14/12/2009 To: Dan Crowley, Principal Environmental Health Officer. From: Cora Murray, Senior Environmental Health Officer and Jenny Fortune, Environmental Health Officer. Title: A Survey into the Environmental Health Standards Operating in Beauty Salons, March – April 2009, by the Environmental Health Department, HSE, Co. Donegal. Contents: 1. Introduction 1.1 Regulatory background 1.2 Training 1.3 Case Incidence 1.4 Potential Health Risks 1.5. Role of the Environmental Health Officer 2. Executive summary 3. Scope & Limitations 4. Methodology 4.1 Aims 4.2 Objectives 4.3 Survey development and conduct 5. Results 5.1 EC (Cosmetic Products) Regs., 2004 - 2006 5.2 Microbiological results 5.3 Hygiene standards observed and practices reported 5.3.1. Facilities for Cleaning 5.3.2. Facilities for Hand washing 5.3.3. Laundry 5.3.4. Storage of Equipment 5.3.5. Services – sanitary accommodation, heating, lighting and ventilation 1
Transcript
14/12/2009
To: Dan Crowley, Principal Environmental Health Officer.
From: Cora Murray, Senior Environmental Health Officer and Jenny Fortune, Environmental Health Officer.
Title: A Survey into the Environmental Health Standards Operating in Beauty Salons, March – April 2009, by the Environmental Health Department, HSE, Co. Donegal.
Contents:
1. Introduction
1.1 Regulatory background1.2 Training 1.3 Case Incidence1.4 Potential Health Risks1.5. Role of the Environmental Health Officer
2. Executive summary
3. Scope & Limitations
4. Methodology
4.1 Aims4.2 Objectives4.3 Survey development and conduct
5.3.1. Facilities for Cleaning5.3.2. Facilities for Hand washing5.3.3. Laundry5.3.4. Storage of Equipment5.3.5. Services – sanitary accommodation, heating, lighting and ventilation5.3.6. Policies – disposable gloves, patch tests, personal hygiene5.3.7. Personal Hygiene5.3.8. Waste disposal5.3.9. Equipment for Sterilisation and Disinfection5.3.10. Cleaning of Implements / Tools5.3.11. Practices:5.3.12. After-Care Leaflets:5.3.13. Client Record Cards:5.3.14. Training5.3.15. First Aid Kit:
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5.3.16. Laser and Intense Pulsed Light Treatment:5.3.17. Medical Clinic5.3.18 General Observations
6. Conclusions
7. Recommendations
8. Acknowledgements
9. Appendices
9.1 Description of beauty treatments9.2 Extracts from EC (Cosmetic Products) Regs., 2004 – 2006 9.3. Letter issued to operators prior to survey 9.4 Information sheet accompanying microbiological results 9.5 Information sheet accompanying chemical analysis results 9.6 Detailed Breakdown of Microbiological Results Obtained9.7 Treatments Offered by Beauty Salons9.8 Implementation of Report Recommendations9.9 Abbreviations 9.10 Draft Guide to Good Practice in Beauty Salons
10 References and Bibliography
1.0 Introduction:
At the time of writing (summer 2009), the beauty salon industry in Co. Donegal is thriving with currently approximately 130 beauty salons and 5 beauty therapy training centres known to be operating throughout the county. Beauty salons provide a very wide range of personal body care services ranging from facial and skin treatments such as microdermbrasion, to hair removal by laser and other means, to removal of veins and skin tags. Promises of treatments to remove stretch marks and skin pigmentations abound along with assurances of whiter teeth or removal of bodily toxins by processes such as ‘platinum detox’. A description of some of the treatments on offer is provided in Appendix 9.1. The delivery of treatments inevitably entails much person-to-person contact and the employment of reusable equipment and utensils. Therein lies the potential for cross infection and / or injury to the recipient.
1.1 Regulatory Background:
There is currently no public health legislation governing the operation of businesses such as beauty and nail salons in the Republic of Ireland. Businesses can set up without any legal requirement to enforce standards regarding qualifications of staff, hygiene, maintenance of equipment, personal hygiene of staff, information to be provided to their service users etc.
Other jurisdictions have taken action on controlling standards in such premises e.g.
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1. In the USA, the Iowa Dept. of Public Health inspect and licence premises delivering nail services (Ref1: http://www.emaxhealth.com/57/9116.html) and state inspectors issued 435 citations between June 2005 and July 2006 to South Florida cosmetology shops, which include nail and beauty salons (Ref 2: http://www.sun-sentinel.com/business/custom/consumer/sfl-0121nailsalons,0,1515810.story)
2. In Australia, premises where skin penetration procedures are carried out are registered and regularly inspected by a council's Environmental Health Officers. Procedures performed at these premises include beauty therapy (e.g. cutting of cuticles and skin wicks, removal of dead skin and black head extraction), acupuncture, manicure (including acrylic and gel nails), pedicure, and any other activity, which includes skin penetration.
These premises are inspected for compliance with public health legislation and associated codes and guidelines that deal with issues such as cleanliness, defective construction, sterilisation of equipment and usage practices and personal hygiene of staff (Ref 3: http://www.sutherland.nsw.gov.au/ssc/home.nsf/Web+Pages/6A7DFA8856451040CA256DB800235CC0?OpenDocument#legislation)
3. In the UK and Northern Ireland, Environmental Health colleagues enforce health & safety legislation. Guidelines have been provided on safety in beauty salons including guidelines on hygiene (Ref: http://www.colerainebc.gov.uk/content_gfx/other/Beauty%20S.pdf - ‘Safety in Beauty Salons’). In addition, premises in which certain classes of lasers are required to be registered by Health Authority Inspectors. These premises may include beauty salons, cosmetic clinics and other premises using these lasers for any cosmetic purpose (Ref 4: http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/DH_4009463)
To the best of the authors’ knowledge, beauty salons have not been investigated within the field of Environmental Health in Ireland heretofore. It was therefore decided to carry out an investigation into the standard of hygiene prevalent in beauty salons throughout Co. Donegal. To this end, a survey of 30 salons was undertaken in March – April 2009, details of which are outlined under Sections 4 and 5 below.
1.2 Training:
The National Standards Authority of Ireland have issued ‘I.S. 380: 2007 Beauty & Holistic Therapy – Management of Training Centres’. The Standard provides a management framework for beauty and holistic therapy training centres.
A body called the NABTET Group is an umbrella organisation incorporating:
The National Agency for Beauty Therapy Education and Training
The NABTET Institute of Higher Education FHT (Federation of Holistic Therapies) Ireland (affiliated to FHT UK)
The Group aims to promote best practice and seeks to continue to set and maintain high standards in the delivery of training of teachers for beauty schools within the sector and of beauty therapists also (Ref 5: http://www.nabtetgroup.ie/index.html).1.3 Case Incidence:
The incidence of non-occupational salon-acquired infection or injury is difficult to pinpoint. “It is hard to gather accurate data as to the number of clients and nail technicians who contract infections through nail bars” (Ref. 6: ‘Nail Infection - Tool Kit for Raising Awareness of the Need to Prevent Spread of Infection through Nail Bars’ accessible on the CIEH website). “The risks to patients undergoing procedures such as injectables, peels and lasers are well known although there is no data available on how widespread the resulting health problems may be” (Ref. 7: Beauty Treatments ‘a health risk’, EHN 1 June 2007) However, there is some anecdotal evidence to indicate that unreported incidents may occur or that standards are not satisfactory e.g.
A website blog address entitled ‘Beaut.ie – The Irish Beauty Blog’ reports (1/8/2008) a visit to a beauty salon for a facial resulting in eye damage (Ref. 8 http://beaut.ie/blog/?p=5730). Anecdotal evidence also suggests that a number of cases have been heard in the civil courts in relation to damages incurred by clients in beauty salons. However, it is beyond the scope of this research to substantiate this claim.
‘The Birmingham News’, a newspaper in the USA reported (2006) fungal infections and nail bed damage as a result of treatment at a nail salon (Ref. 9: http://www.beautytech.info/articles/brminghamnews02132006.pdf)
Again, in the US, an outbreak of infection from Mycobacterium fortuitum occurred as a result of clients receiving pedicures with whirlpool footbaths and / or shaving (Ref. 10: Winthrop, K et al “An Outbreak of Mycobacterial Furunculosis Associated with Footbaths at a Nail Salon”, The New England Journal of Medicine - Volume 346:1366-1371; May 2, 2002, Number 18). The infections resulted from failure to clean and disinfect the equipment used.
In 2006, “Skin treatments in a beauty salon likely lead to MRSA transmission as a result of contact with an infected Beautician” in The Netherlands (Ref 11: Huijsdens et al Methicillin-resistant Staphyloccus aureus in a Beauty Salon, the Netherlands, Emerging Infectious Diseases, www.cdc.gov/eid, Vol. 14, No. 11, November 2008, pp 1797-1799). Of a total of 45 people who had been screened, 11 were found to be MRSA positive, 3 of whom were the Beautician and two of her customers, while another 6 people had an indirect link with her. During a visit to her premises, it was noted that the 70% alcohol used to disinfect the skin after waxing was diluted and that she touched the clients waxed skin with ungloved hands to check for remaining hairs and had not washed her hands after removing the gloves.
In the UK, research conducted by Bristol City Council indicated that out of 45 nail salons inspected, one in five posed a significant risk to health as a result of poor hygiene and / or failure to employ adequately trained and qualified staff (Ref 12: Bove, JP & Conrad, J Nailing the Hazards EHP 31 March 2006 pp 12-14). As a result
of the rising number of nail salons and complaints about infected nails and fingers received, the CIEH have called for more research to assess the extent of the problem nationally (Ref. 13: Environmental Health News, 7 Sept 2006). To this end, the CIEH held a seminar on ‘Managing Health & Safety in the Beauty Industry’ on 9 Dec 2008.
Furthermore, concerns have been expressed regarding gaps and loopholes in UK legislation governing the beauty industry, including treatments such as nail extensions, waxing, laser hair removal, chemical body treatments and tooth whitening (Ref. 14: Beauty Bars “are health risk’’, EHN, 24 Nov., 2006), all of which services are available in beauty salons in Co. Donegal and no doubt, throughout the rest of the Republic of Ireland.
1.4 Potential Health Risks
“Some of the treatments offered in beauty therapy could, if performed incorrectly, give rise to significant dangers such as scarring. There are many specific problems of hygiene because so many treatments involve physical contact between the therapist and the client, or the intimate contact of therapy apparatus which is then used on other clients.” (Ref. 15: Hatton, Phillip, Hygiene for Hairdressers and Beauty Therapists, 3rd Ed., (1998), Addison Wesley Longman, UK, page 150)
The following outlines some of the potential health hazards when attending beauty and / or nail salons:
Hazard Potential cause / sourceSkin and other infection Re-use of towels, tools, materials without
proper cleaning and disinfectionRe-use of disposable tools, materials
Hepatitis / HIV Re-use of crystals during medical microdermabrasionInadequate disinfection of body-piercing tools
Burning of skin / hair, ear damage Improper use of ear candlesBurns and scarring Improper laser treatmentNail infection Manicures / pedicures / application of
acrylic nails / poor cleaning / poor training /
Mouth and gum irritation / tooth damage Teeth whiteningAllergic reaction / skin irritation Failure to carry out patch testing prior to
application of e.g. dye, bleachFungal infections of feet Recycling of water in or improper
disinfection of foot spas
Table 1.4.1 Potential health hazards in a beauty salon
1.6 Role of the Environmental Health Officer
Beauty salons provide the service of make-up application, facials, waxing, exfoliation etc. and the inherent use of a wide range of cosmetics such as skin creams, make-up, lip stick, cleaners, massage oil etc.
