11.5 Client Consultation and Preliminary Procedures for Colour

Key Takeaways

  • The predisposition or patch test is applied behind the ear or on the inner elbow 24 to 48 hours before each application of aniline derivative colour.
  • A positive patch test — redness, itching, burning, blistering or swelling — means the service must not be performed.
  • The patch test requirement flows from the coal-tar hair dye labelling condition in the Federal Food, Drug, and Cosmetic Act, and is repeated before every application because sensitisation can develop at any time.
  • A preliminary strand test predicts the finished colour, the processing time and the condition of the hair after processing.
  • 19 NYCRR § 160.27(e) prohibits applying dye of any kind to eyelash or eyebrow hair, except FDA-listed silver nitrate additives under 21 CFR § 73.2550.
Last updated: August 2026

Client Consultation and Preliminary Procedures for Colour

Exam Focus: The patch test is the most heavily tested safety procedure in the colour subject. Know where it is applied, how long before the service, what a positive reaction looks like, and — critically — that it is repeated before each application rather than performed once. Know also the New York eyelash and eyebrow rule, which has no equivalent in most states' curricula.


1. The Colour Consultation

A colour consultation answers five questions before any product is mixed.

  1. What does the client actually want? Use the client's own hair in the mirror and a swatch or photograph, and translate the request into level and tone — "warmer, two levels lighter, with the ends kept dark" — rather than a brand name or a photograph alone.
  2. What is on the hair now? Natural level, existing artificial colour and where it sits, previous lightening, henna, box colour, colour-depositing shampoos, gradual colour restorers. Ask specifically; clients do not volunteer this.
  3. What is the hair's condition? Texture, density, porosity, elasticity, and the presence of any previous chemical restructuring. Chapter 6's tests apply directly.
  4. What is realistic in one appointment? A level 3 box-coloured client asking for level 9 blonde is a multi-session plan, and saying so at the consultation rather than at hour four is a professional duty under Chapter 1's honesty and transparency standard.
  5. What is the maintenance commitment? Regrowth interval, toner refreshes, at-home products, and cost. A client who cannot maintain a colour should be steered to one they can.

Grey coverage

Assess the percentage of grey and its distribution. Resistant grey — often coarse, low-porosity and concentrated at the front hairline and temples — may need pre-softening, a higher proportion of natural or neutral base in the formula, or a longer processing time. The natural pigment level of the non-grey hair still determines the underlying pigment that will be exposed.

2. The Predisposition (Patch) Test

Where the Predisposition Test Comes From

The patch test is not imposed directly by Part 160, and the Federal Food, Drug, and Cosmetic Act does not order practitioners to perform one either. Its force is indirect and worth stating precisely, because the exam and the real world both reward the accurate version. Oxidative colour uses aniline derivative dye precursors such as para-phenylenediamine (PPD), which the FD&C Act treats as coal-tar hair dyes. Those dyes are exempt from the colour additive approval requirement only if the label carries the prescribed caution statement and adequate directions for a preliminary patch test (section 5.3). The manufacturer therefore instructs a patch test on every label, and 19 NYCRR § 160.26 requires that original manufacturer labelling stay intact so those directions remain available in the salon. Skipping the test means departing from the manufacturer's directions on a sensitising chemical, which is the negligence standard a hearing officer or a court will apply.

The Predisposition Test (Patch Test / Skin Allergy Test)

Perform it for every haircolour containing aniline derivative dye precursors, before every application rather than once per client.

┌─────────────────────────────────────────────────────────────────────────────┐
│                    MANDATORY PREDISPOSITION PATCH TEST                      │
├─────────────────────────────────────────────────────────────────────────────┤
│  1. Timing: Must be performed 24 to 48 hours PRIOR to every color service.  │
│  2. Location: Behind the ear (mastoid area) OR inner bend of the elbow.     │
│  3. Product: Exact mixed color formula and developer to be used.            │
│  4. Observation: Leave uncovered for 24-48 hours. Check for reaction.      │
│  5. NEGATIVE Reaction: Skin clear; no redness/edema ──> Service PROCEEDS.   │
│  6. POSITIVE Reaction: Redness, swelling, itching ──> SERVICE IS CANCELLED! │
└─────────────────────────────────────────────────────────────────────────────┘

Clinical Predisposition Protocol

  1. Wash a 1-inch square area behind the ear or in the inner fold of the elbow with mild soap and water; pat dry.
  2. Mix a small amount of the exact haircolor product and developer in a clean glass bowl.
  3. Apply a small dab of the mixture to the test site using a sterile cotton-tipped swab.
  4. Leave the test site undisturbed and uncovered for 24 to 48 hours.
  5. Evaluate the Results:
    • Negative Reaction: No sign of inflammation, erythema (redness), edema (swelling), itching, burning, or blisters. The cosmetologist may proceed with the color service.
    • Positive Reaction: Redness, hives, swelling, rash, or severe itching. The color service must NOT be performed under any circumstances. The client must be referred to a dermatologist.

The Preliminary Strand Test

A Preliminary Strand Test is performed on a small 1/2-inch subsection of the client's hair prior to full-head application to determine:

  • Exact processing time required for full oxidation.
  • How the color formulation reacts with existing artificial dye or porous hair.
  • Final target tone and lightness results.
  • Physical integrity, elasticity, and condition of the hair shaft under chemical processing.

General colour safety rules

  • Never apply color if the client has scalp abrasions, open lesions, or contagious skin disorders.
  • Always wear protective chemical-resistant nitrile gloves.
  • Do not mix color formulas in metallic bowls or use metal hair clips (metal causes rapid oxidation of developer).
  • Protect the client with a sanitary neck strip, drape, and protective barrier cream around the hairline.

3. The New York Eyelash and Eyebrow Rule

19 NYCRR § 160.27(e) — no appearance enhancement licensee is authorised or permitted to apply dye of any kind to eyelash or eyebrow hair, with one exception. Products containing silver nitrate colour additives authorised by the FDA under 21 CFR § 73.2550 may be used to tint eyelash or eyebrow hair, and must be applied exactly as the manufacturer directs.

This aligns with the federal caution statement on every coal-tar hair dye label, which states that the product must not be used for dyeing the eyelashes or eyebrows and that to do so may cause blindness. The rule is absolute regardless of how a product is marketed, how experienced the practitioner is, or whether the client requests it and offers to sign a waiver.

4. Documenting the Preliminary Procedures

Record on the client card, every time:

  • the date and result of the patch test, and who performed it;
  • the date, formulation, developer volume, processing time and result of the strand test;
  • the client's stated goal and the plan agreed, including how many sessions;
  • the natural level, the level and tone of any existing artificial colour, and the percentage of grey;
  • porosity and elasticity findings;
  • any decision to decline or modify a service, and the reason given.

If a client later reports a reaction, that record is the evidence that the required preliminary procedures were performed.

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Mandatory Salon Safety Testing & Corrective Workflow
Test Your Knowledge

According to U.S. FDA regulations and New York State appearance enhancement laws, how far in advance must a Predisposition (Patch) Test be administered before applying an aniline derivative haircolor?

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Test Your Knowledge

Where should the Predisposition (Patch) Test be applied on a client's body?

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Test Your Knowledge

How often must a predisposition (patch) test be performed for a client who receives permanent aniline derivative colour every six weeks?

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Test Your Knowledge

A client asks a New York cosmetologist to tint her eyebrows with the same permanent colour used on her hair. What does the law require?

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