2.1 Minn. Stat. 155A & Minn. R. 2105 Scope of Practice & Prohibited Services
Key Takeaways
Minn. Stat. 155A.23, subd. 7 defines a nail technician as a person who, for compensation, performs cosmetic care of the hands, feet, and nails only.
Minn. R. 2105.0105, subp. 3 bars nail technicians from waxing, eyelash or eyebrow enhancements, esthetician services, and using any tool that penetrates the skin.
Nail technicians may remove calluses only with callus removal products, sanding, buffing, or filing; credo blades, razor-type callus shavers, rasps, and graters are banned.
Before offering a new product, technique, or device, a Minnesota licensee must confirm it is in scope, follow the manufacturer's directions, and keep training records.
Licensees must not perform services on clients with open wounds or sores in the area to be serviced (Minn. R. 2105.0375, subp. 7).
Minn. Stat. 155A & Minn. R. 2105 Scope of Practice & Prohibited Services
The state exam's General Information domain (15%) asks what each license may and may not do. Scope questions also show up on the theory and written practical exams whenever a scenario tempts you to cut skin, wax, or treat a medical condition.
1. The Statutory Definitions (Minn. Stat. § 155A.23)
| Term | Definition |
|---|---|
| Cosmetology (subd. 3) | Personal services, for compensation, for the cosmetic care of the hair, nails, and skin, including cleaning, conditioning, shaping, reinforcing, coloring, and enhancing the body surface |
| Nail technician (subd. 7) | Any person who, for compensation, performs personal services for the cosmetic care of the hands, feet, and nails only |
| Esthetician (subd. 5) | Personal services for the cosmetic care of the skin only; the 2026 amendment specifies the stratum corneum of the epidermal layer |
| Advanced practice esthetician (subd. 14) | Cosmetic care of the skin, including mechanical or electrical skin care apparatuses used on the epidermal layer |
| Eyelash technician (subd. 4b) | Performs eyelash extensions only |
| Cosmetologist (subd. 4) | Performs cosmetology services: hair, nails, and (after the 2026 amendment) the stratum corneum of the skin |
"Compensation" means monetary or nonmonetary payment (Minn. R. 2105.0010, subp. 4a), so trading a manicure for a haircut is still practice for compensation.
2. What Nail Technology Includes (Minn. R. 2105.0105, subp. 3)
The practice of nail technology is the cosmetic care of the hands, feet, and nails. It includes:
| Item | Service |
|---|---|
| A | Cleansing, removing polish, cutting, trimming, polishing, tinting, coloring, or manicuring the fingernails or toenails |
| B | Attaching and removing acrylic, other artificial nails, or nail enhancements |
| C | Cleansing, massaging, and cosmetic care of the skin of the hands and feet, including paraffin treatments |
| D | Callus removal by the use of callus removal products, sanding, buffing, or filing |
| E | Massaging the hands, feet, and lower arms and legs in conjunction with the services above |
| F | Other services for the cosmetic care of the hands, feet, and nails |
The same subpart sets two hard limits: nail technician services do not include waxing, eyelash or eyebrow enhancements, or any other esthetician service, and nail technicians must not use any tool or equipment to penetrate the skin.
Comparing Licenses
| License | May do | May not do |
|---|---|---|
| Nail technician | Items A–F above | Waxing (anywhere, including knuckles or toes), lash or brow tinting, lash extensions, extractions, peels, hair services, any skin penetration |
| Esthetician | Skin care of the stratum corneum: facials, makeup, waxing and hair removal, basic exfoliation and extractions, lash and brow tinting, and eyelash extensions | Nail services; advanced exfoliation or electrical energy treatments |
| Advanced practice esthetician | Esthetics plus advanced exfoliation (dermaplaning, microdermabrasion, chemical or enzyme exfoliation beyond the stratum corneum), electrical energy treatments, lymphatic drainage, advanced extractions, skin needling | Laser (the practice of medicine); nail services unless separately licensed |
| Eyelash technician | Applying, removing, and trimming eyelash extensions and cleansing the eye area | Tinting, perming, bleaching, brow work, any other cosmetology service |
| Cosmetologist | Hair, skin, and nail services | Advanced practice esthetic services without the AP license |
Other boundaries worth knowing: threading is exempt from cosmetology licensing (§ 155A.27, subd. 9), and permanent makeup and tattooing are body art regulated by the Minnesota Department of Health under Minn. Stat. chapter 146B, not by the cosmetology board.