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Many salons also sell or supply such products from their premises, thereby rendering their sale or supply subject to the EC (Cosmetic Products) Regs., 2004 – 2006, which is enforced by the Environmental Health department of the HSE. A detailed list of cosmetic products subject to these Regulations is given in Appendix 9.2 as Schedule 1. In addition to carrying out inspections under this particular piece of legislation, products can be samples and analysed - ten cosmetic products were sampled from these premises, including cosmetics absorbed by the skin for the presence of lead and cadmium and teeth whitening products for the level of bleaching agent. The results of the analysis of these samples are outlined below under Section 5.
2.0 Executive summary
There is an abundant supply of beauty salons in Co. Donegal. They offer treatments that involve the use of cosmetic products, much person-to-person contact, often employing reusable equipment and tools.
There is currently no public health regulatory control over the operation of beauty salons.
The incidence of beauty salon acquired illness or injury in the Republic of Ireland is difficult to determine.
Environmental Health Officers are authorised to enforce the EC (Cosmetic Products) Regulations, 2004 - 2006 governing the sale of cosmetic products from premises, including beauty salons.
A survey was carried out in Co. Donegal in March / April 2009 by the Environmental Health Department of the HSE to determine the level of compliance within the beauty salon sector with these Regulations and to investigate the standard applied in relation to hygiene precautions.
The results of the survey indicate that: A high level of compliance with the aforementioned Regulations in that
most salons sold cosmetics having the required labelling information and the results of cosmetics sampled were deemed to be compliant for specific parameters analysed
While there are no known microbiological guideline standards for the beauty salon sector, microbiological analysis of sixty samples taken indicate a generally high level of cleanliness within salons. However, 14% of the salons visited required a follow-up visit due to levels of contamination that were deemed unsatisfactory.
The washing facilities e.g. a sink or basin, for cleaning the premises, tools and equipment were adequate in the majority of salons. However, 7% of salons provided only a wash hand basin in a toilet cubicle for this purpose.
Furthermore, none of the salons assessed provided sterilisation equipment. All provided chemicals as a means of disinfection and 73% provided a UV cabinet for disinfection / storage purposes. Of the latter, half did not know when the bulb was last changed, casting doubt on the efficacy of the UV cabinet as a means of surface disinfection.
Cleaning and disinfection procedures were clearly lacking in many instances e.g. in 66% of salons providing a foot spa, in 63% of salons applying make-up and in17% of salons in which manicure and pedicure tools are used, adequate cleaning and disinfection procedures were not applied.
17% of salons visited did not have adequate hand washing facilities
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The means of providing services such as sanitary accommodation, heating and lighting was satisfactory for the most part but a sufficient means of ventilation was lacking in half of the salons visited.
Policies and their implementation on hand-washing, use of disposable gloves and patch testing varied greatly – they were found to be inadequate for the first two mentioned; further investigation into policy regarding patch / sensitivity testing is needed prior to making comment on the issue.
As would be expected, personal hygiene standards observed were generally good
Waste disposal, particularly in relation to knowledge of proper disposal channels of used needles, requires improvement
The practice of ‘double dipping’ (i.e. repeated dipping of a spatula, make-up brush, sponge etc into a cosmetic product after contact with client skin) is widespread.
The provision of after-care leaflets for all appropriate treatments and the adequate maintenance of client records was not met in 86% and 57% of salons respectively
Laser treatment is available in 23% of salons A medical clinic was provided in 17% of salons
The main conclusions of the study include: High level of compliance with the EC (Cosmetic Products) Regs., 2004 -
2006 Generally, low levels of microbiological contamination were found The introduction of regulatory standards would afford greater uniformity
of standards and practices and ultimately, greater protection for the public The main recommendations from the report encompass:
Training for Environmental Health staff in the beauty therapy industry Development of a ‘Guide to Good Practice in Beauty Salons’ Contribution to the training of Beauty Therapists by Environmental Health
staff
3.0. Scope and Limitations:
The survey investigated the degree of compliance with selected aspects of the EC (Cosmetic Products) Regulations, 2004 - 2006 in relation to cosmetic products sold in beauty salons. Furthermore, the facilities, practices and policies in place to prevent cross-infection and in the interests of client care were assessed by means of interview, observation and microbiological and chemical analysis. The method by which this assessment was carried out is elaborated upon in Section 4 while the results are discussed in Section 5.
This survey only assessed the beauty treatment services provided in commercial beauty salons. If the following services were offered at the same premises, they were not included in the scope of this survey:
sun-bed facilities, tattooing, ear piercing and hair dressing services.
The survey did not include the assessment of beauty services offered in private residences. Anecdotal evidence suggests that this is a widespread activity, whether in the home of the Therapist or the client.
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The survey did not include premises offering holistic services such as reiki, acupuncture and reflexology.
Other than for the enforcement of the EC (Cosmetic Products) Regs., 2004 – 2006, participation by salon proprietors was voluntary.
Observation of practices was limited as treatments are usually delivered in the privacy of a screened-off cubicle or room.
Reporting of practices was based on the information provided by the person in charge at the time of the survey. It is accepted that data based on self-reporting may be biased. However, information gathered by self –reporting was collaborated as much as possible by observation and by microbiological analysis.
The survey was generally not carried out by prior appointment. Therefore, in some cases, time restrictions prevented full capture of information sought.
The survey did not include a workplace health and safety assessment.
The survey did not look at the efficacy of various treatments on offer but concentrated on the general hygiene precautions in place in the salon.
4.0 Methodology:
4.1 Aim:
a) To determine compliance levels with the EC (Cosmetic Products) Regs., 2004 - 2006 among beauty / nail salons in Co. Donegal and
b) To determine the degree to which such salons protect public health in the delivery of their service by way of the hygiene precautions implemented and
c) To make recommendations as to any improvements that could be made andd) To instigate the formulation of national standards for health and hygiene
within the commercial beauty salon industry in Ireland, working in partnership with relevant bodies such as the E.H.O.A., N.S.A.I., NABTET and / or IBPA.
4.2 Objectives:
1. To carry out a survey of approx. 25% (N = 30) of the salons operating within Co. Donegal focussing on the areas of:
- structural facilities provided to assist in hygienic procedures- hygiene practices - waste disposal- provision of information on treatments to customers- compliance with EC (Cosmetic Products) Regs., 2004 - 2006 - training of therapists employed
2. To assess the standard of hygiene by taking environmental swabs & / or samples for microbiological analysis.
3. To sample cosmetic products used in beauty salons for analysis under the EC (Cosmetic Products) Regs., 2004 - 2006
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4. To publish and disseminate results of the survey
4.3 Survey Development
The survey was conducted by a team of two members of the HSE West Environmental Health Department, namely, Jenny Fortune, Environmental Health Officer and Cora Murray, Senior Environmental Health Officer, both based at the Co. Clinic, Letterkenny, Co. Donegal.
A database of beauty salons operating in the county was generated from a variety of sources, including telephone books, advertisements in local newspapers, the Internet and other media.
A draft survey form was developed and piloted in March 2009 in four beauty salons.
A letter was issued to all known operators in Co. Donegal in advance of the commencement of the survey (see Appendix 9.3).
The survey essentially took on a two-pronged approach i.e.
1. Assessment of compliance with EC (Cosmetic Products) Regs., 2004 - 2006 including assessment under Article 10, relating to labelling, and sampling of cosmetic products in a number of salons.
2. Assessment of hygiene standards a) observed by the E.H.O. and b) as reported by the person in charge and c) by microbiological analysis of environmental swabs & or samples.
The bulk of the survey was conducted in March and April 2009. The survey was not carried out by prior arrangement (N = 87%) in all but a few cases. A process of random selection was not feasible. If a salon proprietor was unable to facilitate the survey at the time of visit, another salon on the database was visited. The majority of the visits occurred on a Tuesday or Wednesday and very occasionally a Thursday. Monday is usually a day of closure for salons in Co. Donegal and bookings are heaviest in salons between Thursday and Saturday.
The duration of the survey itself ranged from 75 minutes to 140 minutes, with an average of approx. 100 minutes. Considering the range of topics to assess and samples to take, 75 minutes was too little time to carry out a thorough assessment. Two hours per survey was a comfortable time allocation, depending on the range of treatments provided in the salon.
In all cases, the salon proprietor was written to at the conclusion of all 30 surveys, outlining the findings of the survey of her (all owners were female) particular salon.
Microbiological results that were considered to be unsatisfactory were conveyed to the salon owners concerned at the first opportunity immediately after receipt of the results by this Department.
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Results of the chemical content analysis were conveyed to the relevant salon owners at a later date due to the time difference in receipt of the results and conclusion of the physical survey of the premises.
4.3.1. Cosmetic products on sale were assessed for compliance with Article 10 of the EC (Cosmetic Products) Regs., 2004 – 2006, under which the container and packaging must bear certain information (see Appendix 9.4 for detail)
Details of suppliers of cosmetic products were obtained, where possible.
4.3.2. All relevant parts of the premises were inspected. This included the reception area, treatment rooms, cleaning facilities, staff facilities, sanitary accommodation, storage areas and spray tanning rooms.
4.3.3. The person in charge, which was usually the proprietor, was interviewed in relation to:
- treatments offered- cleaning facilities and equipment available- cleaning techniques applied- policies on hand washing, disposal glove use and patch testing- waste management- practices relating to use of delivery of treatments including use of
tools, towels, cosmetics, - maintenance of client records- after-care information on offer- training received by staff members
For consistency of inspection and to facilitate assessment of findings, the information gathered was recorded during the course of each survey on a survey form.
4.3.4. Environmental swabs / samples of surfaces, equipment, tools, cosmetic products etc. were taken for microbiological analysis to determine the level of microbial contamination present in salons. On average two samples where taken from each salon where possible, paying particular attention to details given during the survey of practices that may be deemed inadequate e.g. cleaning methods, double dipping of utensils, lack of disinfection etc.
The samples were delivered to the laboratory within 24 hours and were held under cold storage conditions from the time they were taken until the time of delivery at the laboratory
The following microbiological parameters were employed (results were given in Colony Forming Units (cfu)):
Total Viable Count (TVC) at 30ºC.Staphylococcus aureusEnterobacteriaceae (not tested for regarding foot spas)Pseudomonas spp. (tested in swabs from foot spas only)
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These particular parameters were chosen in an attempt to give an objective indication of the general cleanliness within the salons. There are currently no reference standards for microbiological levels within beauty salons. The interpretation of the results obtained from the swabs and samples taken from the salons are based on a combination of factors including comparison with results from other salons in Co. Donegal, experience within the Environmental Health Department and general
research. As microorganisms are found everywhere sterile conditions are not expected, however, equipment used to pierce skin must be sterile.
