1.4 Michigan Statutory Scope of Practice for Estheticians

Michigan Statutory Scope of Practice for Estheticians

Quick Summary: Michigan is unusually specific about what an esthetician may do: the list lives in statute, at MCL 339.1210(2)(a)–(k), not in a rule or a board policy. Public Act 160 of 2024 (effective April 2, 2025) expanded that list to name dermaplaning, microdermabrasion, hydrodermabrasion, nonmedical grade chemical peels, brow lamination and tinting, lash extensions and tinting, and facial cupping. Every one of those services is then capped by MCL 339.1210(3): the service "must be limited to an individual's stratum corneum."

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1. The Enumerated Scope — MCL 339.1210(2)

"Subject to subsection (3), an esthetician or a cosmetologist may perform the following skin care services or combination of skin care services":

Several of these carry conditions that are easy to test and easy to miss:

• (c) is hands-only. Michigan authorises temporary hair removal "by using hands-only techniques in combination with" the listed implements. Machine- or energy-based hair reduction is not in the esthetician scope.
• (d) excludes permanent makeup. Micropigmentation, microblading and cosmetic tattooing are not esthetician services under Article 12.
• (d) excludes tanning equipment but carves out spray tan. UV tanning beds sit outside; spray tan equipment is inside.
• (f) has a grandfather clause with a training condition. An individual licensed before hydrodermabrasion was added must have documented training before performing it. Newly licensed estheticians take it as part of the scope.
• (i) puts a durability limit on brow tint. "Eyebrow tinting must be performed with a product that does not last for more than 6 weeks." A longer-lasting product moves the service toward permanent makeup and out of scope.

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2. The Boundary: Stratum Corneum — MCL 339.1210(3)

"As applicable, a skin care service described in subsection (2) must be limited to an individual's stratum corneum."

This one sentence does most of the regulatory work in Michigan esthetics, and it is the reason so many "can an esthetician do X?" questions have a clean answer. The stratum corneum is the outermost, non-living layer of the epidermis — corneocytes with no nuclei, no blood supply, and no sensation. A service that removes or acts on dead corneocytes is inside the scope. A service designed to wound living tissue is not.

Apply the test:

Exam Note: Michigan does not authorise estheticians to use lancets. The stratum corneum limit in subsection (3) is a hard cap, and no rule in R 338.2101 et seq. creates a lancet exception. Where a study source tells you Michigan permits lancet-assisted extraction, it is describing another state's practice or an unregulated custom — not Michigan law. Extraction in Michigan is manual and atraumatic; anything that will not release without puncturing living tissue is referred out.

Note also R 338.2179g(2): "An esthetician shall not use razors, scissors, or clippers on the scalp of a patron." Those implements are available for temporary hair removal under §(2)(c), but the scalp belongs to hair care services.

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3. Statutory Definitions That Set Device Limits — MCL 339.1210(7)

Michigan defines three terms inside the section, and the numbers are testable:

• "Class 1 medical device" — "a low-risk device that requires minimal regulatory oversight and is used for basic aesthetic procedures, including, but not limited to, LED light therapy and noninvasive skin care tools, such as galvanic current at not less than 0.1 and not more than 0.5 milliamperes for a duration of not more than 20 minutes, and microcurrent that does not cause visible contractions."
• "High-frequency treatment" — "a skin care service that uses an electrical current of not less than 5 megahertz to treat various conditions, including, but not limited to, acne, wrinkles, and skin renewal."
• "Nonmedical grade" — "a product or material that is not certified for medical use only."

Exam Note: Two device numbers to hold: galvanic 0.1–0.5 mA for ≤ 20 minutes, and high frequency ≥ 5 MHz. A microcurrent unit driven hard enough to produce visible muscle contractions has left the class 1 definition and therefore left the statutory safe harbour.

4. Light Therapy and Medical Waste — MCL 339.1210(4) and (5)

Light therapy. An esthetician who performs a light therapy service "shall use only noninvasive light therapy" that (a) is approved by the FDA and (b) is intended to not penetrate into an individual's layers of living skin. Both conditions must hold. A device that is FDA-cleared but designed to reach the dermis fails the second limb.

Medical waste. An esthetician who performs a skin care service "shall comply with part 138 of the public health code, 1978 PA 368, MCL 333.13801 to 333.13832, for the disposal of medical waste," using the definition of medical waste in MCL 333.13805. In practice this is the statutory hook for sharps and blood-contaminated waste handling — dermaplaning blades above all.

Finally, R 338.2179g(1)(i) bars any licensee from performing "services that are limited to the scope of practice of a licensed health profession regulated under article 15 of the public health code... unless he or she is performing a service that is delegated to him or her under section 16215." Delegation by a physician is the only route by which an esthetician in a medical spa performs a medical act, and it is the physician's authority, not the esthetician's licence, that carries it.

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Real-World Scenario: A Request List in a Birmingham Medical Spa

Scenario: A client asks Maya, a licensed Michigan esthetician working in a medical spa, for four things: a lash lift and brow lamination; a glycolic peel; a hyaluronic acid filler in her nasolabial folds; and removal of two raised, irregularly pigmented lesions on her forehead with a dermaplaning blade.

Analysis:

1. Lash lift and brow lamination. In scope — §(2)(i) and (j) name brow lamination and tinting and lash extensions and tinting. If tinting the brows, Maya must use a product that does not last more than six weeks.
2. Glycolic peel. In scope — §(2)(g) permits a nonmedical grade chemical peel, subject to the stratum corneum limit in subsection (3). Maya selects a cosmetic-grade formulation and stops at superficial frosting-free exfoliation.
3. Dermal filler. Out of scope. Injection penetrates living, vascularised tissue and is the practice of medicine under article 15 of the Public Health Code. Only a licensed prescriber, or someone acting under a valid MCL 333.16215 delegation, may perform it — and delegation does not convert Maya's esthetician licence into medical authority.
4. Removing pigmented lesions. Out of scope, twice over. Cutting a lesion is surgical alteration beyond the stratum corneum, and the lesions are undiagnosed and suspicious. Maya treats them as an absolute contraindication, avoids exfoliating over them, and refers the client to a dermatologist for evaluation before any further facial work.

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Key Takeaways

• The list is statutory: MCL 339.1210(2)(a)–(k), expanded by PA 160 of 2024, effective April 2, 2025.
• The cap is statutory too: MCL 339.1210(3) limits every enumerated service to the stratum corneum.
• Named-in-statute services: dermaplaning, microdermabrasion, nonmedical grade hydrodermabrasion (with a training condition for pre-existing licensees), nonmedical grade chemical peels, high-frequency treatment, brow lamination and tinting, lash extensions and tinting, facial cupping, body wrapping, spray tan.
• Named exclusions: permanent makeup, tanning equipment other than spray tan, scalp razors/scissors/clippers, and anything reserved to a health profession absent MCL 333.16215 delegation.
• Device numbers: galvanic 0.1–0.5 mA ≤ 20 min; microcurrent with no visible contractions; high frequency ≥ 5 MHz; light therapy FDA-approved and non-penetrating.
• Lancets are not authorised in Michigan; extraction is manual and stops at the horny layer.