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Q: Permanent Hair Removal ( Answered 5 out of 5 stars,   5 Comments )
Question  
Subject: Permanent Hair Removal
Category: Health > Beauty
Asked by: whippur1-ga
List Price: $20.00
Posted: 13 May 2004 10:31 PDT
Expires: 12 Jun 2004 10:31 PDT
Question ID: 345858
Some research was previously done on this site (Page 6 - Hair Removal)
which indicated:

"(Please note, there are thousands of 'Beauty Salons' offering laser hair
removal treatment, in the areas you mentioned.  I have omitted these
in favor of individuals/organizations who appear to have professional
medical qualifications in the area of hair removal)"

I am specifically interested in 1) knowing what 'beauty salons' use
IPL or  Intense Pulsed Light laser devices for their permanent hair
removal.  Also, I would like to know 2) how to access a database of
those beauty salons.

It was my understanding this technology needed to be provided under a
physician's direction and I would like to know 3) if you can identify
something official that says this is NOT the case and that Intense
Pulsed Light can legally be provided by non-licensed skin care or
beauty salon employees in the United States.

A quick response would be greatly appreciated.  Thank you!

Request for Question Clarification by nenna-ga on 13 May 2004 13:49 PDT
In reference to your numbered questions.... 

1. There is no possible way to list ALL salons in the US.  Is there a
specific geographical area you would like us to focus on, or say, X
number of salons? Something like that?

2. We can also reference you to the URL's of these salons, but it is
very unlikely there is a list readily available for you of all of
them. As much as both customers and researchers' alike would love a
database filled with "ALL ________" we still do not have one, as
things change all the time. Would referencing the URL's of the salon's
we list for you be fine?

3. Laws for licensing in cosmetology, etc. vary from state to state.
It's not federal law that regulates estheticians most times. Is there
(a) specific state(s) you are looking for as well?

The more details and communication we have, the better answer I or
another researcher can provide for you.

Nenna-GA
Google Answers Researcher

Clarification of Question by whippur1-ga on 13 May 2004 15:38 PDT
I apologize as I am a first time user of this fabulous service so I am
feeling my way a bit.

Let's focus on beauty salons (or non physician directed facilities) in
the State of California or if that is too broad, Southern California
(Santa Barbara South to San Diego).  Referencing the URL would be
fine.

Again, I am especially interested in only those who are using the
Intense Pulsed Light Laser of which there are several manufacturers.

Also was glad to hear from thx1138 regarding the original research.  

I would be interested in any other information regarding state laws on
the use of IPL for California, New York and Florida.

Let me know if you need further clarification. Thank you!

Request for Question Clarification by nenna-ga on 13 May 2004 21:00 PDT
Nope, that's just what one of us needs to get started. Thank you and
I'm glad you decided to try out this service. Hopefully I or one of
the other reseachers will be able to provide you with information in a
timely manner.

Nenna-GA

Clarification of Question by whippur1-ga on 16 May 2004 00:22 PDT
Can someone tell me if progress is being made on this question?  Thank you...

Request for Question Clarification by nenna-ga on 17 May 2004 09:06 PDT
whippur1,

Hello again, I've got some info for you that I wanted to talk to you
about before I answered your question. You state you would like beauty
salons that offer the IPL. However, according the the California
Bureau of Barbering & Cosmetology, a esthetician can not offer this
service. It may only be done by a Physicaian, RN, or Phys assistant.
Therefore,  can not offer you salons that offer this service. I can
however, offer you spas with medical professionals and other offices
that offer this treatment.

Since we now know the peramaters, would you be ok with a list of
places (that can legally offer IPL, so, NO salons) in So. California
that offer the IPL, and also the information stating why a lisenced
Physician, Phys. Assistant or RN has to perform the proceedure? Please
let me know....

Nenna-GA
Google Answers Researcher

Clarification of Question by whippur1-ga on 17 May 2004 10:54 PDT
Thanks Nenna-GA.  This is very helpful.

Can you tell me the location of your excerpt (a particular page on the
web link provided?)

It is helpful to know that beauty salons CANNOT offer this service.
Yes, I would appreciate a list of Medical Spas and others who can
offer this service in Southern California.

I am thinking it would most likely include Plastic Surgeons,
Dermatologists and Medical Spas directed by Physicians and am
interested in your thoughts and what you come up with.