Staphylococcus aureus was chosen as a parameter as it is commonly found on the exterior of the body and can be spread by direct person-to person contact e.g. unwashed hands or indirect contact by touching objects that have been contaminated. It can cause minor skin infections such as spots, impetigo boils etc or can cause more serious infections where Staphylococcus aureus enters the blood stream via a cut or broken skin.
Enterobacteriaceae are a family of bacteria that normally inhabit the intestines of humans and animals, so again inappropriate hand washing and/or a lack of general cleanliness can be a factor in its spread.
Pseudomonas spp. was tested for only in foot spas due to it being commonly associated with water, warmth, aeration and human contamination, which provide an ideal environment for Pseudomonas to grow.
An information sheet in relation to the microbiological parameters analysed was sent to each salon that took part in the survey (See Appendix 9.4).
5.0 Results
The findings of the survey will be presented in three sections i.e.
5.1 enforcement of the EC (Cosmetic Products) Regs., 2004 - 2006 5.2 microbiological analysis5.3 hygiene standards observed and practices reported.
The results under paragraphs 5.1 and 5.3 were analysed using Epi-Info Version 3.5.1 of 13 August 2008.
5.1 European Communities (Cosmetic Products) Regulations, 2004 - 2006
5.1.1 Article 10 of the EC (Cosmetic Products) Regs., 2004 - 2006
Of the 30 salons visited, 29 were assessed as to whether or not cosmetic products were sold. Of those 29, 25 were assessed for compliance with Regulation 10 of the EC (Cosmetic Products) Regs., 2004 – 2006. The information that must be provided on the label or packaging of a cosmetic product is outlined in Appendix 9.4
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Approx. four different products were selected per salon. Most (N =20) of the salons assessed sold cosmetics that had all the necessary information on the label. Of those that sold cosmetics not compliant with labelling requirements (N = 5), the main issue noted was failure to provide the name or style and the address or registered office of the manufacturer of the cosmetic product or of the person responsible for placing the product on the market, who must be established within the EU.
Apart from being a legal requirement, it is important for a contact within the EU to be provided on the label for traceability purposes in the event of any health or safety issue arising with the product.
5.1.2 Cosmetic Product Sampling
During the month of April 2009, 70 samples of cosmetic products were taken throughout Co. Donegal. Of these, 10 samples were taken from beauty salons. These consisted of:
Sample of No. of Samples Tested for ResultEye lash and eye brow tint
1 P-phenylenediamine and labelling compliance
Compliant
Teeth whitening foam strips
1 Bleaching agent Not yet received
Moisturiser / tanning cream / cleanser / body butter / foundation make-up
8 Lead and cadmium Compliant
Total: 10 - 9 out of 9 compliant
Table 5.1.2.1 Types of samples and tests on cosmetic products taken from beauty salons March – April 2009
The EC (Cosmetic Products) Regs., 2004 - 2006 set the limits, fields of application, and conditions of use for the parameters tested – the relevant extract is given in Appendix 9.2. An information sheet for proprietors accompanying the results of chemical analysis is given in Appendix 9.5.
Regulation 8 (2) states that “Without prejudice to Regulation 7, the provisions of paragraph (1) shall not apply to the presence in cosmetic products of traces of any of the substances specified in Schedule 2 where such traces are technically unavoidable in the context of good manufacturing practice and could not reasonably have been removed during or after manufacture.” In the context on this clause, samples having any trace elements of lead or cadmium detected were deemed compliant.
5.2 Microbiological results
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The following are a list of items swabbed or sampled from 29 salons included in the survey. They were tested for the parameters as mentioned previously in section 4.3.4.
Swab of No. of swabsFoot spa 14Make-up brush, Eye shadow / Make-up Lip & eye pencil Lipstick
14
Sinks / WHBs 6Wax from wax pot 4Toe separators /Manicure & Pedicure tools
4
Heads of facial machine / Interior of UV cabinet /Hot towel cabinet / Towels /Surface of trolley /Bowl / Plastic sheet for waxing /Hot stone in tank
15
‘Barbicide’ disinfectant 1Vaseline 1Sun bed surface 1Total N = 60
Table 5.2.1 Breakdown of Types and Number of Samples / Swabs taken
As has already been mentioned, without clear guidelines, the interpretation of these results does not claim to be final and conclusive.
The results were interpreted as follows.
For the purpose of this report, individual results obtained in individual salons will not be discussed. However, a broad outline will be given below. Different types of equipment and materials used in the salons will be dealt with more specifically due to their common usage and results obtained. Please note a more detailed results table is available in Appendix 9.6.
Foot Spas
Levels of TVC
14 foot spa swabs were taken including 1 control sample. Swabs were taken of the interior surfaces and/or outlets of empty foot spas that may have been used on the day or held in storage. The result for the control sample taken was <10cfu which was deemed excellent with very low levels of micro-organisms detected. 1 foot spa had a TVC count of 360,000cfu. and it was noted that the method of cleaning this foot spa was inadequate due to a lack of a physical cleaning step prior to disinfection. 5 of the remaining foot spas matched the control sample result of <10cfu whilst the remaining 7 foot spas had TVC counts that were >10cfu ranging from 40cfu to 3,000cfu. Again
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the method of cleaning the foot spas varied but it can be noted from the surveys in all cases where the level of TVC was <10cfu a physical cleaning step was adopted by the salon along with a disinfection step.
Levels of Pseudomonas spp.
Out of the14 foot spas swabbed, 2 were found to have Pseudomonas present. In both cases it was noted that there had been no physical cleaning of the foot spas in conjunction with a disinfection step carried out between use on different clients. Both foot spas were only rinsed and sprayed using an antibacterial agent. In all cases where foot spas had Pseudomonas present, a follow up visit to the salons was organised to discuss the result with the Therapist. An information leaflet was given with regard to the recommended cleaning procedure of the foot spas. It should be stressed that Pseudomonas is ubiquitous and the levels found were interpreted as being more of a reflection of a lack of proper cleaning than being a source of infection. It should be noted that analysis was limited to the Pseudomonas species rather than a specific organism. There are guidelines available for the operation of spa pools and the presence of Pseudomonas aeruginosa. (Ref. No 16 “Management of Spa Pools: Controlling the Risks of Infection”, Health Protection Agency, London. March 2006). If >50 cfu/100ml the spa pool is to be taken out of operation and treated. However, it was felt that the operation of such pools and the use of a foot spa differs greatly.
Make up and Make up applicators etc.
Levels of TVC
8 swabs of make-up brushes, eyeliner applicators; lip liner applicators etc were taken including 1 control sample. The result of the control sample was <10cfu. which was deemed to be an excellent result with very low levels of micro-organisms present and 5 of the other swabs taken were comparable. 2 other samples indicated higher levels of micro-organisms with TVC counts of 282cfu and 55cfu. However, generally, the results were very good.
6 swabs or samples of make up were taken e.g. eye shadow powder, foundation lip stick etc. 5 of the samples taken were <10cfu and 1 sample of powdered eye shadow had a TVC of 80cfu. The reason samples and swabs were taken of these items was due to ‘double dipping’ of applicators whilst applying make up.
Sinks/Wash hand basins
6 swabs of sinks/wash hand basins were taken from salons including 1 control sample where a result of <10cfu TVC was found. A single sink in the WC was considered to be inadequate for the washing of tools and equipment. A swab of one such sinks had a TVC count of 464cfu. In general, the results indicated a high standard of cleanliness.
Wax taken from wax pots
4 samples of wax were taken from wax pots and all came back with TVC levels of < 10cfu. which indicates very low levels of microorganism contamination. Although it was found that re-dipping of spatulas was being carried out in many salons, which
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is contrary to good practice, the 4 samples of wax taken from these pots were found to be satisfactory which may be indicative that wax may not be a suitable medium for microorganisms to grow or the temperature wax is held at is not conducive to microbial growth. “It should be noted that any viable microorganisms resident in wax would be unlikely to multiply, due to an absence of water availability or suitable nutrients” Ref. Identification of microbial contamination in body wax samples, Prepared by Health and Safety Laboratory for the Health and Safety Executive 2009, page 13.
Toe Spacers & Manicure and Pedicure tools
In the majority of salons toe spacers were not used. Therapists preferred the use of cotton wool instead. In cases where they were used the majority were disposable, however, a small number of salons re- used toe spacers, which required cleaning between clients. 2 swabs of 2 different toe spacers were taken. While both had relatively low levels of TVC present, one was found to have Staph aureus present. Both were washed in hot soapy water e.g. using fairy liquid. There was no disinfectant step applied. The swabs taken of manicure and pedicure tools indicated low levels of microrganisms present.
General Equipment used in salons
A number of swabs were taken of different pieces of equipment used in the salons as can be seen from the table above. It is interesting to note that from one swab of the interior of a UV cabinet, a TVC level of 673cfu was found, emphasising the point that UV cabinets do not sterilise and have limited disinfection properties – they are efficient in storing previously disinfected equipment. In general terms, the results indicate a standard of hygiene within salons to be very good.
The results found of TVC levels were not deemed significant. However where levels were deemed to be much higher than the norm it had been agreed to follow up on these results with the salons. It was decided that salons would be contacted in these cases to inform them of results. It was also agreed that if Pseudomonas spp. was present in any foot spa results, salons would be revisited and an information leaflet in relation to the microorganisms tested and a method of cleaning the foot spas would be given.
In conclusion 4 out of the 29 salons (14%) required a follow up visit where it was deemed that the results of analysis were unsatisfactory. Otherwise, results would indicate that the standard of hygiene were found to be very good.
5.3 Hygiene Standards Observed and Practices Reported
5.3.1. Facilities For Cleaning
The provision of a sink or basin, separate from any provided for in a toilet area, was considered essential to facilitate the proper cleaning and disinfection of tools and equipment used in the business. In some cases, a basin or sink located in a treatment room doubled up as a wash hand facility as well as a sink at which to clean tools and
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equipment. In addition, a means of providing a constant and instant supply of hot as well as cold water at the time of survey was required in order to be deemed adequate. In essence, if a salon has at least one sink or basin (other than one in a toilet) with hot and cold water at which to wash tools, equipment etc. which may also have been used for hand washing, the cleaning facilities were deemed to be satisfactory.
7% (N = 2) of the salons visited did not have adequate facilities for cleaning. This was evidenced in both cases by the use of a wash hand basin in a toilet cubicle as the only sink available for cleaning of tools and equipment. This is considered to be grossly inadequate. It is worth noting that during the pilot survey, 75% (N = 3) of the salons visited at that time also has inadequate facilities for cleaning for the same reason, hence, the incidence of deficient cleaning facilities may be more prevalent than the main survey indicates.
Of the 30 salons visited, 7% also did not have a suitable means of providing hot water at the sink or basin used for cleaning tools and equipment at the time of the survey. These were the same two salons that only had a basin in a toilet for cleaning purposes. In some cases, a means of providing hot water was provided but was not in operation at the time of the survey.
5.3.2. Facilities for Hand washing
Hand washing facilities were considered adequate if a wash hand basin(s) was provided in toilet areas and a basin /sink was provided in or adjacent to the working areas (see 5.3.1. above). All salons had a wash basin in toilet areas. In some salons, a wash hand basin was provided in each treatment room while in others, a basin was provided in one treatment area only. The latter was considered acceptable in circumstances such as salons operated by one person only as access to the basin was guaranteed when required. In addition, a means of providing a constant and instant supply of hot as well as cold water and soap at the time of survey was required in order to be deemed adequate
17 % (N = 5) of the salons did not have adequate hand washing facilities. This is broken down into 2 salons that had no wash hand basin other than one in a toilet area, 1 with no hot water at the wash hand basin in the toilet area, 1 with no hot water at basins in treatment rooms and 1 salon without soap at wash hand basins.
