Public Meeting with Permanent Makeup Artists
6/2/2014
Introduction. Minnesota Department of Health (Department) began regulating the practice of body art
in January 2011. Since this time, both the Department and body artists have had enough experience
with the body art law to realize that thoughtful amendments may be able to make regulation more
protective of the public, less burdensome for artists, and more efficient for the Department to
implement.
In spring of 2014, the Department hosted two public meetings: one for traditional body artists and one
for permanent makeup artists. The purpose of these meetings was to get input from artists and other
stakeholders about regulatory changes the Department is considering proposing and to learn what
changes artists and other stakeholders suggest. The same broad areas were addressed at each meeting.
The Department used specific questions to elicit comments, but encouraged whatever discussion arose
from those questions. Below are notes from the meeting for Permanent Makeup Artists. (Notes from
the meeting for traditional body artists.)
Notes
Supervision, Training, and Permanent Makeup Schools
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Supervision is not clearly defined in statute.
o This needs to be clarified. People are paying me to supervise them.
Person being supervised should be my priority. Their work reflects on me.
I charge $1000 per day for training.
Is supervision necessary?
o I’d been tattooing for four years before I started doing permanent makeup. As an artist,
you’re responsible for your own work.
o Medical students have to complete residency; are we different?
o I would have like to have supervision.
How long does someone need to be supervised?
o Can’t imagine a body artist standing and watching a procedure after the first two.
o Length of time for supervision is too much.
o 200 hours isn’t that much. We’re working on people’s faces. Our training and standards
should be at least as high as for the “artistic” tattooists.
o Permanent makeup artists need permanent makeup skills, plus blood borne pathogen
training, plus knowledge about skin.
 200 hours is not a lot.
 Cosmetology requires 350 hours to cut a cuticle and 1200 to color hair.
 Licensed cosmetologist commented that she was required to have 1500 hours
of training when she went to school.
o 200 hours isn’t enough time. Training makes our industry strong.
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Training requirement is not rational or constitutional.
It doesn’t take 200 hours to teach people to wash their hands.
Can’t put everyone in the same box in terms of how much training/supervision is
necessary.
o Traditional body artists suggested 1000 hours.
 Too much.
No real difference between us and “artistic” tattooists – except that we work on faces and
sometimes chests and may be paid by insurance.
Problem with supervision – we’re not required to have a permanent makeup person as our
supervisor. What’s the advantage of having a regular body artist supervise you?
No reason to prohibit supervising while training to learn different modality.
Comments about blood borne pathogen training
o APT course was incredible. It was really scary. Had I known this before I started doing
permanent makeup, I probably would not have gone into this business. Should have to
take the APT course before they start.
o Another participant mentioned training with David Vidra, an OSHA instructor who does
a 4-6 hour course.
o I was a nurse; my blood borne pathogen training course was 30 hours. Does it take 1000
hours to enforce and learn infection control?
o Need to separate blood borne pathogen training and supervision.
Comments about trainee schooling and experience in the context of supervision
o Contrast with an experienced person – I don’t oversee them as they work, but I am
responsible for their work.
o I had a trainee from Wyoming – she had done one procedure every four months.
o Different procedures required in different states.
o Don’t need someone standing over you if you’ve been to school.
o Most schools are just doing a weekend. We shouldn’t have to be responsible for the
work of people who have only done one eyeliner and one eyebrow. Schools do not
teach biohazards and sanitation.
o A weekend course is not enough.
Comments about schooling, generally
o We need a school. (Repeated.)
o I used to teach at Wadena, but the program was discontinued.
o Needs to be a curriculum.
 Look at Dept. Edu. Department of Higher Education – if > 16 hours of training,
the Dept requires a license.
o There are people coming out of schools who don’t know blood borne pathogens
regulations.
Had a permanent makeup association in another state.
Training
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I had good basic training, in a shop. I was better after 200 hours and way better after
800 hours.
o In terms of training, I don’t want to see any difference between “artistic body art” and
permanent makeup.
o It’s difficult to get good training. Trainers need to be paid.
