequenting places of business may be inherently dangerous. Offering a positive social sharing of food or beverages could be a signal of care and return to normality.

Ambient Air Quality
We do not believe it is necessary for a heating and ventilation review or professional air balancing in reopening a salon. However, it is possible that as we learn more about COVID-19, more findings may emerge supporting certain optimal standards of air exchange, relative humidity, and temperature.

Some published data suggests that increased air exchange will reduce the persistence of some viruses, but there is no published data regarding COVID-19. There are concepts suggesting that somewhat warmer temperatures and increased humidity may enhance immune systems. There is no published data supporting connections to temperature or humidity and COVID-19.

Facility managers should strive for comfortable ambient air, a bit on the warm side, perhaps 71°F, and a sensitivity to fresh air. Technically, thresholds of 6 to 12 turnovers per hour of ambient air have been recommended as comfortable levels for salons. Similarly, humidity burdens for salons involve suggested levels, ranging between 40% and 60%. These are not regulatory standards.

While comfort is important, these are not high priority imperatives, and there is no documentation relative to COVID-19. We may discover that ambient air controls are significant. Research is progressing and may become important.

Regulatory and Civil Law
For many decades we have worked with public health policy in areas of exposure and risk. When there are clearly serious health consequences involved in preventable exposures, civil litigation can quickly become a reality.

We contracted with a major law firm in the practice of health policy and civil litigation and requested an opinion regarding evolving legal liability as related to regulatory and civil damages for salons. We will summarize their findings here. However, we felt the potential of civil action against salons significant enough, so we have also attached the actual legal opinion focusing on the liability of salons relative to providing service during the COVID-19 pandemic.

In summary, there are three important legal issues upon which salon management should focus relative to potential civil action:

1) Regulatory Guidelines
Absolutely follow all state and any county/parish or municipal regulations regarding health and safety. Violating regulatory guidelines not only may impact licensing and give rise to other regulatory sanctions but will significantly enhance the potential for civil liability.

2) Document Good Faith Service
Following regulatory and responsible public health guidelines is not enough. You must document and archive that you have conducted your services professionally and responsibly. You must preserve documentation to support knowledgeable and good faith conduct.

We can provide a draft form for recording responsible practices. Essentially, one of the employees at the end of the day signs a dated statement that the salon has complied with health and safety guidelines.

3) Responsiveness to New Findings Involving Safe Practices
You must maintain awareness of current health and safety issues relating to your services and provide information and/or training to employees on new health- and safety-related issues.

Projecting a Hygiene Focused Image

For at least a century haircare providers have followed clear and evolving rules on hygiene practices. State licensing authorities have typically been responsible for providing guidance to assure specific sanitation oriented practices. Yet, stylists often kept their hygienic practices out of the line
of vision of the clients. Now with salon staff wearing masks, hygiene etiquette constantly being discussed and promoted in the media, the relationship between public health and responsible salon operations should be acknowledged and displayed. Given the prominence of pandemic concern, a salon’s commitment to hygiene and safety will be comforting to clients.

Clients will be grateful for reconnecting with salon services, but there also will be a subtle concern for their safety. The responsive 21st-century pandemic-sensitive salon will benefit from defining itself as safety and hygiene focused.

July 6, 2020