Clean cotton towels were considered adequate as a means of hand drying. However, single use paper towels are preferred to fabric reusable towels. 3 % (N= 1) of salons provided paper towels for hand drying.
5.3.3. Laundry Storage
The storage facilities for cloth items awaiting washing were assessed. Salons having laundry stored in a suitable covered container lined with a plastic bag were considered to be providing suitable facilities. This issue was not assessed in 10% of the salons visited. 66% ( N = 20) of the salons did not have suitable laundry storage. In many cases, laundry bins were not covered or lined and in some cases, a plastic bag was used. The risk posed by such means of storage is considered low.
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5.3.4. Storage of Equipment
The storage of equipment was considered to be adequate if it was stored off the floor and in a manner so as to protect it from contamination. 27% (N = 8) were deemed to be storing equipment inadequately. It was found that some equipment, predominantly foot spas, was stored under treatment couches or on the floor in room corners. Again, the risk posed by such means of storage is considered low.
5.3.5. Services – Sanitary accommodation, Heating, Lighting and Ventilation
Sanitary Accommodation
If at least one toilet and wash hand basin was provided for use by staff and clients, it was considered that adequate sanitary accommodation was provided. Most salons (45% N = 12) had two staff members, with the maximum number of staff noted being 5 members (3%, N = 1). The provision of wheelchair accessible toilet facilities was not included in the assessment
100% or all of the 30 salons assessed were considered to have adequate sanitary accommodation.
Heating:
Heating was deemed to be adequate if a means of heating was provided at the time of assessment. Room temperatures were not recorded as part of the assessment. In all cases (N = 30), the means of heating provided was considered adequate.
Lighting:
Lighting was considered adequate if a means of artificial or natural lighting was provided in all essential areas. Again, in all cases (N = 30), the lighting provided was considered adequate.
Ventilation:
A visual assessment of the means of ventilation provided was carried out in treatment rooms, spray tanning rooms, toilets and staff areas. Ventilation was considered to be satisfactory if adequate mechanical extract or air conditioning in appropriate areas and / or a natural means of ventilation, such as openable windows, was provided. However, the provision of suitable mechanical extract ventilation in spray tanning areas was considered essential for the removal of aerosols released in the spray tanning process. Propylene glycol (PG) is an ingredient of spray tan solutions – “Inhalation of the PG vapors appears to present no significant hazard in ordinary applications. However, limited human experience indicates that inhalation of PG mists may be irritating to some individuals. Therefore inhalation exposure to mists of these materials should be avoided.” (Ref 17 http://www.dow.com/productsafety). Preservatiives such as parabens are also added to cosmetics – butyl paraben, for example, has the potential health effect upon inhalation of causing irritation to the respiratory tract. Symptoms may include coughing, shortness of breath (Ref. 18 http://www.jtbaker.com/msds (material safety data sheet))
37% (N = 11) did not have adequate ventilation in treatment areas. In some cases, treatment rooms consisted of internal, partitioned areas. Many salons were not purpose-built thereby contributing to this issue.
Of the 30 salons, 20 of them (66%) provided a spray tanning service. Of those 20 salons, ventilation in the spray tanning area was not assessed in 5 of them. Of the remaining 15 salons, 20% (N = 3) did not have adequate ventilation in the spray tanning area while in 80% (N= 12) of cases, extract ventilation was provided. However, further research into the adequacy of ventilation in spray tanning areas is required as adequacy is more complex than simply providing an extract fan.
13% (N = 4) of sanitary accommodation did not have adequate ventilation. 7% (N = 2) were not assessed for this criteria.
In relation to the staff areas, 10 % (N = 3) did not have adequate ventilation. In some cases, a staff area was not provided and in others (20% / N = 6) ventilation in this area was not assessed. 47% (N = 14) of the staff areas assessed did have adequate ventilation.
Ventilation was inadequate in 47% (N = 14) of salons visited, while 50% (N = 15) had a satisfactory means of ventilation in every area of the salon.
5.3.6. Policies – Hand Washing, Disposable Gloves, Patch Tests
Hand Washing:
Hands must be washed before and after treating a client and after handling food, using the toilet, handling money etc. Soap must be used, preferably liquid soap (Ref. 19 Habia – Hygiene in Beauty Therapy – 2006 – page 10). Therapists were asked to describe their policy on hand washing. In view of the fact that the above standard requires hands to be washed before and after treating a client, 27% (N = 8) were considered to have an inadequate policy regarding hand washing, as some reported washing hands after treating a client as opposed to beforehand also. In many cases, hand spray with disinfectant properties were used in addition to hand washing. In one case, soap was not used.
Disposable Gloves:
Disposable gloves should be worn where there is or may be contact with mucous membranes (e.g. during intimate waxing) or blood or serum (e.g. in case of blood spotting during waxing or other treatments such as microdermabrasion). (Ref. 19 Habia – Hygiene in Beauty Therapy – 2006 – page 10). From various research sources, the use of disposable gloves has been recommended for each of the following treatments:
waxing electrolysis extractions application of nail extensions eyebrow tweezing
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red vein treatment application of tooth jewellery microdermabrasion.
Where a Therapist reported use of gloves according to the above and replacement of gloves after each client, the disposable glove policy was considered to be satisfactory.
This was not found to be the situation in 87% (N = 26) of the cases. In some instances, Therapists did not use gloves for certain treatments such as waxing (excluding bikini waxing), eyebrow tweezing and extractions.
Patch Tests:
There are various types of sensitivity tests that are required before the application of certain treatments in a beauty salon e.g. a skin sensitivity test before facial electrical treatments whereby sharp and soft objects are placed on the face and neck; a patch test to detect any allergic reaction; a thermal skin test to check a clients’ tolerance to heat. For the purpose of this survey, only the policy on patch testing was assessed.
Therapists were asked to name the treatments offered that are subject to a patch test. Various resources employed in the research for this survey indicated that patch testing should be:
a) carried out regularly on each client when attending for the following treatments:
waxing tinting of eye brows or eyelashes eyelash perming application of false eyelashes application of semi-permanent make-up laser and intense pulsed light treatments self tanning hair bleaching microdermabrasion
How ‘regular’ the testing should be can be dependent upon a number of factors, including the area of the body being treated e.g. “The skin may become sensitive to a particular product even after many years of use and an allergic reaction may occur. Regular testing for allergy is important as the dye is being used on a highly sensitive area” i.e. around the eyes (Ref. 20: Cressy, Susan, Beauty Therapy Fact File 4th Edition, Heinemann Educational Publishers, 2004, page 144).
b) carried out with sufficient time lapse between the patch test and application of treatment. For certain treatments e.g. eyebrow / eyelash tinting, eyelash perming, hair bleaching, a patch test should be carried out a minimum of 48 hours before treatment (Ref. 20: Cressy, Susan, Beauty Therapy Fact File 4th Edition, Heinemann Educational Publishers, 2004, page 144/ 5). For others, a minimum of 24 hours is recommended, with guidance being taken from the instructions provided with the product or by the manufacturer of the equipment concerned.
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c) carried out on each client if a different brand or type of cosmetic product is used from the previous test.
Further research is required in this area to determine the suitability of patch testing policy and its implementation.
Additionally, some Therapists expressed the opinion that clients are often not inclined towards patch testing or that it is ‘not popular’ with clients. This suggests that some measures to increase awareness of the need for such testing would be beneficial.
5.3.7. Personal Hygiene
Personal hygiene was considered satisfactory if it was observed that clean protective uniforms were worn, fingernails were clean, short and without enamel and if Therapists presented with good personal cleanliness (Ref 19: Habia – Hygiene in Beauty Therapy – 2006 and Ref. 21 IBPA Standard of Excellence Award criteria)
Suitable protective uniforms were worn in all salons in which this was assessed. (N = 29). Fingernails were clean in all cases but were not kept short in 13% (N = 4) nor without enamel in 20% (N = 6) of cases.
5.3.8. Waste disposal
Half of the salons surveyed produce clinical waste in the form of used needles (N = 15) from procedures such as electrolysis. Other clinical waste is generated from blood spotting following procedures such as waxing or extractions.
Waste disposal was considered acceptable where the following standards were met:
1. Lidded bins being provided for the storage of general waste 2. Double-bagging prior to disposal by landfill of contaminated waste including waste cotton wool, tissues or cloths with any blood spots or human tissue3. Use of a ‘sharps box’ labelled as ‘contaminated’ and ‘for incineration’ for used needles4. Disposal of boxes of used needles by collection by permitted collectors.
General Waste:
Over half of the salons did not provide bins that were lidded for the storage of general waste (N = 16 or 53%) but used open-type bins.
Contaminated Waste:
The disposal of contaminated waste was assessed in 12 salons (40%). In each case, it was not double bagged. In all cases, material with blood spots, such as waxing strips, was disposed of in the normal fashion among general waste.
Used Needles:
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Of the 15 salons requiring the use of a sharps box, two of them (13%) did not have such a box in the salon at the time of the survey. In one case, the sharps box was not labelled as ‘contaminated’ and ‘for incineration’. In 12 out of the 15 salons, it was stated that disposal of the needles had not been required to date. In 9 cases, the person interviewed did not know how or where to dispose of used needles. Information to this end has since been issued by this office to the persons concerned. Only two salon operators indicated that needles have been disposed of in the past – this was stated to have been done through a medical professional.
Overall, waste disposal was not satisfactory in 63% (N = 19) of the salons visited. While the lack of a lidded bin for general waste storage is not an issue of major concern, the lack of knowledge on the proper disposal of contaminated waste needs addressing.
5.3.9. Equipment for Sterilisation and Disinfection
Sterilisation Equipment:
Sterilisation of ‘hard’, reusable implements e.g. commodone extractors, metal scissors, tweezers, cuticle knives etc. used to cut or pierce the skin using suitable sterilisation equipment such as a glass-bead steriliser or an autoclave is considered essential (Ref. 19 Habia – Hygiene in Beauty Therapy – 2006 – page 13) unless using disposable, single-use equipment.
None of the salons assessed had sterilisation equipment.
Disinfection Equipment:
73% (N = 22) salons provided disinfection equipment, predominantly in the form of a UV cabinet. UV cabinets do not sterilise and have limited disinfection properties – they are efficient in storing previously disinfected equipment. UV light inactivates microorganisms on the surface that it hits and is not suitable for the disinfection of tools such as make-up brushes, sponges or items with hidden surfaces
Ultraviolet (UV) light cabinets require maintenance e.g. bulbs in ultraviolet cabinets should be changed according to manufacturers’ instructions. Bulbs have a limited lamp life and their output depletes over time. Hence, a note should be taken of the date of change of each bulb rather than depending on the visual appearance or a fusing of the bulb in determining its replacement.
Of those that had UV cabinets, when asked when the UV bulb(s) was/were last changed, 50% (N = 11) didn’t know, 36% (N = 8) did not change the bulb within the previous 12 months while 14% (N = 3) had.