Looking forward to hearing further as I have a meeting tomorrow afternoon. 
Thanks for the good work!
Answer  
Subject: Re: Permanent Hair Removal
Answered By: nenna-ga on 17 May 2004 13:07 PDT
Rated:5 out of 5 stars
 
Whippur1,

I found out the licensing information from the California State Board
of Barbering and Cosmetology

Article 21, section 991 states
991. Invasive Procedures
(a) No licensee may perform any act which affects the structure or
function of living tissue of the face or body. Any such act shall be
considered an invasive procedure.
(b) Invasive procedures include, but are not limited to, the following:
(1) Application of electricity which contracts the muscle.
(2) Application of topical lotions, creams, or other substances which
affect living tissue.
(3) Penetration of the skin by metal needles, except electrolysis needles.
(4) Abrasion of the skin below the non-living, epidermal layers.
(5) Removal of skin by means of a razor-edged instrument.
NOTE: Authority cited: Sections 7312, Business and Professions Code.
Reference: Sections 7312(e), 7316, 7320, 7320.1, Business and
Professions Code.
http://www.barbercosmo.ca.gov/laws/index.htm
http://www.barbercosmo.ca.gov/laws/art12.htm#991

Since the hair follicle the IPL is treating goes into that portion of
your skin, it is considered an invasive procedure and therefore a
cosmetologist or esthetician cannot operate this machine.

This is reinforced in the Consumer Guide put out by the Board, pg 23 of 28

?Laser hair removal is a popular technique currently being advertised.
However, it is illegal for any Bureau licensee to perform this service. The
equipment used to perform laser hair removal is classified as a ?medical
device? by the FDA, and use of these machines is considered the practice of
medicine. Laser hair removal may be performed only by a physician or by a
registered nurse or a physician?s assistant who is working directly with a
physician.?
http://www.barbercosmo.ca.gov/formspubs/barbcosm.pdf

You are correct in who would provide this service since a salon
couldn?t unless it has a licensed Physician, Physician Assistant, or a
RN.

?Intense Pulse Light is designed to be operated only by personnel
properly trained in its handling and use. This may include physicians,
nurses, technical staff, or other professional staff members.
In-service training for the Intense Pulse Light is provided by a
professional technical/instructor. These procedures are highly
technique dependent, and it is strongly recommended that you do not
attempt to do these procedures without adequate training. At the end
of this in-service training, personnel are considered trained only for
the Intense Pulse Light.?
http://www.skincarepro.com/training_IPLoverview.htm


Here are some places in So. California who offer the IPL

http://www.hairlasers.com/california.php
http://www.laser-hair-removal-information.com/hair_removal/california_all.php
http://www.advancedlaserclinics.com/
http://www.totaldermatology.com/pages/laserhairremov.html
http://www.bareskinmedspa.com/sevices.asp#IPL
http://www.experienceblue.com/contact.html
http://www.spa415.com/home/
http://www.ultimatephotorejuvenation.com/

Some of those are providers? websites, some are lists of providers.
You should find about 20 in total there.

If this answer requires further explanation, please request
clarification before rating it, and I'll be happy to look into this
further.
Nenna-GA
Google Answers Researcher

Request for Answer Clarification by whippur1-ga on 17 May 2004 20:28 PDT
Thanks Nenna ga -

I am not meaning to split hairs (pun intended) but I am wondering if
there is a document from the FDA that specifically states intense
pulsed light devices are considered "medical devices" and must be used
under a physician.

You also mentioned CA DOES consider IPL a laser treatment.  Can you
provide me the site that makes that statement?

Technically IPL is not a laser and is a non-invasive procedure so it
could technically NOT be included in Article 21, Section 991.

The other quote discusses Laser Hair Removal is illegal for any Bureau
licensee to perform ... but doesn't specifically state "IPL" Laser
Hair Removal.

Sorry to be a pain, but I need to split hairs on this for a reason. 
If you can add anything more specific on IPL, it would be much
appreciated.

Thank you!

Clarification of Answer by nenna-ga on 18 May 2004 15:17 PDT
whippur1,

I contacted the California Bureau of Barbering & Cosmetology by
telephone today, and spoke with an employee named (name withheld due
to request) and I asked her your questions you posed to me in the
clarification. I wanted to make sure I had interpreted everything
correctly, and get some definitive reasons from the horse's mouth.

The reason for the refusal to allow IPL to be done by a cosmetologist
or esthetician is because of the invasive procedures rules I stated
before. IPL is technically not a laser, you are correct; I misspoke
when I said they considered it a laser.
However, since laser and IPL both use light and heat to remove hair by
destroying the hair follicle. Both of which affects the structure or
function of living tissue of the face or body. Therefore, the IPL is
considered a medical device under CA law, the same as a laser machine
is.

Because the IPL generates intense pulsed light that safely disables
hair follicles to impair growth without damaging the surrounding skin,
it violates this rule:

*** No licensee may perform any act which affects the structure or
function of living tissue of the face or body. Any such act shall be
considered an invasive procedure.***

Since the hair follicle is no longer living after the IPL treatment is
performed, it falls into the rule mentioned above, even though it is
not a laser treatment. In addition, both an IPL treatment and a laser
treatment both use light pulses and heat.

