1.3 Salon Standards, Sanitation Rules & Scope of Practice
Key Takeaways
- Under 225 ILCS 410/3C-1, the scope covers natural and artificial nail care plus massage of the hands, arms, elbows, feet, lower legs, and knees "for other than the treatment of medical disorders," and bars any technique, product, or practice intended to affect the living layers of the skin.
- Rule 1175.115(b)(16) expressly prohibits nail products containing monomer methyl methacrylate (MMA); IDFPR has separately stated that fish pedicures cannot be performed in compliance with the Code sanitary standards; and blade callus-paring and matrix-level e-filing are barred by the 3C-1 living-layers limit rather than by a rule that names those tools.
- Rule 1175.115(b)(30)-(32) requires a safe, adequate supply of continuous hot and cold running water from an approved source, immediate licensee access to it, and ventilation adequate to keep the salon free of excessive heat, steam, condensation, vapors, odors, smoke, and fumes as required by the city, county, or municipality. Restroom sinks do not count as the water source.
- Multi-use implements must be washed with soap and water before complete immersion in an EPA-registered hospital-grade disinfectant with bactericidal, virucidal, and fungicidal efficacy; single-use porous items must be discarded immediately.
- IDFPR has statutory authority to inspect salons and schools under 225 ILCS 410/4-1(5); refusing or interfering with an inspection is unprofessional conduct under 68 Ill. Adm. Code 1175.120(k)(1), and civil penalties under 225 ILCS 410/4-7(1) may not exceed $500 for each violation.
Salon Standards, Sanitation Rules & Scope of Practice
Quick Summary: In Illinois, the statutory scope of practice (225 ILCS 410/3C-1) covers manicuring, pedicuring, decorating nails, artificial applications, and massage of the hands, arms, elbows, feet, lower legs, and knees - "for other than the treatment of medical disorders." Technicians may not use any technique, product, or practice intended to affect the living layers of the skin, and may not advise on medical treatment for diseases of the nails or skin. Rule 68 Ill. Adm. Code 1175.115(b)(16) expressly bans methyl methacrylate (MMA) nail products. IDFPR has stated that fish pedicures cannot comply with the sanitary standards. Salons must use EPA-registered hospital-grade disinfectant, discard listed single-use items, and follow the three-tier pedicure foot spa procedure in 1175.115(c) with a 90-day cleaning log. IDFPR inspects under 225 ILCS 410/4-1(5), and civil penalties are capped at $500 per violation by 225 ILCS 410/4-7(1).
1. Statutory Scope of Practice (225 ILCS 410/3C-1)
Section 3C-1 defines nail technology as manicuring, pedicuring, decorating nails, applying artificial applications by hand or with mechanical or electrical apparatus, or otherwise beautifying the nails or the skin of the hands or feet, "including massaging the hands, arms, elbows, feet, lower legs, and knees of another person for other than the treatment of medical disorders." Two express limits follow in the same section: nail technicians are prohibited from using techniques, products, and practices intended to affect the living layers of the skin, and while they may advise on what is cosmetically appealing, no licensee may advise on appropriate medical treatment for diseases of the nails or skin. Practicing beyond those boundaries is unprofessional conduct under 68 Ill. Adm. Code 1175.120(b) and can constitute the unlicensed practice of medicine.
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| ILLINOIS NAIL TECHNICIAN SCOPE OF PRACTICE |
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| AUTHORIZED PRACTICE (225 ILCS 410/3C-1) | PROHIBITED & UNLAWFUL ACTS |
| --------------------------------------- | ---------------------------------------- |
| - Manicuring and pedicuring natural nails | - Any technique, product, or practice |
| - Applying artificial nails, tips, gels, | intended to affect the LIVING LAYERS |
| acrylics, dipping powders, and wraps | OF THE SKIN (the statutory red line) |
| - Decorating nails / nail art | - Cutting or paring living skin, corns, |
| - Beautifying, shaping, and polishing | or calluses with blades |
| - Massaging hands, arms and ELBOWS | - Diagnosing nail/skin diseases or fungi |
| - Massaging feet, lower legs and KNEES | - Advising on medical treatment for |
| - Advising on what is cosmetically | diseases of the nails or skin |
| appealing | - Treating medical disorders of any kind |
| - Cosmetic exfoliation (non-cutting) | - Massaging shoulders, neck, thighs, body |
| - Safe electric file (E-file) operations | - Waxing/esthetics (without dual license) |
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The Medical Boundary
- No Diagnosis or Treatment: Nail technicians cannot tell a client they have onychomycosis (nail fungus), paronychia, or bacterial infections. If abnormal inflammation, discoloration, swelling, pus, or open sores are observed, the technician must politely refuse service and refer the client to a licensed physician or podiatrist.