Of the 22 salons using UV cabinets, records in relation to changing UV bulbs 95% (N = 21) were not kept and in the other case, the interviewee did not know if such records were kept.
5.3.10. Cleaning of Implements / Tools
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Cleaning (not including sterilisation, discussed above) of implements and tools used in the beauty salon industry was considered to be sufficient if all of the following standard was adhered to:
1. Disinfectant solutions used to steep tools must be changed regularly in line with manufacturers’ instructions. The preparation and use of a new solution of disinfectant daily is recommended as many disinfectants deteriorate when stored or are inactivated by contaminants.
2. Re-usable tools such as sponges, make-up brushes, some manicure / pedicure tools (e.g. foot files, toe separators etc) should be adequately cleaned, by washing in warm soapy water, rinsing followed by disinfection e.g. a) using chemicals such as ‘Barbicide’ etc. or b) by heat e.g. boiling water / steam / hot air, as appropriate. Thorough cleaning is essential before disinfection so as to remove all organic matter such as skin tissue, dirt etc.
3. An effective disinfectant(s) suitable for use on tools, equipment, surfaces etc within a beauty salon should be used e.g. hand-sprays, tea tree oil or similar preparations used as skin disinfectants or anti-bacterial soap for hand-washing are not suitable for disinfecting tools or equipment.
4. An adequate supply of effective disinfectant(s) suitable for use on tools, equipment, surfaces etc. within the beauty salon should be available.
Most salons changed disinfectant solution in which tools were steeped on a daily basis, some less often, depending on how busy the salon had been. At the beginning of the survey, one sample of ‘Barbicide’ disinfectant was taken from a waxing room, the owner having indicated that it was changed once a week - the results of microbiological testing of this solution did not indicate any noteworthy contamination.
In the absence of sterisilation equipment, as outlined above, it could be argued that none of the salons performed adequate cleaning of hard / metal tools that pierce the skin. In 5 cases out of 29 salons (17%), cleaning of manicure and pedicure tools (toe spacers, scissors, cuticle knives etc) was inadequate due to a lack of adequate or no disinfection. This was due in all cases to the improper cleaning of toe spacers.
29 out of 30 salons (97%) provided a foot spa or foot basin for pedicure treatments. These foot spas were properly cleaned and disinfected in only 10 salons (33% of cases). In the 19 cases where cleaning was inadequate, the foot spa may only have been washed without any disinfection or by cursory disinfection by wiping with a disinfectant-soaked cloth rather than steeping in disinfectant of a suitable strength for a suitable time period. Many foot spas have perforations for an aeration and bubbling effect on the water - microorganisms may harbour in such perforations, outlets or ducts, thus wiping or spraying proves deficient in these spas of this design.
Hygiene precautions were not adequate in the application of make-up in 63% (N = 19) of the salons assessed. Make-up brushes, for example, are used to apply powders directly to the skin and are therefore liable to become contaminated from any
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pathogens present. Furthermore, inadequate washing and disinfection of the brush increases the risk of contaminating the make-up into which the brush is applied. Cleaning brushes by means of shampoo and water alone or followed by a spray disinfection is not adequate as the spray is unlikely to cover all surfaces of the brush hair. Similarly, placing brushes in a UV cabinet after washing with a detergent is inadequate as the UV radiation cannot reach all surfaces of the brush hair.
Hygiene precautions for skin and eye treatments were inadequate in 2 (6.6%) cases. In both instances, sponges (which are porous and can harbour bacteria) used to remove face masks were not disinfected after use.
Sterile needles were available for use in electrolysis in all cases assessed (N= 13).
Hot stone equipment was not adequately cleaned in 5 out of 13 (38%) salons providing this treatment (1 salon was not assessed for this criteria). Again, this may have been due to lack of or inadequate disinfection e.g. detergent wash only or a spray disinfection rather than steeping.
No issue was identified in relation to the disposal of crystals after use in microdermabrasion.
All of the salons surveyed provided suitable chemicals as a means of disinfection (N = 30). Popular disinfectant used included surgical spirits, ‘Barbicide’, ‘Marvicide’, ‘savlon’, ‘milton’ and alcohol-based spray disinfectants.
5.3.11. Practices
Protection for Bare Feet:
Suitable covering e.g. couch roll, should be placed on floor areas upon which clients walk barefooted. Alternatively, disposable foot covers should be provided for use by the client. In 10% of salons (N=3), adequate measures were not taken to protect clients feet during treatments necessating the removal of foot ware e.g. during pedicures, massage.
Disposable Tools / Items:
The use of single-use disposable tools / items, where possible, is recommended e.g. use of cotton wool in lieu of toe separators / wooden spatulas in lieu of metal ones.Figures are not available for the number of salons using disposable tools or items, however, the use of disposable eye shadow applicators, mascara wands, wooden spatulas, sponges and cotton wool were popular.
The use of single client tools is recommended e.g. use of single client pots, cartridges and disposable applicator heads for waxing.
Double Dipping
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Double dipping is a term used to describe where applicators are repeatedly dipped into a cosmetic product even though it has touched the clients skin, whether using either disposable or washable applicators. In all cases, in order to reduce the risk of cross infection, double dipping must be avoided. This practice relates to the application of make-up (when using either disposable applicators or washable brushes) or waxing. The use of a new spatula for each dip into the wax pot or using a single spatula to take wax from the pot and then allowing the wax to drop onto another spatula for application on the client - sometimes referred to as the ‘spooning method’- is recommended.
Although many salons used disposable make-up applicators, the practice of re-dipping the applicator into the make-up was carried out in a few cases.
In 23 salons (77%), Therapists reported that a different spatula was not used for each dip into the wax pot. In effect, a disposable spatula applies wax onto the client’s skin, with the risk of picking up any pathogens present on the skin in the process, and introducing these pathogens into the pot of wax for the next application of wax. In 93% of salons (N = 28), the practice of changing a spatula on different parts of the body was adhered to e.g. when changing from leg to underarm or bikini line. However, 7% (N = 2) used the same spatula for different areas of the body. In all cases (N=30 / 100%), it was reported that the spatula was disposed of in the event of blood spotting.
Wax
Wax remaining in the base of a wax pot should not be decanted into a fresh pot of wax. When asked if this practice was carried out in the salon (N = 14), 6 out of the 14 (43%) reported that it was. Four samples of wax from a wax pot in use were analysed for microbiological levels and were found to be satisfactory.
Dispensing of Products:
Creams, lotions and sprays should be dispensed from pump or spray bottles where possible. Otherwise, products must be distributed with a disposable spatula. In 28 out of 29 (96.5%) salons, the practice of removing a product from its container for manicures and pedicures was satisfactory e.g. many Therapists reported using a pump dispenser onto the back of her hand.
However, in 13 out of 28 cases (46%), a suitable practice was not applied in the proper use of disposable tools and removal of product from containers in the application of make-up. This was predominantly due to reusable and disposable make-up brushes being re-dipped into the make-up during application onto a client. A safer practice would be to load a palette or the back of the hand with enough material to complete a treatment or reload using a fresh spatula (Ref. 15: Hatton, Phillip, Hygiene for Hairdressers and Beauty Therapists, 3rd Ed., (1998), Addison Wesley Longman, UK, page 153)
Towels
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Towels should be changed after use by every client (Ref 19: Habia – Hygiene in Beauty Therapy – 2006, page 14) 96.7% (N=29) reported doing so. However, in one case (3.3%) towels were reported to be turned over and changed after approx. the fourth use, with the use of couch roll. Two swabs of towels used on treatment couches, including the one referred to above, were satisfactory upon microbiological analysis.
In 2 out of 27 salons (7%), an adequate supply of couch roll was not available.
5.3.12. After-Care Leaflets:
After care leaflets should be provided for first time clients having availed of the following treatments:
Microdermabrasion (after care & home care advice) Semi-permanent make-up (after care advice) Ultrasound (home care advice) Waxing (home care advice) Electrolysis (home care advice) Laser and pulsed light treatment (home care advice) Artificial nail systems (after care advice) Self-Tanning Treatments (after care advice) Red vein removal (after care & home care advice) Body electrical treatments (home care advice) Spa treatments (home care advice)
(Ref. 20: Cressy, Susan, Beauty Therapy Fact File 4th Edition, Heinemann Educational Publishers, 2004 and various ITEC syllabi)
In 24 out of 28 salons (86%), after-care leaflets were not provided for all the appropriate treatments above available in the salon. In some cases, after-care leaflets were provided only for a selection of the treatments offered or it was reported that verbal advice was given as necessary.
5.3.13. Client Record Cards:
Updated records outlining the treatments given to each client together with dates, patch / sensitivity tests and any contra-indications should be kept for the following treatments:
electrical epilation laser and pulsed light treatments eye lash and eye brow tinting manicure and pedicure waxing nail art body and facial electrical treatments microdermabrasion
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(Ref. 20: Cressy, Susan, Beauty Therapy Fact File, 4th Edition, Heinemann Educational Publishers, 2004 and various ITEC syllabi)
In 23% (N=7) of salons, client consultation records were not kept for each client.
In 57% (N=17) of the 30 salons, client consultation records were not kept for each visit for the above treatments. In some cases, client records were maintained for new clients only or for a selection of treatments, such as laser or electrolysis or if a problem was noted on a treatment applied to a regular client, but not, for example, waxing or manicure / pedicure on regular clients.
5.3.14. Training
The qualifications of and documents relating to training received by all Therapists, whether whole time or part-time, should be available on the premises for inspection by members of the public. This could be achieved by public display within the salon or by being available in a display folder.
However, there is a myriad of training centres (private and public) and courses available to instruct Therapists in the practice of Beauty Therapy and its associated skills. Courses can be accredited to various levels of expertise through many different certification bodies such as CIBTAC, ITEC, NVQ, City & Guilds, CIDESCO, and BABTAC. Courses can vary in duration from a day, such as a training day provided by a cosmetics company in the use of its product, to a number of years. Qualifications observed varied from a certificate of attendance to diploma level. In view of the complexity of training available, assessment was restricted to the display or availability for viewing of staff training qualifications.
As can be seen from the table below, 1 – 2 people worked in the majority of salons. Many were small proprietor-operated businesses. The table outlines the number of staff employed in 29 out the 30 salons.
In 21 out of 29 salons (72%), staff training certificates were available for viewing or on display. In salons employing two people or more, 7 did not have qualifications for all members of staff available for clients to view, while 8 did (this criterium was not assessed in 3 cases and was not applicable in 12 cases).
5.3.15. First Aid Kit:
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A first aid box should be provided for use in the salon. In a quarter of salons (N = 7 out of 28 salons), a first aid box was not provided.
