2.3 Scope of Practice, Specialty Licenses & HB 2141 Carve-Outs
Key Takeaways
- OAC 175:10-7-29 puts services that puncture the skin outside Cosmetology and Facialist/Esthetician scope, including permanent makeup, microblading, microneedling deeper than 0.25 mm, lasers, FDA Class 3 devices, and tattoo or skin-tag removal.
- Chemical peels used by Cosmetologists or Facialists/Estheticians are generally 30% solution or less at final formulation, or pH not less than 3, unless every listed manufacturer-documentation exception is met.
- Microdermabrasion devices must be Food and Drug Administration (FDA) Class 1 or Class 2, with a training-proficiency certificate prominently displayed for each type used; Class 3 microdermabrasion is prohibited.
- HB 2141 (Laws 2024, c. 282) removes a license requirement for persons who only shampoo or only hair-braid, and creates a Blow-Dry/Styling certificate path posted at $80; NIC theory still includes shampooing and natural styling for cosmetology candidates.
- Methyl methacrylate (MMA) is prohibited; credo blades, cheese graters, and rasps are prohibited; fish pedicures are prohibited; styptic pencils and lump alum are prohibited.
2.3 Scope of Practice, Specialty Licenses & HB 2141 Carve-Outs
Quick Answer: An Oklahoma Cosmetology license covers hair, cosmetic skin, and nail work that does not puncture the skin. Permanent makeup, microblading, microneedling deeper than 0.25 mm, lasers, and Food and Drug Administration (FDA) Class 3 devices are out. HB 2141 lets a person only shampoo or only braid without a license, but the National-Interstate Council of State Boards of Cosmetology (NIC) theory exam still asks shampooing and natural-styling items of cosmetology candidates.
What Cosmetology includes
59 O.S. § 199.1 and the OSBCB Cosmetology license page describe Cosmetology as the usual work of beauticians and hairdressers: bleaching, cleansing, curling, cutting, coloring, dressing, removing, singeing, styling, waving, or similar work upon the hair by hand or by mechanical or electrical appliances. The Act also reaches nonpermanent hair removal without puncturing the skin and cosmetic work on the scalp, face, neck, arms, and nails, including manicuring — exclusive of practices that belong to the healing arts.
OAC 175:10-7-29 restates that Cosmetology expressly does not include services that puncture the skin or that sit inside the healing arts. For the Act, puncturing the skin means perforating the skin by any means, including:
- Permanent makeup
- Microblading (pigment scratched into the skin with a hand tool whose blade is formed of tiny needles)
- Microneedling (collagen induction) that creates microchannels deeper than 0.25 mm
- Lasers; ultrasound and high-intensity focused ultrasound (HIFU); radiation; plasma pen; injections, including needle-free injection devices; and FDA-approved Class 3 medical devices
- Cryolipolysis (fat freezing)
- Dermabrasion (sanding or scraping top skin layers with a specialized instrument)
- Removal of tattoos, skin tags, moles, or angiomas
Those services are beyond both a Cosmetology license and a Facialist/Esthetician license (OAC 175:10-7-29(a)(2)). Refer them. Do not rebrand them as a facial add-on.
Devices and peels that stay in cosmetic skin care
OAC 175:10-7-29(b) lists esthetic devices intended for cosmetic skin care, beautifying, and improving appearance, including galvanic current, high frequency, mechanical brushes, vacuum spray, steamers, micro current, microdermabrasion devices, low-level radio frequency, light-emitting diode devices (including intense pulsed light), and metal extractor tools.
Cosmetologists and Facialists/Estheticians may only exfoliate stratum corneum cells. With proper training they may use chemical, mechanical, or electrical services to exfoliate that layer, including alpha hydroxy acids (glycolic and lactic), beta hydroxy acids, salicylic acid, Jessner's solutions, and resorcinol — provided chemical peels are mixed and used at an ingredient concentration of thirty percent (30%) solution or less at final formulation, or with a pH value not less than three (3), unless all of these manufacturer exceptions are met (OAC 175:10-7-29(c)(1)):
- The peel is a commercially available product approved for Cosmetologists and/or Facialists/Estheticians.
- The licensee can document from the manufacturer that the specific product does not penetrate below the stratum corneum when used as directed.
- The licensee can document training and/or certification in that product.
- The licensee follows all manufacturer directions.
- The preparation is stored to specification and discarded after expiration.
Microdermabrasion: equipment must be an FDA Class 1 or Class 2 device. The Cosmetologist or Facialist/Esthetician must prominently display a certificate of training proficiency for each type of microdermabrasion equipment used. Class 3 FDA-approved devices for microdermabrasion are prohibited (OAC 175:10-7-29(c)(2)). Licensees using any device, chemical, or product must follow manufacturer directions for use, storage, and disposal.
Related license limits in OAC 175:10-9-55: threading may be performed by a licensed Facialist/Esthetician, Cosmetologist, Threading Technician, or Barber. Eyelash extensions may be performed by a licensed Facialist/Esthetician, Cosmetologist, or Eyelash Extension Specialist. Body sugaring may be performed by a licensed Facialist/Esthetician, Cosmetologist, or Barber.
HB 2141 carve-outs: two layers of the same topic
HB 2141 (Laws 2024, c. 282) changed who must hold an Oklahoma license. Study both layers.