- Callus Management vs. Callus Removal: Technicians may smooth and soften calluses cosmetically using foot files, pumice stones, scrubs, and chemical callus softeners. They can never attempt to cut, shave, or surgically excise a callus or corn.
2. Strictly Prohibited & Banned Practices in Illinois
Some prohibitions are named outright in 68 Ill. Adm. Code 1175.115; others follow from the 3C-1 living-layers limit. Know which is which, because that distinction is exactly how a state-law item is written:
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| STRICTLY PROHIBITED PRACTICES IN ILLINOIS |
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| NAMED IN THE RULE |
| 1. METHYL METHACRYLATE (MMA) - 1175.115(b)(16) |
| - "The use of nail products or the distribution of nail products containing |
| monomer Methyl Methacrylate (MMA) is prohibited." |
| - Only Ethyl Methacrylate (EMA) or light-cured oligomers are used instead. |
| |
| 2. ANIMALS IN SALONS - 1175.115(b)(36) |
| - "Pets or other animals shall not be permitted in a salon or shop at any time." |
| - Exception: an animal assistant for the physically impaired. |
| |
| 3. MASSAGE OVER INFLAMED OR INFECTED SKIN - 1175.115(b)(34) |
| - No licensee may massage any skin surface that is inflamed or shows infection. |
| |
| 4. SERVING A PERSON WITH A SERIOUS COMMUNICABLE DISEASE - 1175.115(b)(33),(35) |
| - As defined in 77 Ill. Adm. Code 690. |
| |
| BARRED BY THE 3C-1 LIVING-LAYERS LIMIT (no rule names the tool) |
| 5. BLADE CALLUS PARING (Credo blades, corn planes, rasps, scalpels) |
| - Illinois publishes no rule naming "credo blade," but cutting or paring skin is |
| a practice intended to affect the living layers of the skin and is outside the |
| nail technician scope. It is also unprofessional conduct under 1175.120(b). |
| |
| 6. E-FILE ON THE NATURAL NAIL ROOT / MATRIX |
| - Not named in the rule either; it causes matrix trauma and "rings of fire," and |
| is gross negligence / departure from standards under 1175.120(e) and (g). |
| |
| IDFPR DEPARTMENT STATEMENT |
| 7. LIVE FISH PEDICURES (Garra rufa) |
| - IDFPR Statement Regarding Fish Pedicures (March 17, 2009): sanitizing the fish |
| to the Code standards would kill them, so "it appears to be impossible to |
| perform fish pedicures that comply with the Code's sanitary standards." |
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[!WARNING] MMA vs. EMA Identification: MMA monomer has an extremely strong, acrid chemical odor, does not soak off easily in acetone (creates a stringy, gooey sludge), and cures into an unnaturally rock-hard enhancement that can rip the natural nail bed upon impact. EMA has a milder odor, soaks off cleanly in 20-30 minutes, and flexes safely with natural nail growth.
3. Salon Facility Standards & Physical Specifications
The facility rules for salons and shops live in 68 Ill. Adm. Code 1175.115(b), and registration requirements in Subpart M (1175.1300 et seq.). Quote the rule, not a generic "salon code":
- Water Supply (b)(31)-(32): A safe and adequate supply of continuous hot and cold running water from an approved source (see the Illinois Plumbing Code, 77 Ill. Adm. Code 890). Sinks located in the restroom do not qualify as a water source, and licensees must have immediate access to hot and cold running water.