3. The Skin-Cutting Ban and Legal Callus Care
Minn. Stat. § 155A.355, subd. 2 prohibits "razor-type callus shavers, rasps, or graters designed and intended to cut growths of skin such as corns and calluses, including but not limited to credo blades." Minn. R. 2105.0377, item B adds that such skin-cutting equipment "must not be present in a salon."
- Presence alone of one of these tools in the work area is prima facie evidence of use.
- The inspection penalty is up to $500 (§ 155A.25, subd. 1a), and a salon, its DLSM, and the practitioner can each be cited (Minn. R. 2105.0115, subp. 4).
- Keeping a blade "only for clients who ask" is not a defense.
Why the Ban Exists
A callus is a protective thickening of the stratum corneum. A blade can slip through it into the living, vascular dermis in a fraction of a second. Open cuts on feet are portals for Staphylococcus aureus (including MRSA), Pseudomonas aeruginosa, and the waterborne Mycobacterium fortuitum linked to pedicure-basin outbreaks. Clients with diabetes or peripheral arterial disease may not feel the cut and heal slowly, so a small wound can become an ulcer.
What Is Allowed
- Callus softeners (keratolytic products) used according to the manufacturer's directions.
- Sanding, buffing, or filing with foot files. Under Minn. R. 2105.0375, subp. 13, files are single-use unless made of metal, glass, or crystal (ceramic files are single-use unless completely sealed by glaze), and disposable abrasive pads or sleeves are single-use.
- Pumice bars or stones are single-use and go in the trash after one client.
Minnesota bans callus rasps and graters, which are designed to cut skin. A narrow metal nail file that smooths the toenail's edge in the groove is a nail implement, not a skin-cutting grater; it must still be cleaned and disinfected between clients.
4. New Services, Products, and Devices (Minn. R. 2105.0190, subp. 1a)
Before offering any product, technique, device, or equipment that is new to you, you must:
- Ensure it is within your scope of practice under Minn. R. 2105.0105;
- Review and follow the manufacturer's directions, safety requirements, and contraindications;
- Keep a record of any training on it for as long as you use it; and
- Attest that you have the knowledge and training to provide the service safely.
Electric or battery-operated files or drills not specifically manufactured for use on humans are prohibited (Minn. R. 2105.0377, item F), so a hardware-store rotary tool is never acceptable.
5. Open Wounds, Diagnosis, and Referral
Minn. R. 2105.0375, subp. 7, item G states that licensees must not perform services on clients with open wounds or sores in the area of the body to be serviced. Nail technicians are also licensed only for cosmetic care, so they do not diagnose or treat disease.
Refer and do not service the affected area when you see pus, oozing, open sores, weeping fissures, marked redness with heat and swelling, or signs of infection such as a thickened, crumbling, discolored plate or scaling between the toes.
A professional refusal:
- Speak privately and calmly.
- Describe what you see without naming a disease: "The skin around this nail is red, swollen, and open."
- Explain the rule: "Minnesota's rules don't allow me to work on an area with an open wound or sore."
- Recommend a physician or podiatrist and offer to rebook once the area has healed.
- If an unexpected cut occurs during a service, stop and follow the blood-exposure steps in Minn. R. 2105.0375, subp. 5 (Section 3.3).
Under Minn. Stat. 155A.355 and Minn. R. 2105.0377, which item may not even be present in a Minnesota salon?
A glass foot file that is cleaned and disinfected between clients
A credo blade or razor-type callus shaver
A pumice stone that is discarded after one client
A callus-softening product used according to the manufacturer's directions
Which service is outside the scope of a Minnesota nail technician license?
Massaging a client's lower legs during a pedicure
Applying and removing acrylic enhancements
Waxing the hair on a client's toes during a pedicure
Giving a paraffin treatment to the hands
A client arrives for a manicure with a red, swollen fingertip and pus along the nail fold. What must the Minnesota nail technician do?
Decline to service the affected area, avoid naming a diagnosis, and recommend the client see a physician
Clean the area with alcohol, apply an over-the-counter antibiotic, and continue
Cover the area with an enhancement to protect it while it heals
Complete the service wearing two pairs of gloves
A nail technician wants to add a new electric callus-smoothing device. Under Minn. R. 2105.0190, subp. 1a, what must happen before the first client?
The salon must file the device's invoice with the Board and wait for written approval
The technician needs only the client's signed waiver
The technician must complete a 40-hour podiatry course
The technician must confirm the service is within scope, follow the manufacturer's directions and contraindications, keep training records, and attest to being trained
Sections you finish are checked off in the contents.