Layer 1 — Oklahoma occupation law (what you may do without an OSBCB license). 59 O.S. § 199.1 and § 199.6(E) now exclude:
- Shampooing as a standalone occupation: washing or cleaning hair with shampoo, conditioner, and drying, which may use topical agents such as balms, oils, and serums, including on extensions, hair pieces, and wigs. Shampooing does not include cutting hair or applying dyes, bleach, reactive chemicals, keratin treatments, or other preparations that color or alter hair structure. A person solely practicing that definition shall not be required to hold a license or certification.
- Hairbraiding as a standalone occupation: twisting, wrapping, weaving, extending, locking, or braiding by hand or with mechanical devices, including natural or synthetic extensions, fibers, beads, accessories, and making wigs. Topical agents such as conditioners, gels, moisturizers, oils, pomades, and shampoos are included. Hairbraiding does not include dyes, reactive chemicals, or other preparations that color, straighten, curl, or alter structure, and it does not include chemical hair-jointing agents such as synthetic tape, keratin bonds, or fusion bonds. Hairbraiding is not the practice of cosmetology. A person solely practicing that definition needs no license or certification. 59 O.S. § 199.6(E)(6)–(7) repeats the exemptions for persons performing shampooing services and no other licensed services, and persons performing hairbraiding services.
Layer 2 — Cosmetology theory content (what a Cosmetology candidate is still tested on). Independent OpenExamPrep teaching for Oklahoma candidates: the NIC theory examination used for Cosmetology candidates still includes shampooing and natural styling. Deregulation of those tasks as standalone Oklahoma occupations does not delete them from a full Cosmetology candidate's national theory items. If you sit the Cosmetology theory exam, study shampoo draping, product choice, and natural styling even though Oklahoma will not ticket a shampoo-only or braid-only worker for lacking a Cosmetology license.
Specialty certificates the homepage still prices at $80
| Certificate | Instruction in HB 2141 / 59 O.S. § 199.1 | Establishment license for a shop that offers only that service? |
|---|---|---|
| Blow-Dry/Styling | At least 12 hours of general safety and sanitation, 4 of those hours on mechanical devices for drying, curling, straightening, or styling | No establishment licensing and inspection under the Act |
| Makeup Artist | At least 8 hours of general safety and sanitation; makeup is cosmetics such as powder, foundation, rouge, eyeshadow, eyeliner, mascara, or lipstick, including airbrush; not permanent makeup or tattooing | No establishment licensing and inspection under the Act |
| Eyelash Extension Specialist | Enrolled HB 2141 new 59 O.S. § 199.19: at least 120 hours of training with a certified eyelash extension instructor. An instructor certificate needs those 120 hours plus at least 60 hours of eyelash extension application services. Establishment licensing is required where eyelash extensions are performed (§ 199.19(F)). Conflict to label: § 199.1 definitions say the specialist and instructor shall pass a state written safety/sanitation exam, while § 199.19(D) says the Board shall not require an examination. Do not treat eyelashes as unlicensed shampooing. | Yes — § 199.19(F) requires establishment licensing and inspection |
Blow-dry styling means shampooing, conditioning, drying, arranging, curling, straightening, or styling hair using mechanical devices, hairsprays, and topical agents (balms, oils, serums), including styling extensions, hair pieces, and wigs. It does not include cutting hair or applying dyes, bleach, reactive chemicals, keratin treatments, or other preparations for coloring and altering hair structure. Homepage fee for Blow-Dry/Styling, Makeup Artist, and Eyelash Extension Tech certificates: $80 biennial on the Board homepage. Section 199.19(E) still says an eyelash specialist certificate shall be renewed annually; treat that as leftover annual wording next to the November 2025 two-year table.
A master cosmetologist is a licensee who has practiced cosmetology for a cumulative 15 years and requests the master-level license; a master may instruct no more than two registered apprentices at a time (HB 2141). Master Cosmetologist posts at $80 on the homepage; Master Cosmetology Instructor posts at $130.
Tools and services Oklahoma bans in the salon
These bans are safety items, not fashion opinions:
- Methyl methacrylate (MMA) is prohibited in manicuring products (OAC 175:10-7-14). If the label is silent, contact the manufacturer for content before use.
- Credo blades or any implement used to remove skin such as razors, cheese graters, and rasps are prohibited (OAC 175:10-7-30(e)).
- Fish pedicures and the use of fish or other animals to perform a service are prohibited; service animals under the Americans with Disabilities Act (ADA) are not banned as pets (OAC 175:10-7-25).
- Styptic pencils and lump alum are prohibited; use liquid or powdered astringent on separate, clean, sterile gauze or cotton, then dispose of it (OAC 175:10-7-18(c)).
Kiosk reminder from Section 2.2: even a licensed kiosk may not run chemical hair services. Color, bleach, keratin, and relaxers belong in a full Establishment with proper plumbing and wet/dry disinfection — not a mall cart.
Official sources for this section
- OAC 175:10-7-14, 175:10-7-18, 175:10-7-25, 175:10-7-29, 175:10-7-30, 175:10-7-32, 175:10-9-55
- 59 O.S. §§ 199.1, 199.6, 199.19; enrolled HB 2141 (Laws 2024, c. 282)
- OSBCB Cosmetology license page
Which service is outside Oklahoma Cosmetology and Facialist/Esthetician scope under OAC 175:10-7-29 because it punctures the skin?
Unless every manufacturer-documentation exception in OAC 175:10-7-29 is met, a chemical peel performed by a Cosmetologist or Facialist/Esthetician must be which of the following?
After HB 2141, which statement is accurate about shampooing in Oklahoma?
Which combination is prohibited in an Oklahoma Establishment?