- Ventilation (b)(30): Salons must provide ventilation as required by the city, county, or municipality to keep the space free of excessive heat, steam, condensation, vapors, obnoxious odors, smoke, and fumes. Illinois does not publish its own numeric air-change or CFM figure - the local code sets it, and source-capture at the table is the industry best practice on top of it.
- Surfaces and storage (b)(21)-(29): floors clean, orderly, and in good repair; storage drawers used only for clean tools; walls, doors, windows, and ceilings free of spots, mildew, condensation, or peeling paint; soiled towels in covered containers; clean towels in a closed or covered space.
- Devices (d): every device must meet federal, State, county, and local product registration and product safety requirements, be used consistently with the manufacturer's intended use, and stay within the licensee's scope. Licensees must be able to access documentation for any FDA-classified device they use.
- Other regulators (e): owners, managers, and licensees remain subject to Illinois Department of Public Health rules and to local building, fire, plumbing, and electrical codes.
[!NOTE] Home-based salons. Part 1175 does not set a separate residential-salon standard: a salon in a residence must hold the same salon/shop certificate of registration and meet the same 1175.115 sanitary standards as any other salon. Requirements people often attribute to IDFPR - a separate exterior entrance, a dedicated client restroom, solid-wall separation from living quarters - come from local zoning and municipal codes, not from Part 1175. Verify them with the municipality.
4. Sanitation, Disinfection & Foot Spa Protocols
Under 68 Ill. Adm. Code 1175.115(b)(3)-(7), every tool or item that touches a client must be cleaned and disinfected or disposed of after use on each client; non-disposable manicure tools must be cleaned and disinfected with a hospital grade disinfectant after each client; and manicure tables and work stations must be cleaned and disinfected with a hospital grade disinfectant before and after each client. The rule defines a hospital grade disinfectant as one registered with the EPA as hospital-level that acts as a bactericide, virucide, and fungicide. That is a two-step process: Cleaning followed by Disinfection.
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| TWO-STEP INFECTION CONTROL PROTOCOL (IDFPR) |
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| |
| STEP 1: CLEANING & DEBRIS REMOVAL |
| - Scrub implement with warm water, soap/detergent, and a clean brush |
| - Thoroughly rinse and dry before chemical exposure |
| - (Disinfectants are deactivated by organic debris, skin particles, and dust) |
| | |
| v |
| STEP 2: CHEMICAL DISINFECTION |
| - Completely immerse clean, non-porous implement in an EPA-registered |
| HOSPITAL-GRADE DISINFECTANT |
| - Solution MUST be labeled as BACTERICIDAL, VIRUCIDAL, and FUNGICIDAL |
| - Maintain full immersion for the complete manufacturer contact time (typically 10 min)|
| | |
| v |
| STEP 3: STORAGE |
| - Remove with tongs/gloves, rinse, dry, and store in a clean, closed container labeled |
| "DISINFECTED IMPLEMENTS" |
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Single-Use vs. Multi-Use Implements
| Classification | Implements Included | Mandatory Handling |
|---|---|---|
| Multi-Use (Non-Porous) | Metal cuticle nippers, steel pushers, nail clippers, diamond/carbide e-file bits | Clean with soap/water $\rightarrow$ Fully immerse in EPA hospital grade disinfectant $\rightarrow$ Store separately from all others in a clean drawer used only for clean tools (1175.115(b)(6), (b)(22)) |
| Single-Use (per 1175.115(b)(5)) | Orangewood sticks, cotton, gauze, neck strips, nail wipes, tissues, sponges, paper towels, wooden applicators and spatulas, emery boards or porous nail files, buffer blocks, pumice stones, sanding bands or sleeves, and disposable nail bits | Disposed of after each use. Rule (b)(11) adds: any article that contacts the client's skin and cannot be cleaned or disinfected must be disposed of immediately after use |
Pedicure Foot Spa Decontamination Regimen
Rule 1175.115(c) adopts the International Nail Technicians Association procedures for whirlpool pedicure foot spas, self-contained foot basins, sinks, and pedicure bowls. Learn the three tiers exactly as written - the frequencies and the numbers are the tested part:
- After each client: (A) drain all water; (B) clean the interior surfaces and walls with soap or detergent to remove all visible debris, then rinse with clean, clear water; (C) disinfect by spraying the interior surface with either an EPA-registered disinfectant (bactericidal, fungicidal, and virucidal, used per label) or a 10% bleach solution; (D) wipe dry. Note what the rule does not say: there is no requirement to circulate disinfectant through the jets between clients.
