2.7 Service Records, Product Dispensing & Personal Hygiene Standards

Record Keeping

The content outline lists Record keeping as its own sub-item under client contact and communication. The reason is practical: in a licensing dispute, an injury claim, or a Board investigation, the service record is the only evidence that the licensee did the right thing.

What Belongs on a Client Service Record

Write the refusal down. When you decline a service because of a contraindication, the record entry — date, observation, action taken, referral made — is what protects the licensee later. An undocumented refusal looks identical to no appointment at all.

The § 7.82 Outside-Service Record

Records take on a specific regulatory form when the service leaves the building. Under 49 Pa. Code § 7.82, a licensee who renders licensed services outside the salon shall maintain at the employing salon complete records for each service rendered outside the salon, including:

• the date
• the time
• the place
• the fee charged

The regulation adds that this record "shall be considered part of the records of the salon," and § 7.83 makes the salon responsible for ensuring licensees are fully supplied and equipped and that all other Chapter 7 requirements are met during outside services. Under the Act 48 schedule at § 43b.5, failure to maintain the record of services rendered outside a shop is cited at $50 for a first offense and $250 for a second.

Records the Salon Itself Must Keep

• The name of the owner or designated person in charge, posted conspicuously (§ 7.62(c)).
• Current licenses and permits available on the premises — cited at $100 then $250 under § 43b.5 (63 P.S. § 524).
• Safety Data Sheets for every hazardous chemical, accessible to employees under the OSHA Hazard Communication Standard.
• Schools keep student records under § 7.119 and transfer-student verification under § 7.119a; failure to maintain student records is a $250 first offense escalating to formal action.

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Dispensing Products Without Contaminating Them

"Dispensing products" appears on the content outline as a sanitation sub-topic in its own right, because the moment of dispensing is where a clean product becomes a contaminated one.

The Governing Rule — § 7.94(c) and (d)

§ 7.94(c): Creams and other semisolid substances shall be removed from their containers with a sterile spatula or similar utensil. The spatula or similar utensil may not be permitted to come into contact with the skin or hair of another client until it is properly disinfected.

§ 7.94(d): An article that has been dropped on the floor or otherwise rendered unsanitary shall be sterilized before it is reused.

Aseptic Dispensing Technique

1. Decant, never dip. Pour or spatula the working quantity into a clean single-use cup, bowl, or palette. The bulk container never receives a used implement, a gloved finger, or a returned surplus.
2. Never return surplus product to the bulk container, even if it never touched the client. It has been exposed to salon air, aerosolized hair, and the working surface.
3. One applicator, one pass, one client. This is the same principle as the waxing no-double-dipping rule: a wooden spatula that has touched skin never re-enters the pot.
4. Use pumps, shakers, and squeeze bottles in preference to open jars wherever the product allows.
5. Keep dispensing surfaces disinfected — the dispensary counter is a client-contact surface under § 7.91(b), which requires all areas of the salon to be maintained in a safe, orderly, and sanitary condition.
6. Mix only what the service needs. Excess mixed oxidative color or disinfectant is waste, and a half-used bowl invites reuse on the next client.

Labeling Every Secondary Container

Whenever a product is transferred out of its original manufacturer container — a diluted disinfectant into an immersion tray, a concentrate into a spray bottle, a bulk shampoo into a back-bar pump — the OSHA Hazard Communication Standard (29 CFR 1910.1200) requires the secondary container to be labeled with the product identity and the appropriate hazard warnings. Pennsylvania reinforces the manufacturer's instructions independently: § 7.96 requires a licensee using a dye, tint, or other chemical to follow the directions of the manufacturer and the FDA regulations and instructions that appear on or within the container or packaging. An unlabeled spray bottle makes compliance with § 7.96 impossible, because no one can prove which product it holds or at what dilution.

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Personal Hygiene of the Licensee (§ 7.95)

The regulation is short and absolute:

"Every salon employee who serves the public shall be clean as to person and dress and shall thoroughly cleanse the hands immediately before rendering services to a client and immediately after using the lavatory."

Note that § 7.95 reaches every salon employee who serves the public, not only licensees — the shampoo assistant is covered. Section 7.97(b) adds a related requirement: a nonlicensed cosmetology shop employee who renders shampoos to clients shall have a physician's certification that the employee does not have an infectious, contagious, or communicable disease.

Handwashing as a Procedure

1. Wet hands with warm running water and apply liquid soap from a pump — never a shared bar.
2. Lather and scrub palms, backs of hands, between the fingers, thumbs, and under the nails for at least 20 seconds.
3. Rinse under running water with fingertips angled downward.
4. Dry with a single-use paper towel.
5. Use the paper towel to turn off the faucet and to open the restroom door.

Hand sanitizer is a supplement, not a substitute: alcohol gels do not remove physical soil, hair clippings, or chemical residue, and they are ineffective against some pathogens. Wash first when hands are visibly soiled.

Professional Presentation and Ergonomic Hygiene

Clean-as-to-dress means laundered work clothing changed daily, closed-toe non-slip shoes in an environment with dropped shears and chemical spills, hair secured away from the face and the client, short clean nails on the working hands, and controlled use of fragrance around clients who may be chemically sensitive. These are not cosmetic preferences — under § 43b.5, individual cleanliness sits in the same regulatory neighborhood as the towel, supply, and equipment sanitation rules that inspectors cite most often.