5.3.16. Laser and Intense Pulsed Light Treatment:
Laser treatment was available in 7 out of the 30 salons assessed (23.3%). The assessment of issues under this criterium was limited to the hygiene precautions carried out on the instruments used. While the adequacy of training and use of laser equipment was not assessed in this survey, the opportunity to echo calls for regulation over this type of treatment is taken at this point. Mr. Douglas McGeorge, President of the British Association of Aestheic Plastic Surgeons is quoted as stating that “injectables, peels and lasers should all be performed by a properly trained clinician, a plastic surgeon or a dermatologist. …..it is essential that people do their homework as these treatments can affect not only their appearance but health and safety as well” (Ref. 7: Beauty Treatments ‘a health risk’, EHN, 1 June, 2007). The growing use of laser light treatments in beauty salons was said to pose significant health problems, such as burns, scarring and failure to identify certain skin conditions that may require medical help (Ref. 21 White and Melia, Unregulated beauty industry a time bomb, health experts warn in The Irish Independent, 21 June 2005). The Irish Association of Cosmetic Doctors (IACD) is reported to have lobbied the government for a system of external regulation in the interests of patient safety in the administration of treatments such as laser treatment (Ref 22: Treacy, Dr. Patrick, Condemnation of laser deregulation in the Irish Medical Times, posted in Letters on 14 June 2008). This department would support that stance. Health and safety regulation is currently in place specifically to protect employees within the salon rather than its clients .
5.3.17. Medical Clinic
A medical clinic was provided in 5 out of the 30 salons (17%). Services such as botox and injectables to treat crow’s feet, frown lines and fillers offered as anti-ageing treatments are provided. Botox is a prescription-only medicine that can only be ‘given by physicians with appropriate qualifications, and expertise in the treatment and the use of the required equipment.’ (Ref. 23 personal communication with The Irish Medicines Board). To practice in the Republic of Ireland, a medical practicioner must be registered with the Irish Medical Council and is given a registration number. This survey did not include any assessment of any medical clinic carried out as it is within the remit of bodies outside this service, as above. However, it is interesting to note the prevalence of medical clinics on offer within businesses such as beauty salons and there may be scope for liaison between the Environmental Health service and other regulatory bodies in this matter.
5.3.18. General Observations
Attitudes of Salon Owners to Guidance and Regulation
In discussions with salon owners during the course of the survey, many welcomed the survey taking place and indeed, were very welcoming of some form of guidance being available. While data on the attitudes of salon owners was not formally gathered, it was clear that many were in favour of some form of regulation, be that licensing or
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otherwise. Many had worked in other jurisdictions and were familiar with a regulatory process; some expressed surprise that there was no form of regulation here.
Treatments:
A description of the treatments on offer is given in Appendix 9.5
A breakdown of the number of salons offering such treatments is outlined in Appendix 9.7. The most popular treatments on offer were the application of make-up, manicures / pedicures, skin care and eye treatments, massage and waxing. Those on offer least were body electrical treatments, application of teeth jewellery, platinum detox and microdermabrasion.
6.0 Conclusion:
6.1 EC (Cosmetic Products) Regs., 2004 – 2006
1. The labelling of cosmetic products for sale in beauty salons was in the most part compliant with Regulation 10 of the EC (Cosmetic Products) Regs., 2004 – 2006. However, one in five of the salons selling cosmetic products examined did not fully comply with this Regulation.
2. While the number of samples analysed for specific parameters was relatively low, the results indicate that the products were compliant with the above Regulations
6.2 Microbiological Results
3. The absence of guideline standards presented a challenge in the interpretation of microbiological levels detected. The general level of cleanliness as observed and as objectively analysed by microbiological examination was found to be generally very good. However, there were four instances in which a follow-up visit was required in order to advise of microbiological levels that were deemed to be unsatisfactory and for which remedial action was recommended.
6.3 Hygiene Standards Observed and Practices Reported
4. The majority of salons visited had adequate facilities for cleaning the ‘tools of the trade’ and the premises itself. However, 7 % only had a wash hand basin in a toilet area for this purpose, which is considered to be grossly inadequate. Furthermore, 7 % of salons had no means of providing hot water at the cleaning sink or basin for tools and equipment.
5. Hand washing is considered an essential practice in the control of infection. It is therefore of concern that the facilities for hand washing in 17% of the salons visited were inadequate. In two of such salons, there was no wash hand facility other than one located in a toilet area.
6. There is scope for improvement in the manner in which laundry and equipment storage is managed in salons.
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7. Services such as sanitary accommodation, heating and lighting provided within salons were generally good. However, in ventilation spray tanning areas requires further research.
8. The policies surrounding certain practices, as reported, were found to be lacking. While Therapists reported that hands are washed frequently, just over a quarter adopted a policy in which hand washing was not at a sufficient frequency. A revised policy indicating a more widespread use of disposable gloves for certain treatments is required in 87% of salons. Further investigation into policies regarding pre-treatment testing is required before comment can be made.
9. Personal hygiene was observed to be generally very good among personnel in salons at the time of survey.
10. The storage and disposal of general and contaminated waste was not satisfactory in many cases. A knowledge of the proper means and channels through which to store and dispose of used needles was greatly lacking.
11. None of the salons surveyed has equipment to sterilise ‘hard’, reusable tools used to cut or pierce the skin. 73% of salons provided a UV disinfection cabinet but the knowledge regarding the maintenance of these cabinets was lacking in 86% of those salons.
12. All of the salons surveyed provided suitable chemicals for disinfecting tools, equipment, surfaces etc. However, an absence of the use and / or proper use of detergents and these disinfectants was apparent in a number of cases, such as in the cleaning of foot spas, make up brushes, toe separators and sponges.
13. In most cases, the protection of bare feet in contact with floor / other surfaces from infection was adequate. However, the practice of ‘double dipping’ i.e. repeated dipping of applicators into certain cosmetics is common practice. A suitable method of dispensing other cosmetics was reported in many instances as was the practice of changing towels.
14. An improvement in the provision of after-care leaflets for first time clients is needed.
15. Similarly, the maintenance of client records was not satisfactory in more than half of the salons.
16. The display of qualifications for all Therapists employed in the salons was not available in almost quarter of salons. The scope of this survey did not permit an assessment of the adequacy of qualifications of staff employed.
17. The majority of salons (86%) were small, independently run businesses employing up to two people.
18. Regulation for the protection of clients receiving certain treatments, such as laser treatment, is greatly lacking.
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19. The practice of holding a medical clinic was noted in 17% of the salons surveyed.
20. A positive reception to the introduction of some form of regulation over beauty salons was noted during interviews with many salon operators.
21. The introduction of regulatory standards would afford greater uniformity of standards and practices and ultimately, greater protection for the public
7.0 Recommendations
1. That research into the practices within beauty salons is further developed by means of Environmental Health personnel replicating this survey in other parts of the country.
2. That Environmental Health staff receive training on the practices, procedures, and treatments provided by and within the beauty therapy industry.
3. That a ‘Guide to Good Practice in Beauty Salons’ is developed for use and dissemination in the Republic of Ireland by the Environmental Health in conjunction with relevant stakeholders.
4. That Environmental Health staff, in turn and in conjunction with relevant bodies, contribute to the training of Beauty Therapists by the development of a syllabus including, but not exclusively, content on the EC (Cosmetic Products) Regs., 2004 - 2006 and public health aspects.
5. That Environmental Health staff develop an award system for salons proving to be operating to a defined standard, such as a guide referred to in point no. 3. This could be done in conjunction with relevant, interested bodies.
6. That information is provided to the public in relation to standards to expect in a beauty salon.
7. That microbiological guideline standards applicable to beauty salons are developed by the Environmental Health service.
8. That research is undertaken to determine the level of beauty salon acquired infection or injury.
9. The operation of beauty salons should be regulated within the Republic of Ireland such that the premises is licensed once the physical design, facilities etc. meet a minimum standard, the staff employed meet a minimum level of training in relation to the treatments offered among many other relevant criteria. Such standards should be enforced on an ongoing basis through regular inspections carried out by Environmental Health Officers and any other profession deemed necessary.
The implementation of these recommendations is envisaged on a staged basis, which is outlined in Appendix 9.8.
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8.0 Acknowledgements
The authors would like to sincerely thank the following for their co-operation and assistance in carrying out this survey:
1. The proprietors and staff members of all the salons surveyed.2. Ms. Mary Ferry, proprietor of the Gweedore Beauty and Body Clinic, Gweedore and Fás Course Tutor in beauty therapy3. Mr. Joe O Neill Management Consultants, Treenduff, Bohola, Claremorris, Co. Mayo4. The Irish Beauty Professionals Association, 46, Lr. Leeson St., Dublin 25. Aqualab Laboratory, Killybegs, Co. Donegal6. The Public Analysts’ Laboratory, Seamus Quirke Rd., Galway7. Ms. Wendy Nixon, Senior Business Development Manager, Business Development Group, Hairdressing and Beauty Industry Authority (HABIA), Oxford House, 6th Avenue, Sky Business Park, Robin Hood Airport, Donacster, South Yorkshire,UK DN9 3GG8. Ms. Tina Garrity, Information and Communications Manager, Chartered Institute of Environmental Health, Chadwick Court, 15 Hatfields, London SE1 8DJ, UK. 9. Ms. Suzanne Tinney , Waste Awareness Officer, Donegal County Council, The Kube, Magheranan, Letterkenny, Co. Donegal10. Dr.Olive Smyth, Senior Medical Officer, Irish Medicines Board, Kevin O’Malley House, Earlsfort Centre, Earlsfort Terrace, Dublin 2.11, Ms. Louise Cullen, Surveillance Scientist, Dept. of Public Health, HSE West, St. Conal’s, Letterkenny, Co. Donegal12. Mr. Julian Cant, DaRo UV Systems Ltd., Chilton, Sudbury, Suffolk, CO10 2YA, UK.
9.0 Appendices
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Appendix 9.1 Description of Beauty Treatments
The following is a basic description of the treatments concerned:
Facial & Eye Treatments
These include manual treatments such as cleansing, toning, moisturising, application of face mask, facial massage, eyebrow shaping, eyebrow and eyelash tinting, eyelash perming, application of false eyelashes etc.
Electrical treatments for the face can be provided by equipment for microdermabrasion (see below), vaccum suction, laser treatment (see below) and those providing electrical muscle stimulation, among others.
Manicures and Pedicures
A manicure could involve nail filing, nail buffing, cuticle work, hand massage and nail enamelling. Common special hand and nail treatments use paraffin wax, oil, salt rub and thermal mittens. Nails can be extended by artificial nail systems.
A pedicure can involve the above in addition to a foot soak in a foot spa.
The application of nail art and jewellery can also be part of a manicure or pedicure
Laser Treatments
In beauty salons, lasers are used for treatments such as hair removal, skin rejuvenation and to address fine line and wrinkles. For hair removal, the process uses light, which is absorbed by the pigment in the individual hairs. The pigment converts the light to heat, a process which disables the ability of the hair follicle to grow further hair.
IPL (Intensed Pulsed Light) works on the same principles as lasers in that light energy is absorbed into particular target cells with colour in the skin but differ to lasers in that they deliver many wavelengths (or colours) in each pulse of light instead of just one wavelength. (Ref. http:// dermnetnz. org/procedures/ipl.html)
Body Electrical Treatments
Used as part of a weight loss programme where equipment is used to aid weight loss as part of an effective body treatment programme. Electrical treatments offered could be vibratory treatment, which is a form of mechanical massage. Vacuum massage treatment which increases the body’s circulation and lymphatic flow to aid in the removal of waste products and excess fluid. Electrotherapy is the application of an electrical current for therapeutic purpose such as the removal of cellulite or muscle toning
This is a method of hair removal using an electrical current. A needle is inserted into the follicle and a current is applied which causes localised damage to the areas that generate hair. There are a number of techniques, such as galvanic electrolysis, which chemically alters the salt and water around the hair follicle to produce a small amount of lye to destroy the cells. Another type of electrolysis, thermolysis, vibrates the cells around the hair follicle to produce heat, which will achieve the same affect. In some cases, both techniques are applied.