Most of what I’m hearing is about quality. The focus should be on infection control.
Competency needs to be part of the hours.
Comments about organization of regulation.
o Permanent makeup should have a state board. The Health Department should not be
regulating this.
o We should be with cosmetology.
o Can’t even reach board of cosmetology.
o Need permanent makeup society in MN – used to be one.
My malpractice is the same as an RN’s.
Reciprocity
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Requirement of 200 hours is extremely problematic when it comes to people coming from other
states.
How does reciprocity law read in other states?
There are no laws in Wisconsin.
Should have people test out – do a 40 hour testing period with designated pm artists.
Should require an 8 hour blood borne pathogen course and supervised training for people for
people coming in from out-of-state.
Doing permanent makeup does not make you an artist.
When defining a standard, you have to talk to people who are already in the practice.
When people come from other states, you don’t know what they’re coming from. Some training
is really good.
If you’re from out-of-state, you have to find a supervisor in Minnesota. Just like if you’re brand
new out of school – you need 200 hours.
Not impossible to find a supervisor.
Testing
o “Testing out” is subjective.
o Should be competency-based testing.
Establishments
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Concerns about requirements for relicensing establishment upon new owner or location
o Wants to transfer license to new location –
o Only operated at one location
o Building sold the same month she was inspected. Does not want to pay for new license.
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Suggestions
 Charge for inspection fee only if establishment moves during license period
• Edina charges $300/month
Should licensing be yearly?
o Yes – too hard to come up with full amount all at once. Several people thought every
three years was too infrequent.
o No – will cost MDH more to license every year and costs will be passed on; don’t want to
be inspected more often.
o Survey by show of hands – 7 people want yearly licensing; 7 people did not vote.
Amount of fees
o Fees are too high.
o Maybe fee should depend on size of the establishment – that is the number of people
working there. Small food establishments pay less than large food establishments.
o Inspection fee should be same as for temp event.
Operating in an unlicensed establishment should be a misdemeanor
“Lack of anything being done by MDH”
Should lapsed establishments be treated differently than unlicensed establishments?
o Lapsed establishments should be allowed maybe one month, because unforeseen
disasters do occur
o Should look at cosmetology licensing to see how they treat lapse and also for fines and
penalties
Penalties
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MDH should be allowed to deny license based on past discipline of owner.
Should operating in an unlicensed establishment be a misdemeanor.
o Yes.
Should corrective action be allowed in lieu of discipline?
o Yes .
o Look at cosmetology.
Group suggested grace period for a lapsed establishment, as contrasted with a never-licensed
establishment.
Temporary Events
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Should there be a fee increase to cover costs?
o Yes.
o $220
Should there be a limit on how many events a sponsor can have in one year or how long a
temporary event should last?
o 14 days
Should all events be inspected?
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o Don’t need to inspect every event in state.
o But isn’t that where most violations would occur?
Should there be a limit to the number of temp events one person or entity can host in a year?
o If you raise the fee, there will be fewer.
Temporary events should not be allowed. Should require an establishment license to do a
temporary event.
Health and Safety
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Blood borne pathogen training
o Should online Blood borne pathogen (BBP) training be allowed?
 If not online, has to be more than one hour per year
 This is 2014 – we need to allow online training.
o MDH should create a list of satisfactory BBP courses.
o Recertification should require BBP contact hours.
o Really need a 6-8 hour BBP class for an initial license.
o The only continuing education required should be BBP.
Red Cross requires people who have received permanent makeup to wait before donating blood
– but people who have had an “artistic” tattoo don’t have to wait.
Inks should be different.
Inspections
o I was told I had to change out my ceiling – that textured ceilings are not allowed.
o State should check with Hennepin County.
o Should be treated like inspection of medical clinic.
Have there been fewer infections or blood-bank diseases since licensing?
o Most tattoos from body art are “routine” infections, not the infections you read about
in the news. Even if a person whose tattoo gets infected sees a doctor, “routine”
infections are not tracked or reported to the health department.