"Light pulses are delivered through a rectangular crystal which acts
as a light guide. The light is converted to heat when it is absorbed
by the melanin in the hair follicle."

It's not the FDA calling it a "medical device" it's California's
policy/law determined by the California State Board of Barbering and
Cosmetology.

I hope this clears things up and explains why. The California State
Board of Barbering and Cosmetology also stated if you had any further
questions about IPL, you could call them for additional information.
The number is 1-800-952-5210.

I?m glad I could get the details ironed out for you.

Nenna-GA

Request for Answer Clarification by whippur1-ga on 22 May 2004 10:23 PDT
Nenna-ga:  BRAVO!  I apologize I have been off line as my schedule
went off the chart for a few days.  I was on my way to a meeting
regarding this subject and had to return to my office for something I
had forgotten and fortuitously saw your last bit of information from
your phone call to the California State Board.  It was a much
appreciated clarification and arrived just in time.   Thank you for a
great effort!  I am happy to provide a 5 star rating... and look
forward to using Google Answers again.

Clarification of Answer by nenna-ga on 22 May 2004 15:50 PDT
Thank you very much. Just to let you know, everytime one of us writes
in the "clarify" section, it keeps the question unfinished. If we have
any further correspondance, let's put it in the comments section.

I'm so glad you got you information in time.

Nenna-GA
whippur1-ga rated this answer:5 out of 5 stars and gave an additional tip of: $25.00
I really appreciate the helpful, supportive, thorough and pleasant way
nenna-ga solved my research challenge.

Comments  
Subject: Re: Permanent Hair Removal
From: thx1138-ga on 13 May 2004 11:17 PDT
 
Hello whippur1 and thank you for your question

To address point 3 in your question.  There appears to be little
control regarding laser treatment, although it might vary from state
to state:

(Curiously enough I was the researcher who answered the question you quoted)

May 2, 2004
"Electrologists, for example, say they are plenty qualified to provide
the service and hold up Florida as a model for regulation. There,
laser hair removal can be performed either in a doctor's office or by
an electrologist, said Lisia Cooley-Walch, president of the national
Society of Clinical and Medical Electrologists.

"We are the hair removal experts," said Cooley-Walch, who is also an
electrologist in Big Rapids, Mich. "We know what that thermal effect
is going to be on the skin. We know when to treat and not to treat. We
know when to refer to a physician and we want to partner with
physicians."

'Amberg, the laser manufacturer, says many non-physicians can safely
operate lasers. And Dr. Nancy Leiland-Fisher, a dermatologist in
Shadyside, said she has referred patients to non-physicians who have
provided quality care."

"Anybody can use these things and pretty much anybody is using them
now," Bowling said. "The problem is, if you have a woman who has hair
on her face, she won't be willing to come forward to report a problem
because she's embarrassed. ... Nobody [at the state] is taking
responsibility for this one."
http://www.post-gazette.com/healthscience/20020312hlaser1.asp

Very best regards

THX1138
Subject: Re: Permanent Hair Removal
From: thx1138-ga on 14 May 2004 06:10 PDT
 
Hello again whippur1 :)

Just a note for you and any other researcher who wants to take this
question on. The Intense Pulsed Light System is not actually a laser.

"This is a broad wavelength Intense Pulsed Light System. It is not a
laser and due to the patented technology, adjustments to the treatment
parameters can be made to suit each particular client."
http://www.hairfree.co.uk/qanda_epilight.htm

Best regards

THX1138
Subject: Re: Permanent Hair Removal
From: nenna-ga on 17 May 2004 09:21 PDT
 
In regards to THX's comment, because the IPL system is used for both
skin conditions and hair removal, it has to be operated by a licensed
professional according to the California Bureau of Barbering &
Cosmetology.

"Laser hair removal is a popular technique currently being advertised.
However, it is illegal for any Bureau licensee to perform this service. The
equipment used to perform laser hair removal is classified as a ?medical
device? by the FDA and use of these machines is considered the practice of
medicine. Laser hair removal may be performed only by a physician or by a
registered nurse or a physician?s assistant who is working directly with a
physician."

http://www.barbercosmo.ca.gov/formspubs/barbcosm.pdf

Every state differs, but CA follows those regulations. I know in some
states, your estheticians? license is enough for this procedure, but
California DOES require a medical license. They DO consider the IPL a
laser treatment.

Nenna-GA
Google Answers Researcher
Subject: Re: Permanent Hair Removal
From: nenna-ga on 22 May 2004 15:48 PDT
 
Thank you for the rating and the generosity of your tip. I am glad I
could be of help.

Nenna-GA
Subject: Re: Permanent Hair Removal
From: whippur1-ga on 22 May 2004 18:33 PDT
 
Thanks for your help educating me on the system!  I now see where to
make the distinction between comments and clarifications.

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