Waxing
Waxing is the removal of body hair by use of heated wax applied with a spatula and removed with fabric strips.
Microdermabrasion
This is a method which exfoliates the surface of the skin using crystals which are directed at the skin surface using compressed air via a specialised hand piece. The dead skin and crystals are then removed via a vacuum as directed by the hand piece.
Platinum Detox
This involves the immersion of the feet in a specialist foot spa unit, which is said to assist removal of toxins from the body through the feet.
Teeth Whitening
Use of a bleach and UV light onto the teeth.
Ear Candling
This involves lighting one end of a hollow candle and inserting the other end into the ear canal. It claims the flame creates negative pressure, which draws ear wax out of the ear canal, offering relief from some ear, nose and throat conditions
10. (1) Subject to the provisions of this Regulation, a person shall not place on the marketa cosmetic product unless the container and packaging bears the following information in indelible, easily legible and visible lettering -(a) the name or style and the address or registered office of the manufacturer of the cosmetic product or of the person responsible for placing the product on the market. Such manufacturer or person responsible for placing the product on the market shall be established in a Member State of the Community. This information may be abbreviated provided that any such abbreviation does not prevent the manufacturer or the personconcerned from being identified;(b) the nominal content at the time of packaging, given by weight or by volume, except in the case of packaging containing less than five grams or five millilitres, free samples and single-application packs. In the case of pre-packages normally sold as a number of items for which details of the weight or volume are not significant, the content need not be stated provided that the number of items is stated on the packaging. Such information need not be given if the number of items in the presentation is easy to see from the outside or if the product is normally only sold individually;(c) the date of minimum durability. This shall be indicated by the words "bestused before the end of....." followed by either:- the date itself, or- details of where it appears on the packaging.The said date shall be clearly expressed and shall consist of either the month and year or the day, month and year in that order. Where this requirement is applicable, the information shall be supplemented by an indication of the conditions which must be satisfied to guarantee the stated durability. The indication of the date of durability shall not be mandatory for cosmetic products with a minimum durability of 30 months;(d) an indication of the period of time after opening for which the product can be used without any harm to the consumer in the case of cosmetic products with a minimum durability of 30 months. This information shall be indicated by the open jar symbol given in Part 1 of Schedule 8 together with an indication of the period of time after opening followed by the period which shall be expressed in months and/or years;(e) any particular precautions to be observed in use, especially those listed in Schedules 3, 4, 6, and 7 in the columns headed "Conditions of use and warnings which must be printed on the label". Such information shall include any special precautionary information on the cosmetic product for professional use. Where this is impossible for practical reasons, anenclosed leaflet, label, tape or card must contain that information and to which the consumer is referred either by abbreviated information or by use of the symbol given in Part 2 of Schedule 8. Any such reference shall appear on the container and on the packaging;(f) the batch number of manufacture or the reference for identifying the goods. Where this is impossible for practical reasons because the cosmetic products are too small, such information need appear only on the packaging;(g) the function of the cosmetic product, unless it is clear from the presentation thereof;(h) a list of ingredients in descending order of weight as determined at the time at which the said ingredients were added to the product. That list shall be preceded by the word "ingredients".
(2) (a) The particulars referred to in sub-paragraphs (b), (c), (d) (e) and (g) ofparagraph (1) shall be in the Irish or in the English language, providedalways that this shall not prohibit the additional use of other languages.(b) The particulars referred to in sub-paragraph (h) of paragraph (1) shall be in
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a language easily understood by the consumer and may be indicated on thepackaging alone.Schedule 1 (Regulation 4(1))
Illustrative list by Category of Cosmetic Products:
- creams, emulsions, lotions, gels and oils for the skin (hands, face, feet, etc.).- face masks (with the exception of peeling products).- tinted bases (liquids, pastes, powders).- make-up powders, after-bath powders, hygienic powders, etc.- toilet soaps, deodorant soaps, etc.- perfumes, toilet waters and eau de cologne.- bath and shower preparations (salts, foams, oils, gels, etc.).- depilatories.- deodorants and antiperspirants.- hair care products.- hair tints and bleaches.- products for waving, straightening and fixing.- setting products.- cleansing products (lotions, powders, shampoos).- conditioning products (lotions, creams, oils).- hairdressing products (lotions, lacquers, brilliantines).- shaving products (creams, foams, lotions, etc.).- products for making up and removing make-up from the face and the eyes.- products intended for application to the lips.- products for care of the teeth and the mouth.- products for nail care and make-up.- products for external intimate hygiene.- sunbathing products.- products for tanning without sun.- skin-whitening products.- anti-wrinkle products.
Schedule 3 (Regulation 8(1)(b)) Part 1
List of substances which cosmetic products must not contain except subject to the restrictions and conditions laid down:
Reference No. 8
Substance:m- and p-Phenylenediamines, their N-substituted derivatives and their salts; N-substituted derivatives of o-Phenylenediamines1, with the exception of those derivatives listed elsewhere in this Schedule
Field of Application and / or Use:Oxidizing colouring agents for hair dyeing -(a) general use(b) professional use
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Maximum authorized concentration in the finished cosmetic product:6% calculated as free base
Conditions of Use and Warnings which must be printed on the Lable: (a) – Contains phenylenediamines. Can cause an allergic reaction. Do not use to dye eyelases or eyebrows.(b) – Contains phenylenediamines. For professional use only. Can cause an allergic reaction. Wear suitable gloves.
Reference No. 12
SubstanceHydrogen peroxide, and other compounds or mixtures that release hydrogen peroxide, including carbamide peroxide and
Conditions of Use and Warnings which must be printed on the Lable:(a) (b) and (c)- Contains hydrogen peroxide.- Avoid contact with eyes.- Rinse eyes immediately if product comes into contact with them.(a) Wear suitable gloves.
Schedule 2 (Regulation 8(1)(a))
List of substances which cosmetic products must not contain
68. Cadmium and its compounds.289. Lead and its compounds.
Appendix 9.3 Letter Issued to Beauty Salon Operators prior to Survey
Environmental Health Department
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County ClinicSt. Conal’s Hospital
LetterkennyCo. Donegal
( 074) 9123759Fax: (074) 9122592
To: The Proprietor,
Co. Donegal.27/4/2009
Re: EC (Cosmetic Products) Regs., 2004 - 2006 and Survey of Beauty Salons in Co. Donegal
Dear Proprietor,
There are over 100 beauty salons in Co. Donegal. The sale and supply of cosmetics used in beauty salons is governed by the EC (Cosmetic Products) Regulations 2004 – 2006 (SI No. 870 of 2004). Information on these Regulations and the role of the Environmental Health service in relation to them is outlined in the enclosed leaflet.
This service intends to call to a number of beauty salons in Co. Donegal in the coming months in order to assess compliance with these Regulations. This may include sampling of cosmetic products for analysis of contents. Please note that although samples can be taken without payment, you will be reimbursed the cost of the product at wholesale price and there will be no fee for the analysis or results of analysis. At the same time, it is proposed to carry out a pilot survey to assess the health and hygiene precautions that are taken to protect client health within beauty salons. The purpose of this is to independently and objectively gain information on the efficacy of self-regulation within the beauty industry to date with a view to contributing to the development of guidelines of best practice for the industry.
The survey may include any or all of the following:
- facilities available for cleaning and disinfection- personal hygiene procedures- waste disposal- cleaning and sanitising procedures- staff training- sampling / swabbing for microbiological levels
Publication of the survey results will not identify any individual person or premises.
If yours is one of the salons visited by myself (or a colleague), I look forward to meeting you and your co-operation is much appreciated. If you have any queries, please contact me at the above office.
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Yours sincerely,
_____________________________Cora Murray,Senior Environmental Health Officer,Environmental Health Dept.
END
Appendix 9.4 Information Sheet issued with letter to Salons Informing of Microbiological Results:
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Information on Bacteria Tested for in Beauty Salons
Microbiological tests on samples or swabs taken from beauty salons included tests for:
Total Viable Counts (TVC) at 30ºCStaphylococcus aureus
Microorganisms are found everywhere and sterile conditions are not expected. However, implements used to cut or pierce the skin must be sterile i.e. totally free from all living microorganisms. The bacteria listed above were selected to indicate the general level of cleanliness of the sample / surface selected. There are no legal limits or guidelines on the maximum levels of bacteria on products / surfaces etc within beauty salons in Ireland.
The following provides some background information on the organisms tested for:
Total Viable Counts (TVC)
This provides a count of the number of micro-organisms present in the swab or sample. It provides a general reflection of the level of micro-organisms present.To be specific, the count actually represents the number of colony forming units (cfu) per g (or per ml or per area swabbed) of the sample.
Staphylococcus aureus (S. aureus)
Staph aureus is commonly carried on the skin and in the nose of humans, where it mostly causes no harm (this is termed as carriage or colonisation by the bacteria). It has been documented that 30% of people continuously carry Staph aureus in their noses, while many other people carry the bacteria, without any ill effects, from time to time.
Colonisation with Staph aureus is NOT the same as infection with Staph aureus:
Colonisation is when someone carries a bacteria around with them without any ill effects
Infection is when a bacteria manages to get through the skin (for example through a cut) or into other parts of the body where it can multiply and cause a person to become ill.
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It can cause a range of illnesses from minor skin infections, such as pimples, impetigo, boils, septic cuts, styes, folliculitis and abscesses, to more serious infections. Staph aureus is mainly spread by direct person-to-person contact (e.g. on unwashed hands) or through indirect contact by touching objects that have been contaminated with the bacteria. If the skin of a client is damaged, S. aureus may gain access to underlying tissues or the bloodstream and cause infection.
Enterobacteriaceae
Enterobacteriaceae, commonly referred to as coliforms, are a family of bacteria that normally inhabit the intestines of humans and animals. They can cause a variety of diseases. They are generally easily destroyed by disinfectants. Because these bacteria are found in large numbers in the gut, they are transmitted most often via the faecal / oral route as a result of inappropriate hand washing after contact with faeces or by drinking contaminated water.
Pseudomonas spp.
Pseudomonads are a group of bacteria found commonly in soil and other natural environments. Although many types of pseudomonads have been identified, the one that most commonly causes infection is Pseudomonas aeruginosa.
Where is it found?Pseudomonas aeruginosa is sometimes called a 'water loving bug', because of its ability to grow and multiply easily in water. Foot spas, hydrotherapy pools, Jacuzzis and hot tubs are a risk because of the combination of water, warmth, aeration and human contamination providing ideal growth conditions for these bacteria.
What are examples of pseudomonas infections?Pseudomonas aeruginosa can cause infections of the lung, eye, ear, and skin, blood, urinary tract and wound infections, particularly in burn wounds.
How do you get pseudomonas infections?A person can acquire a pseudomonas infection in various ways. For example, external ear infections after swimming in contaminated water, and infected wounds through contact with contaminated solutions, hands or equipment, such as a contaminated foot spa.
