1.2 Scope of Practice: Estheticians, Advanced Practice Estheticians and Other License Types

1. Why Scope Questions Are High Value

State exam content area I(c) asks about the scope of practice for cosmetology, esthiology, nail technology and eyelash technology under Minn. R. 2105.0105. Scope also appears in theory items, such as whether a basic esthetician may use a lancet, and in practical scenarios, such as a client asking for dermaplaning. The rule sets the line. What a product or device manufacturer markets does not change it.

2. Esthetics (Minn. R. 2105.0105, subp. 2)

"The practice of esthiology is the cosmetic treatment of the stratum corneum of the epidermal layer of the skin surface." Esthetic practice includes eyelash technology services (subp. 4) and items A to F:

Key consequences for a basic esthetician:

• Exfoliation must stay in the stratum corneum. Basic exfoliation removes dead cells in the stratum corneum by manual or chemical means. Superficial enzyme and hydroxy-acid exfoliation formulated for that layer fits. Anything that "exceeds the stratum corneum" is advanced exfoliation.
• Extractions use gloved fingers, cotton swabs or comedone extractors. Lancets and needles are advanced extraction tools.
• Machine skin cleansing is allowed. A rotary brush used to cleanse is a basic service. Using galvanic current for desincrustation is not, because galvanic current is an electrical energy treatment.
• Eyelash extensions are in scope. An esthetician or advanced practice esthetician does not need a separate eyelash technician license, although they may get one (Minn. R. 2105.0145, subp. 5, item B).

3. Advanced Practice Esthetics (subp. 5)

Advanced practice (AP) esthetics is "the cosmetic treatment of the epidermal layer of the skin." It includes everything in subp. 2 plus:

• A. Advanced exfoliation, including dermaplaning, microdermabrasion, chemical or enzyme exfoliation, and other methods that exceed the stratum corneum.
• B. Advanced skin care treatments using electrical energy treatments, including light therapy, galvanic current, microcurrent, high frequency, radio frequency and sound waves, plus lymphatic drainage and advanced extractions. Laser under Minn. Stat. 147.081, subd. 3 is the practice of medicine and is not an AP service.
• C. Skin needling.
• D. Other cosmetic services on the epidermal layer.

Note the depth limit: AP work is still epidermal. Treatments intended to injure the dermis, such as deep chemical peels, ablative resurfacing and injectables, fall outside both esthetic licenses.

Becoming an AP esthetician. The AP curriculum is 500 hours (Minn. R. 2110.0525). The prerequisite is completing esthetician or cosmetologist training at a board-licensed school within the past five years, or holding an active Minnesota cosmetologist or esthetician license. An AP applicant passes the AP general theory and written practical tests, and the AP license supersedes the esthetician license (Minn. R. 2105.0145, subp. 1a).

4. The Other License Types on the Outline

A cosmetologist with an active Minnesota license does not need a separate esthetician license but may obtain one (Minn. R. 2105.0145, subp. 5, item A). A licensee adding a second field does not retake the Minnesota laws and rules test (item C). Training credit rules in chapter 2110 let esthetician training count up to 550 hours toward a cosmetologist license and nail technician training count up to 200 hours toward an esthetician license.

5. Unregulated and Exempt Services

The Board does not regulate everything that happens near skin. Minn. R. 2105.0010, subp. 13 lists unregulated services: ear piercing; body art; body painting; henna and permanent tattoos; eyebrow embroidery and microblading; permanent hair removal; permanent makeup; tanning by UV radiation and spray tanning units; injectables; services for theater, film, fashion, photography and media productions; mortuary services; massage; body wraps and lymphatic drainage when performed by a massage therapist; the practice of medicine; hair braiding; and threading.

"Unregulated by the Board" does not mean "unregulated by anyone." Body art, for example, is licensed by the Minnesota Department of Health under chapter 146B, and injectables are medical procedures. It does mean an esthetics license does not authorize those services.

Statutory exemptions (155A.27, subd. 9 and 155A.34) include:

• people who perform only threading;
• people who perform only hairstyling and makeup after completing a four-hour board-approved course in health, safety, infection control and state law, carrying proof of completion;
• licensed out-of-state demonstrators serving consumers in the physical presence of a licensed cosmetologist; and
• emergency services without compensation, domestic service, and the practice of medicine, dentistry, podiatry, osteopathic medicine, chiropractic or barbering.

6. Applying the Rule to Scenarios

Common trap: An answer choice says a basic esthetician may perform a device service "after manufacturer training." Training does not expand scope. Minn. R. 2105.0190, subp. 1a requires licensees to confirm a new device or technique is within their scope of practice before using it.