3.3 Labor, Compensation, OSHA, and Professional Conduct

Illinois does not treat “salon business” as optional reading. 68 Ill. Adm. Code 1175.710 states that the esthetician examination covers theoretical and practical knowledge including product chemistry, sanitary rules and regulations, sanitary procedures, chemical service procedures, anatomy of the skin as it relates to services under the Act, the provisions of the Act, and labor and compensation laws. The passing grade is 75. If a fact pattern is about who gets paid, who is covered after a chemical burn, or who may work on an expired license, it is in scope for this exam.

The 750-hour curriculum makes the same point in hour form. 1175.835 requires 25 hours of Business Practices covering:

Those 25 hours sit beside 75 hours basic, 150 hours scientific concepts, and 500 hours practices. The business slice is small, but 1175.710 puts labor and compensation on the same exam as sanitation.

Employees, Booth Renters, and the Classification Trap

Illinois salons commonly mix payroll employees, booth renters, and people who are called independent contractors. This chapter is not tax advice and it does not tell you how to fill out a Form 1099 or a Schedule C. The exam-relevant rule is simpler: a label does not erase a duty. If the working relationship is actually employment — the salon controls the schedule, sets the prices, provides the room and products, and directs the manner of work — calling the person a “contractor” or “renter” does not make Illinois Workers’ Compensation coverage or Occupational Safety and Health Administration (OSHA) chemical duties disappear. Misclassification is a labor-law problem under 1175.120(d) (violating labor laws in the practice of the profession) as well as a workers’ compensation and OSHA problem. 1175.1300(b)(3) already requires either the facility or each renter to hold a salon registration; registration of the booth does not decide employment status.

Illinois Workers’ Compensation is no-fault workplace-injury insurance. Esthetics injuries that belong in this conversation include chemical burns from disinfectants, peel acids, or wax, eye exposures, slips on product, and bloodborne exposure after a nick during extraction or waxing. The Workers’ Compensation Act is in the 25-hour block because a burned employee is a compensation event, not a “sign this waiver” event. Who is an employee in a close case is a legal determination; the exam still expects you to know that WC exists to cover those work injuries and that misclassification does not wipe the duty if the worker was an employee in fact.

OSHA: Hazard Communication, SDS, PPE, and Bloodborne Concepts

OSHA is the federal workplace-safety agency. The chemical-use standards 1175.835 names are the ones you actually handle in a facial room.

Hazard Communication (the federal Hazard Communication Standard, often called “right to know”) requires that hazardous chemicals be labeled, that a Safety Data Sheet (SDS) be available for each hazardous product, and that workers be trained on the chemicals they use. In an esthetics setting those chemicals include EPA-registered hospital-grade disinfectants, peel acids, wax, solvents, and acetone-type products. An SDS is not décor. It tells you first-aid, required personal protective equipment (PPE), ventilation, spill response, and whether an eyewash or specific spill kit is indicated. Secondary bottles (a spray bottle of disinfectant, a peel mixed at the station) still need identity and hazard information; a mystery spray bottle fails HazCom even if the concentrate in the back room is labeled.

PPE follows the SDS and the task: gloves for disinfectants and body-fluid contact, eye protection where splash is reasonably expected, and any respirator or gown the SDS specifies. Eyewash and spill capability is a chemical-use issue, not a luxury for large spas. If you pour concentrated disinfectant or handle peel acids, you plan the spill and the eye exposure before the splash.

The OSHA Bloodborne Pathogens Standard is the conceptual partner of Illinois’s refuse-service rules. Universal precautions (now often taught as standard precautions) mean you treat blood and certain body fluids as if they were infectious — hepatitis B, hepatitis C, and HIV included — every client, every time. You do not wait for a disclosed diagnosis. A blood-exposure nick during extraction is a PPE, cleanup, and reporting event, and it is also why 1175.115 forbids working on inflamed, infected, or erupting skin and on a person with a serious communicable disease under 77 Ill. Adm. Code 690. Microbiology chapters will teach organisms; this chapter teaches that Illinois already folded chemical OSHA and workers’ compensation into the 750-hour business block, and that labor-law violations are unprofessional conduct under 1175.120(d).

