3.5 New York Implement Reprocessing and Prohibited Items (§§ 160.17, 160.18)

Implement Reprocessing and Prohibited Items

Exam Focus: This section produces more written-exam items and more inspection citations than any other in Part 160. Memorise the three reprocessing classes in § 160.17(c), the 10-minute and 10-hour figures, and the full § 160.18 prohibited list. Remember § 160.18(b): mere presence of the banned items is presumptive evidence of use.

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1. Multi-Use vs. Single-Use Implements

Cosmetology implements fall into two distinct regulatory categories:

          ┌───────────────────────────────────────────────┐
          │             IMPLEMENT CATEGORIES              │
          └───────────────────────┬───────────────────────┘
                                  │
         ┌────────────────────────┴────────────────────────┐
         ▼                                                 ▼
 ┌───────────────────────────┐             ┌───────────────────────────┐
 │   MULTI-USE (Nonporous)   │             │    SINGLE-USE (Porous)    │
 ├───────────────────────────┤             ├───────────────────────────┤
 │ • Stainless steel shears  │             │ • Emery boards & buffers  │
 │ • Metal cuticle nippers   │             │ • Orangewood sticks       │
 │ • Hard plastic combs      │             │ • Cotton balls & rounds   │
 │ • Clipper guards & bowls  │             │ • Neck strips & end wraps │
 │                           │             │ • Wooden wax spatulas     │
 │ ACTION: Clean + Disinfect │             │                           │
 │ after EACH client.        │             │ ACTION: DISCARD in trash  │
 └───────────────────────────┘             │ immediately after 1 use.  │
                                           └───────────────────────────┘

• Multi-Use (Reusable / Nonporous): Fabricated from solid, non-absorbent materials (stainless steel, glass, hard plastic). Must be thoroughly cleaned with soap and water, dried, and completely immersed in EPA-registered disinfectant between every client.
• Single-Use (Disposable / Porous): Fabricated from absorbent materials (wood, cardboard, paper, cotton, porous foam). Cannot be properly disinfected because pores harbor microbial pathogens. Must be discarded into a covered waste container immediately after a single client use.

Waxing Rule: "Double-dipping" a wooden wax spatula into a communal wax pot is strictly illegal. A new disposable spatula must be used for every single dip into the wax container.

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2. Step-by-Step Multi-Use Implement Disinfection

To achieve certified disinfection under New York State inspection standards, follow this exact sequence:

1. Pre-Cleaning: Thoroughly wash implements with warm water, liquid antibacterial soap, and a clean nylon scrub brush to mechanically remove all hair, oil, product buildup, and organic debris.
2. Rinsing & Drying: Rinse tools thoroughly under running water and dry completely with a clean disposable towel. Note: Wet tools dilute the disinfectant solution, compromising its concentration and efficacy.
3. Complete Immersion: Submerge completely cleaned, open implements into a covered receptacle containing fresh EPA-registered disinfectant. All surfaces, including hinges, pivot screws, and cutting edges, must remain fully submerged for the manufacturer's specified contact time (10 minutes).
4. Removal: Using clean tongs, gloved hands, or a draining basket, remove the implements from the disinfectant bath.
5. Rinsing & Drying: Rinse implements thoroughly under running water (if required by the manufacturer) and dry with a clean paper towel.
6. Storage: Store disinfected tools in a clean, dust-free, covered, and clearly labeled storage container marked "Clean / Disinfected Implements." Soiled tools awaiting cleaning must be placed in a separate container labeled "Soiled / Contaminated Implements."

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3. Prohibited Implements in New York State (19 NYCRR § 160.18)

Under New York State General Business Law and Appearance Enhancement Regulations (19 NYCRR § 160.18), the following implements and practices are strictly prohibited in any licensed salon or spa:

• Credo Blades, Razor Callus Shavers & Graters: Any tool intended to cut or shave living calloused skin is illegal. Callus reduction must be performed solely through chemical keratolytic softeners, exfoliating scrubs, or foot files/pumice stones.
• Alum Sticks & Solid Styptic Pencils: Solid styptic pencils cannot be disinfected between clients and can transfer bloodborne pathogens. Only single-use disposable liquid styptic, styptic powder, or spray antiseptics applied with a single-use cotton swab are permitted.
• Methyl Methacrylate (MMA) Monomer: Liquid acrylic nail monomer containing MMA is banned due to extreme nail plate damage, severe allergic contact dermatitis, and respiratory toxicity. Only Ethyl Methacrylate (EMA) formulations are legal.
• Chamois Buffers: Traditional leather buffers cannot be disinfected and are prohibited.
• Roll-on Wax without Disposable Cartridges: Reusable roll-on wax heads that directly contact client skin are prohibited.

4. The § 160.17(c) Reprocessing Standard in Full

New York writes three separate reprocessing rules by implement class. Learn them as sequences, because the exam tests the order.

Class 1 — implements used on the hair (§ 160.17(c)(1)): combs, brushes and other implements used on the hair.

1. Clean with warm water and soap or a detergent to remove all hair and scalp debris
2. Rinse thoroughly
3. Dry with clean toweling or other absorbent material
4. Completely immerse in an EPA hospital-grade disinfectant, soaking for 10 minutes or more
5. Remove, rinse, dry
6. Store in a drawer, cabinet or covered container

Class 2 — implements that may abrade or clip superficial layers of skin (§ 160.17(c)(2)): electric razor heads, cuticle scissors and the like.

1. Clean with warm water and soap or detergent
2. Rinse thoroughly, dry
3. Completely immerse in an EPA-approved hospital-grade disinfectant in accordance with the manufacturer's recommendations for that implement, and no less than 10 minutes
4. Rinse, dry, store in a drawer, cabinet or covered container

Class 3 — implements intended to penetrate skin or enter pores (§ 160.17(c)(3)):

• Single-use disposable, or
• Thoroughly cleaned with warm water and soap or detergent, rinsed, and sterilised after each client use. Implements to be autoclaved must be packaged prior to sterilisation.
• § 160.17(b): sterilisation means autoclaved or immersed for no less than 10 hours in an EPA-registered liquid sterilant.

5. Transport and Remote Locations

§ 160.17(e) covers services performed away from the licensed premises, permitted under § 160.8:

• All supplies and implements shall be transported to and from the remote location in covered containers.
• Clean implements and supplies, including towels, shall be kept in containers separate from those that have been used, and the containers marked according to their status.

One bag for clean, one bag for dirty, both covered, both labelled. Nothing travels loose.

6. The § 160.18 Prohibited and Restricted List

Two of these are worth extra attention.

Credo knives and chamois buffers are prohibited because both remove living tissue. A credo blade cuts callus, which means it cuts skin; a chamois buffer is porous and cannot be disinfected. Pumice stones are porous for the same reason. The professional alternatives are a disposable foot file or a properly disinfectable non-porous implement.

Styptic pencils are banned twice over — once in § 160.18(a)(10) and again in § 160.19(d), which requires any material used to stop the flow of blood to be disposed of immediately after use in a sealable rigid container, or to be in liquid or powder form. A shared solid styptic pencil touches an open wound and then touches the next client's open wound.

§ 160.18(b) — the presence in the workplace of chamois buffers, pumice stones, credo knives, common shaving mugs, non-disposable powder puffs, non-immersible neck dusters, sponges and styptic pencils is presumptive evidence of their use. There is no "we keep it but never use it" defence.