11.3 Labeling, SDS, and Chemical Service Procedures

68 Ill. Adm. Code 1175.710 does not stop at naming chemicals. It tests chemical service procedures. 1175.835 expects product knowledge as it relates to esthetics in the 500-hour practices block, chemistry — understanding chemicals and their use in the 150-hour scientific block, and OSHA standards relating to chemical use in the 25-hour business block. This section is the procedure: what the label must tell you, what the Safety Data Sheet (SDS) must tell you without repeating all of Chapter 5, and the order you work in so a superficial peel stays superficial.

INCI listing and active ingredients

Cosmetic ingredient lists use INCI — International Nomenclature of Cosmetic Ingredients. Under U.S. cosmetic labeling, ingredients are listed in descending order of predominance (highest concentration first). Ingredients present at 1% or less may be listed in any order after the greater-than-1% ingredients. Color additives are often grouped at the end.

Water (aqua) is usually first in a lotion because it is the largest fraction. A humectant listed second is present in greater amount than an antioxidant near the bottom. You cannot calculate exact percentages from INCI, but you can tell what the product mostly is. Front-of-bottle marketing is not INCI. “Infused with 12 oils” can still mean the oils sit at a fraction of a percent combined.

Active ingredients are a drug concept. Sunscreens, many acne products (salicylic acid, benzoyl peroxide), and antiperspirants are regulated as over-the-counter (OTC) drugs. They carry a Drug Facts box that names the active — the molecule doing the labeled drug job — separately from inactive ingredients. A zinc oxide sunscreen lists zinc oxide as the active; a moisturizer that merely “brightens” with a botanical does not get to invent an active box. On the exam, “where do I find the UV filter that is doing the SPF job?” points to active ingredients, not to a random INCI line in the middle of a fragrance blend.

Expiration, PAO, and marketing words that are not Illinois law

Expiration dates appear when the manufacturer assigns a period of identity, strength, and quality. Period after opening (PAO) is the open-jar symbol with a number and M (6M, 12M, 24M): how long after you crack the seal the product is intended to be used. Actives such as vitamin C and retinoids, and any jar that fingers can contaminate, are high-yield PAO examples. An expired peel is not “still fine if it smells okay.” Chemistry changes as preservatives fail and actives oxidize.

Once a product is contaminated — double-dipped, water-splashed, or used on a client with an open lesion — 1175.115(b)(9) does not care that the PAO has months left. Discard it after use on that particular client.

Hypoallergenic is a marketing word. It is not a legal Illinois standard under Part 1175 or the Act. It does not mean “cannot cause allergy,” does not replace a patch test, and does not override 1175.120. Fragrance-free means no added fragrance; unscented may still contain a masking scent. Neither term is a substitute for reading INCI for known allergens or for refusing inflamed skin under 1175.115.

SDS: pull Chapter 5 forward, do not re-teach it

Chapter 5 covered OSHA Hazard Communication: labels with signal words and pictograms, a 16-section SDS, PPE, eyewash, and storage. For this chapter, remember the operational rule for the chemical service itself:

• Keep a current SDS for every hospital-grade disinfectant and every peel, enzyme, depilatory, solvent, and concentrated acid in the room.
• Read SDS Section 2 (hazards), Section 4 (first aid), Section 7 (handling and storage), and Section 8 (PPE) before the first pour — not after the splash.
• The SDS tells you how to handle a hazardous chemical. It does not enlarge Illinois scope. A complete SDS for a physician-only medium peel does not make that peel esthetics (1175.120 plus IDFPR 04/06/2026).

If the SDS calls for splash goggles and nitrile, that is the PPE for mixing and application. Gloves you already wear for extractions are not automatically the right chemical glove. Disinfectant SDS and peel SDS both belong in the binder; infection control chemistry and facial chemistry share the same right-to-know duty.

Chemical service procedure (the 1175.710 sequence)

Treat this as a fixed order, the way you treat blood-exposure order.

The nine-step order

1. Consult. Intake: medications (isotretinoin, home retinoids, topical steroids), herpes simplex history, pregnancy, recent waxing or living-layer medical procedures, Fitzpatrick type, allergies, prior peel reactions. Obtain informed consent. Confirm the product is labeled for superficial / cosmetic use. 1175.115 refuse inflamed, infected, erupting, or serious communicable-disease skin.
2. Cleanse. Remove makeup and surface oil so the acid contacts evenly. Use the cleanser the protocol names — usually a syndet that will not leave a strongly alkaline film unless the manufacturer designed the next step for that.
3. Protect eyes and mucosa. Eye pads; petrolatum or manufacturer barrier on lips, alar creases, and any site you are not treating. The client’s eyes stay closed. You wear gloves and eye protection whenever splash is reasonably expected.
4. Time the peel. Apply as labeled. No pooling in the nasolabial folds, no dripping toward the eye. Start the timer when the product hits the skin. Time is dose.
5. Neutralize if required. Some AHAs need a labeled buffer. Some protocols are water-rinse only. Enzymes are typically rinsed. Do not invent a kitchen-alkali neutralization.
6. Cool. Cool compress, fan, or labeled calming product. This is comfort and inflammation control, not a chance to layer a second acid.
7. SPF. Superficial exfoliation increases UV sensitivity. Apply a labeled broad-spectrum sunscreen — often a physical zinc oxide or titanium dioxide formula if the protocol prefers it — and counsel sun avoidance.
8. Aftercare. No picking, no stacking home acids or retinoids until you say so, expected flaking versus blistering or oozing that means stop and refer. Written instructions beat a verbal “you’ll be a little pink.”
9. Document. Product name, that the indication was superficial, time on skin, client response, SPF and aftercare given, any adverse sign. Documentation is how you prove the service stayed in-scope.

No re-dipping, discard, and mixing order

1175.115(b)(9) is the contamination rule: creams, cosmetics, astringents, lotions, removers, waxes, moisturizers, masks, and oils shall be dispensed from containers to prevent contamination of the unused portion. Any product that becomes contaminated shall be discarded after use on that particular client.

No re-dipping a spatula into a bulk jar. No fingers in the mask tub. No pouring leftover peel back into the bottle. Disposable spatulas, pumps, and portion cups exist so the unused bulk stays unused. A “hypoallergenic” cream that you double-dipped is still a contaminated multi-use product under Illinois sanitation.

Mixing order: add acid into water, never water into concentrated acid. Diluting a strong acid is exothermic; water poured onto acid can boil and splash into eyes and skin. Mix in a chemical-resistant dish, with PPE from the SDS, using the manufacturer’s dilution — not a “stronger for oily skin” guess. 1175.115(b)(2) requires disinfecting agents at adequate strength, free of residue, and available whenever the salon is open. A cloudy, over-diluted disinfectant is a sanitation failure and a chemistry failure at the same time.

Put the INCI/Drug Facts label, the SDS, the timer, and 1175.115 on the same tray. That is chemical service procedure for the Illinois exam: product knowledge from 1175.835, product chemistry and chemical service procedures from 1175.710, and no living-layer improvisation from the 04/06/2026 prohibited-practices line.