- At the end of every day, after the last client: repeat the after-each-client steps; remove the screen from the whirlpool basin and brush out all debris trapped behind it; clean the screen and inlet with soap or detergent and water; totally immerse the screen in an EPA-registered disinfectant or 10% bleach before replacing it; then fill the basin with warm water and low-sudsing soap, turn the system on, and flush the spa system for 5 minutes, then rinse and drain.
- Once every week: repeat the end-of-day procedure, then fill the spa with cold water and one tablespoon of 5.25% liquid household bleach (or equivalent) for each one gallon of water based on the unit's capacity; circulate the bleach solution through the system for 5 to 10 minutes; turn the unit off and let the solution sit overnight (at least 6-10 hours); the following morning, before the first client, drain it, refill with clean water, turn the system on, flush with clean water, and drain.
[!IMPORTANT] The weekly bleach strength is a favorite trap. The rule says one tablespoon of 5.25% household bleach per gallon of water - roughly a 1:250 dilution. That is not the same as the 10% (1 part bleach to 9 parts water) solution the rule allows for spraying the basin surface. Two different jobs, two different strengths.
[!WARNING] The 90-day log (1175.115(c)(4)). Make a record of the date and time of the weekly cleaning and disinfecting. The record for the last 90 days must be readily accessible and available on request by a client or an inspector. Separate logs are needed for the weekly and daily procedures, but they may be kept in the same document log.
5. IDFPR Inspection Authority & the Penalty Ladder
Three different penalty tracks exist, and prep material routinely confuses them. Learn the numbers separately:
| Track | Authority | Consequence |
|---|---|---|
| Inspection | 225 ILCS 410/4-1(5) | The Department conducts inspections of nail technology schools, salons, and shops for compliance with the Act and rules, and prescribes the sanitary rules governing them. |
| Interference | 68 Ill. Adm. Code 1175.120(k)(1) | Refusing to permit or interfering with an inspection authorized under the Act is dishonorable, unethical, or unprofessional conduct - a discipline trigger, not an automatic revocation. |
| Discipline | 225 ILCS 410/4-7(1) | The Department may refuse, suspend, revoke, place on probation, reprimand, or take other action, including civil penalties not to exceed $500 for each violation. Fines are due within 60 days of the order. |
| Citation | 225 ILCS 410/4-19 | Citations for unlicensed practice, practice on an expired license, failure to register a salon, aiding unlicensed practice, failure to display a license, or any violation of sanitary rules. The penalty shall not exceed $500 per violation; a cited person has 30 days to request a hearing. |
| Criminal | 225 ILCS 410/4-20 | Unlicensed practice, fraudulent misrepresentation, false oath, or any violation of the Act: Class B misdemeanor for a first offense, Class A misdemeanor for a second, and Class 4 felony fined not less than $1,000 or more than $5,000 for subsequent offenses. |
- Sanitary violations are discipline. 1175.115 opens by stating that failure to comply with the sanitary standards "shall be considered unprofessional conduct and may be determined to be a violation pursuant to Section 4-7 of the Act."
- The $10,000 figure is wrong. Illinois caps the civil penalty for a violation of this Act at $500. If an answer option offers $10,000, it is a distractor.
- Deposit of fines: all fees and fines collected under the Act go into the General Professions Dedicated Fund (225 ILCS 410/4-5.1).
Under Illinois statute 225 ILCS 410/3C-1, which of the following services is legally permitted within the scope of practice of a licensed nail technician?
Which prohibition is stated expressly in the text of 68 Ill. Adm. Code 1175.115, rather than inferred from the scope-of-practice limit in 225 ILCS 410/3C-1?
What is the maximum civil penalty IDFPR may impose for each violation of the Barber, Cosmetology, Esthetics, Hair Braiding, and Nail Technology Act, and where does the inspection authority come from?