1.3 Colorado Scope of Practice, Prohibited Acts & Additional-Training Services

Why Scope Matters Even Though the Theory Test Has No Law Domain

PSI's theory outline does not include a Colorado-law domain, but scope rules decide what you may legally do the day your license arrives. They also overlap heavily with tested content. "Never cut living skin" is both a theory answer and a Colorado rule. This section reads the statute and rules directly so you can tell real Colorado law from salon folklore.

What the Statute Says a Nail Technician Does

C.R.S. 12-105-104(11) defines manicuring as acts done for payment, or for the public generally, "not for the treatment of disease or physical or mental ailments." It lists:

• Nail work: filing, buffing, polishing, cleansing, extending, protecting, wrapping, covering, building, pushing or trimming nails, "or any other similar work upon the nails of a person by any means."
• Skin conditioning: softening the hands, arms, ankles or feet by hand, by mechanical or electrical appliances, or with cosmetic or chemical preparations, antiseptics, lotions or creams.
• Massage-type work: massaging, cleansing, stimulating, manipulating or exercising the arms, hands, feet or ankles.
• Limited hair removal: waxing or depilatories on the leg up to the knee and the arm up to the elbow.

C.R.S. 12-105-104(12) defines a nail technician as a person who engages in "the limited practices of cosmetology known as manicuring." Unless otherwise licensed, a nail technician may not perform other cosmetology services such as facials, makeup, lash work or hair services. Rule 1.8(D)(1) adds that the scope includes "the ordinary and customary services provided by nail technicians in the state." Those services remain subject to the infection-control rules and the additional-training requirements.

Two boundaries come straight from the definition:

1. Cosmetic, not medical. Treating disease is outside the license. A technician can recognize a probable fungal nail or an ingrown corner and refer the client, but cannot diagnose, prescribe or "treat" it.
2. The polish-only exemption. Since August 12, 2026, HB26-1181 exempts "an individual who polishes nails" from the Act. Everything beyond polish, such as shaping, cuticle work, enhancements or pedicures, still requires the license.

Services That Require Additional Training (Rule 1.9)

Electric Files: 8 Hours

Rule 1.9(F) defines an electric file as "a file, drill, or machine specifically designed for use in the professional nail industry." The definition expressly excludes craft, hardware and hobby tools. An electric file may be used only for manicure and pedicure services: natural nail services, filing, and maintenance or removal of artificial enhancements.

Before using one on the public, a nail technician or cosmetologist must complete 8 hours of electric-file training covering:

1. Cleaning and disinfection
2. Client protection during filing
3. Bit selection and use
4. Machine specifications and uses
5. Natural nail procedures
6. Artificial enhancements
7. Pedicure procedures

Training taken in Colorado must come from a DPOS- or CCCS-approved school; out-of-state training must be substantially equivalent. On the Director's request, the licensee must produce written proof. A certificate bearing the school's official seal is sufficient. Without completed training, using an electric file is prohibited.

Hair Removal: 6 Hours

Rule 1.9(G) limits a nail technician's hair removal to the leg up to the knee and the arm up to the elbow. The Director also treats the hands and feet as appropriate waxing areas. Removal may be done only with wax or depilatories. Eyebrows, lips, bikini areas and every other body area belong to cosmetologists and estheticians. The required 6 hours of training must cover:

• skin histology, anatomy and disorders
• client safety, consultation and contraindications for hair removal
• types of hair-removal products and their application
• disinfection, sanitation, rules and safe work practices

A nail technician without the training, or without proof of it, may not remove hair unless also licensed as a cosmetologist or esthetician. Wax services must follow Rule 1.7(K). Use a single-use spatula for one dip, a disinfected spatula for each dip, or a single-use cup portion. Never reuse wax, and empty and disinfect a contaminated pot.

Prohibited Acts (Rule 1.8(A))

Every Colorado licensee is barred from any service, implement, device, product, machine, tool or technique that:

• penetrates, destroys or alters the client's skin beyond the epidermis;
• is banned or deemed unsafe by a local, state or federal agency; or
• has a reasonable likelihood of causing harm or injury to the client.

The rule then names four specific bans:

Possession or storage of a prohibited device, substance or product "will be considered prima facie evidence of use" (Rule 1.8(A)(3)). A bottle of MMA in the back room is treated as if you used it. Rule 1.6(E) imposes the same presumption on shop owners for items outside licensees' scope or banned from the industry.

What About Credo Blades?

Many states name razor-style callus shavers ("credo blades") in their rules. Colorado's rule does not name them. Instead, the general prohibitions apply. A blade that slices into living tissue penetrates or alters skin beyond the epidermis, and shaving calluses carries a reasonable likelihood of injury. For exam and practice purposes, reduce calluses gradually with files and softeners and never cut living skin. Do not tell clients that Colorado has a specific "credo blade statute"; cite the beyond-the-epidermis rule instead.

Delegated Medical Services

Rule 1.8(G) states that the scope rules do not apply to services properly delegated under the Medical Practice Act or the Nurse Practice Act. A nail technician working in a medical office may have duties delegated by a physician or nurse under those laws. That authority comes from the medical delegation, not from the nail technician license.

Scope Summary