1175.120 and Section 4-7: How Sanitation Becomes Discipline

1175.120 interprets dishonorable, unethical, or unprofessional conduct under Section 4-7(a)(1)(q) of the Act (cited in the rule as Section 410/4-7(a)(1)q). IDFPR may suspend or revoke a license, refuse to issue or renew, or take other disciplinary action. Actual injury to a client need not be established for several of these counts. High-yield 1175.120 items for this chapter:

• Conduct likely to deceive, defraud, or harm the public, or a willful disregard for the health, welfare, or safety of a client or student.
• Practicing or offering to practice beyond the scope permitted by law, or accepting work the licensee knows or should know she is not competent to perform — including living-layer techniques, medical claims, or devices used off-label.
• Using products or chemicals not approved by the FDA, or using them contrary to the manufacturer’s indication (the rule’s example is hair dye meant for scalp hair used on eyebrows).
• Violating labor laws in the practice of the profession, including involuntary labor or trafficking — the labor clause is why 1175.710 tests compensation law.
• Departing from standards of practice (sanitation is a standard of practice).
• Deception regarding licensure: allowing another person to use your license; displaying a license that has expired, is inactive, or has been revoked or suspended; selling unearned credentials.
• Fraud or material deception in professional services, including advertising services or goods in a false or misleading manner.
• Sexual misconduct involving a client; failing to cooperate with an IDFPR inspection; offering controlled substances or sex acts in or next to the workplace.

Section 4-7 of the Act is the statutory list. Beside unprofessional conduct, it includes false or misleading advertising, continued practice by a person knowingly having an infectious or contagious disease, operating a school, salon, or shop without a valid license or registration, failure to complete required continuing education, and — under the P.A. 104-153 text effective January 1, 2026 — operating, owning, or managing a school, salon, or shop that is cited for sanitary violations. Sanitation is not only 1175.115. A sanitary citation against the shop can be a 4-7 problem for the owner or manager. Civil penalties under 4-7 may not exceed $500 per violation, and the Department may also suspend, revoke, probate, or reprimand.

Practicing on an expired license is both a 1175.120 display/deception problem and a 4-7 unlicensed-practice problem. Esthetician licenses expire September 30 of odd-numbered years; salon certificates expire November 30 of even-numbered years. Those dates are different on purpose. Working after either one lapses is not “waiting on the card in the mail.”

Advertising, Intake Confidentiality, Students, and Sexual Harassment Prevention

Advertising must match scope. Estheticians may not hold out medical results — treating disease, affecting living layers of the skin, or guaranteeing a medical outcome. 1175.120(j) reaches false or misleading advertising of services or goods; 1175.120(b) reaches practice beyond scope; 1175.1305(b) already bans “medical” in the salon name. “Laser facial,” “treats acne as a physician would,” or “Botox special” on an esthetician’s flyer is an advertising-and-scope problem, not a marketing style.

Intake forms collect health history, medications, contraindications, and sometimes photographs. That information is collected so you can refuse inflamed or infected skin, identify peel or wax contraindications, and document informed consent. It is not break-room conversation and it is not social-media content. Sharing a client’s intake, diagnosis guesses, or identifiable before-and-after images without a proper basis is a professional-conduct failure even though 1175.120 does not use the word HIPAA. Protect the record the same way you protect the client’s skin: need-to-know, secured, not posted.

Tips and student pay. 1175.835 is explicit: students in the current student clinic and internship receive no compensation, including tips. Hour credit toward 750 hours is the compensation the rule allows. A clinic client who leaves cash on the facial bed, or a host salon that “tips the intern off the books,” creates a labor-and-curriculum violation.

Do not confuse that rule with the formal apprenticeship program effective January 1, 2027 under P.A. 104-0478. An apprentice must be employed under an apprenticeship agreement and paid at least Illinois minimum wage, with increases as competency and experience grow. That future 1,500-hour route is distinct from the current unpaid 75-hour school internship and depends on implementing rules.

Sexual harassment prevention is a license-renewal duty under 20 ILCS 2105/2105-15.5, not a substitute for the full esthetician CE chapter. Each individual (non-business) IDFPR licensee must complete sexual harassment prevention training provided by the employer, the Illinois Department of Human Rights, or an authorized continuing education provider, at a minimum before renewing the license. IDFPR applies this beginning with the first renewal after initial licensure, and it also applies at reinstatement or restoration. Profession-specific 10-hour CE, the first-renewal CE waiver, and domestic-violence/sexual-assault awareness hours live in the renewal chapter; this section only flags that the one-hour sexual harassment course is a separate statutory duty that still attaches even when other CE rules shift. It does not apply to business licenses such as the salon certificate itself.

Put the three sections of this chapter together and the Illinois exam story is one chain: 1175.115 tells you how to clean, disinfect, and refuse unsafe skin; Subpart M tells you where those services may occur and what the salon must post and file; 1175.710, 1175.835, 1175.120, and Section 4-7 tell you that labor, OSHA, workers’ compensation, advertising, expired practice, and sanitation failures are professional-conduct and exam content, not after-hours business trivia.