Who is most likely to get pseudomonas infections?Anyone can get a pseudomonas infection, although pseudomonads rarely attack healthy individuals in the community. Generally,
people who are at most risk of getting pseudomonas infections and becoming seriously ill are those who have a weak immune system, for example, cancer patients undergoing treatment, the very sick, the very young, the very old and people with burns.(Ref. http://www.health.qld.gov.au/ph/Documents/cdb/19687.pdf July 2003)
END
Appendix 9.5 Information Sheet Accompanying Chemical Analysis Results
During 2009, a selection of cosmetic product samples were taken from various outlets throughout Co. Donegal and analysed under the EC (Cosmetic Products) Regs., 2004 – 2006.
The following parameters were tested for in the cosmetic product examples given:
The above Regulations stipulate restrictions and conditions of use for the above parameters.
p-Phenylanediamine
p-Phenylanediamine helps to impart colour to hair. It is permitted under the above Regulations as an oxidising colouring agent for dying hair for both general and professional use in a maximum concentration of 6% calculated as freebase. Conditions of use and warning must be printed on the label i.e. when the product is for both general and professional use, the label must state “contains phenylenediamines” and “can cause an allergic reaction”. Those for sale to the public must also state “do not use to dye eyelashes or eyebrows” while those for professional use must state “for professional use only” and “wear suitable gloves”.
This is because of the health risks associated with its use. Exposure to p-phenylenediamine may produce eczema , bronchial asthma, gastritis, skin rash and death. It can cross react with many other chemicals and can cause photosentisitation.
Hydrogen Peroxide
This substance is added to cosmetic products as an oxidising agent used to form dyestuffs during hair dyeing and to oxygenate stains on the teeth.
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Under the above Regulations, hydrogen peroxide and other compounds or mixtures that release it are restricted to the following limits when carrying out the associated activity:
Field of Application or Use: Max. concentration in the finished product:(a) Hair care preparations 12% H2O2 (40 volumes) present or released.(b) Skin care preparations 4% H2O2 present or released.(c) Nail hardening preparations 2% present or released.(d) Oral hygiene products 0.1% H2O2 present or released.
The conditions of use applicable to (a), (b) and (c) above and the warnings that must be printed on the label of such products are: “contains hydrogen peroxide”, “avoid contact with eyes”, “rinse eyes immediately if product comes into contact with them” and also applicable to hair care products, “wear suitable gloves”.
There are health risks associated with the use of hydrogen peroxide - it is an irritant of the eyes, mucous membranes and skin. Undiluted, it can cause burns of the skin and mucous membranes.
Heavy Metals: Lead and Cadmium
Under the above Regulations, lead and cadmium and their compounds are banned as ingredients of cosmetic products. However, the Regulations allow for traces of these metals where such traces “are technically unavoidable in the context of good manufacturing practice and could not reasonably have been removed during or after manufacture.”
The health effects of heavy metals such as lead and cadmium are widely reported. Lead is poisonous in all forms. It is one of the most hazardous of toxic metals because its poison is cumulative and its toxic effects are many and severe. Among them are leg cramps, muscle weakness, numbness, depression, brain damage, coma and death.Lead can effect children’s’ mental development and intelligence.
Cadmium accumulates in kidneys where it can cause kidney damage. It takes a long time before cadmium that has accumulated in kidneys is excreted from the body. Mercuric iodide can also damage the central nervous system and the skin.
(Ref. Ruth Winter, “A Consumer’s Dictionary of Cosmetic Ingredients”).
END.
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Appendix 9.6 Breakdown of Microbiological Results in Beauty Salons:
Swab of No. of swabs
Lowest result (cfu per area swabbed / per g or per ml)
Highest result(cfu per area swabbed / per g or per ml
* 29 out of the 30 salons were assessed for these criteria
END
Appendix 9.8. Implementation of Report Recommendations
The above is envisaged in the following stages:
Stage 1 Survey of Beauty Salons (completed in Co. Donegal)
Stage 2 Provision of training for specific Environmental Health personnel
Stage 3 Development of a ‘Guide to Good Practice’ for hygiene within beauty salons
Stage 4 Dissemination of Information to wider Environmental Health service
Stage 5 Development of training material to contribute to the training of Beauty Therapists
Stage 6 Contribution to the Development of an Awards System in conjunction with
other bodies e.g. trade, beauty industry associations.
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Stage 7 Dissemination of information to the public regarding expected standards
END
Appendix 9.9 Abbreviations
BABTAC - British Association of Beauty Therapy and CosmetologyCIBTAC - Confederation of International Beauty Therapy & CosmetologyCIDESCO- Comite International D'esthetique et de Cosmetologie CIEH – Chartered Institute of Environmental Health EHOA – Environmental Health Officers’ AssociationFETAC – Further Education and Training Awards CouncilFHT – Federation of Holistic TherapiesHABIA - Hairdressing and Beauty Industry AuthorityIBPA – Irish Beauty Professionals’ AssociationITEC – Irish Training & Educational CentreNABTET – National Agency for Beauty Therapy Education and TrainingNSAI – National Standards Authority of IrelandNVQ – National Vocational Qualifications
END
Appendix 9.10 Draft Guide to Good Practice in Beauty Salons
Environmental Health Department
County ClinicSt. Conal’s Hospital
LetterkennyCo. Donegal
( 074) 9123759Fax: (074) 9122592
Nov 2009
DRAFT GUIDE TO GOOD PRACTICE IN BEAUTY SALONS
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EC (Cosmetic Products) Regs., 2004 - 2006
All cosmetic products sold must comply with the above Regulations (see enclosed leaflet “HSE Environmental Health – Retail Sales of Cosmetic Product” for reference)
It is advisable to keep a record of suppliers of all cosmetic products to your premises and the product batch numbers.
Recommendations Regarding Practices within the Beauty Salon
Facilities for Cleaning:
1. Separate facilities for cleaning tools, equipment etc. should be provided in or within easy access to the treatment room(s) e.g. a sink in a hallway from which the treatment room(s) are directly accessed. A sink in a toilet area is not suitable.
2. A means of supplying constant and instant running hot as well as cold water at each sink / whb used within the salon should be provided e.g. by means of an under-sink immersion, connection to the central hot water heating system etc.
3. A supply of hot water should be made available at all times during which the salon is in use.
Facilities for Hand washing:
1. A wash hand basin for washing hands as required for the treatment of clients should ideally be provided and located in each treatment room or alternatively at an easily accessible location to the treatment room(s).
2. Each wash hand basin should be provided with a constant and instant supply of running hot and cold water.
3. A supply of liquid soap should be available at each wash hand facility at all times.4. Single use paper towels are preferred to fabric reusable towels for hand-drying.
Laundry:
1. A covered container lined with a plastic bag should be provided for the storage of cloth items awaiting washing
2. Reusable cloth items (e.g. towels / face cloths / headbands / blankets / duvets / foot or hand mittens / gowns / couch covers / sarongs / floor rugs) should be washed at a minimum temperature of 60 ºC in the washing machine.
3. Re-usable cloth items with direct client contact should be used on one client only before being laundered. Reusable items with indirect client contact e.g. blankets on couches covered with couch roll or similar covering should be laundered once a week or more frequently, as required.
Storage of Equipment:
1. Equipment awaiting use should be stored in a manner so as to reduce the likelihood of contamination e.g. stored up off the floor on suitable shelving or other storage.
Services - Ventilation:
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1. A suitable means of ventilation should be provided in each of the treatment rooms by (a), (b) or (c) below and the toilet area(s) by (a) or (b) below:
a) natural means e.g. an openable window or a permanent vent in an outer wall or
b) sufficient mechanical extract ventilation ducted directly to the outer air c) air conditioning to which air is supplied directly from the outer air
2. Mechanical extract ventilation ducted directly to the outer air should be provided in the spray tanning area. The extract fan should be of adequate strength and located so as to remove all traces of overspray.
Policies:
Disposable Gloves:
1. Disposable gloves should be worn where there is or may be contact with mucous membranes (e.g. during intimate waxing) or blood or serum (e.g. in case of blood spotting during waxing). The use of disposable gloves is recommended for each of the following treatments:
waxing electrolysis extractions application of nail extensions eyebrow tweezing red vein treatment application of tooth jewellery
Gloves should be discarded after each client. Wearing gloves is not a replacement for washing hands.
Patch Tests:
1. A patch test should be carried out regularly on each client when attending for the following treatments:
waxing tinting of eye brows or eyelashes eyelash perming application of false eyelashes application of semi-permanent make-up laser and intense pulsed light treatments self tanning hair bleaching microdermabrasion
However, carrying out a patch test on each client each time a treatment is administered is recommended. The skin may become sensitive to a particular product even after many years of use and an allergic reaction may occur.
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2. For certain treatments e.g. eyebrow / eyelash tinting, eyelash perming, hair bleaching, a patch test should be carried out a minimum of 48 hours before treatment. Guidance should be taken from the instructions provided with the product or by the manufacturer of the equipment concerned.
3. A patch test should be carried out on each client if a different brand or type of cosmetic product is used from the previous test.
Personal Hygiene:
1. Fingernails should be kept short, clean and without enamel 2. Hands should be washed before and after treating a client, involving any physical
contact with the client or any possible blood or body fluid exposure.
Waste Disposal:
1. Lidded bins should be provided for the storage of general waste
2. Most waste material can be disposed of as general waste and placed into the normal refuse containers. However, some treatments can produce contaminated waste including waxing, electrolysis, microdermabrasion and extractions. Any cotton wool, tissues or cloths with any blood spots or human tissue should be double-bagged prior to disposal by landfill.
3. Boxes of used needles should be stored in a ‘sharps box’ labelled as ‘contaminated’ and ‘for incineration’ prior to disposal. Sharps boxes should not be filled to the top so as to avoid accidental injury
4. Boxes of used needles should only be disposed of by collection by permitted collectors. A list of permitted collectors can be obtained from your local authority.
Cleaning of Implements / Tools:
Sterilisation is the total removal or destruction of all living microorganisms. Equipment used to cut or pierce the skin must be sterile. Sterilisation may only be performed on ‘hard’ reusable implements e.g. metal scissors, tweezers.
Disinfection is the destruction of most microorganisms. Disinfectants do not kill all bacteria but they reduce them to an acceptable level.
Cleaning is the physical process that removes dirt, dust, soil and organic matter along with a large proportion of microorganisms from an object.
1. Disinfectant solutions used to steep tools should be changed regularly in line with manufacturers’ instructions. The preparation and use of a new solution of disinfectant daily is recommended as many disinfectants deteriorate when stored or are inactivated by contaminants.
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2. Re-usable tools such as sponges, make-up brushes, some manicure / pedicure tools (e.g. foot files, toe separators etc) should be adequately cleaned, by washing in warm soapy water, rinsing followed by disinfection e.g. a) using chemicals such as ‘Barbicide’ etc. or b) by heat e.g. boiling water / steam / hot air, as appropriate. Thorough cleaning is essential before disinfection so as to remove all organic matter such as skin tissue, dirt etc.
3. An effective disinfectant(s) suitable for use on tools, equipment, surfaces etc within a beauty salon should be used e.g. hand-sprays, tea tree oil or similar preparations used as skin disinfectants or anti-bacterial soap for hand-washing are not suitable for disinfecting tools or equipment.
4. An adequate supply of effective disinfectant(s) suitable for use on tools, equipment, surfaces etc. within the beauty salon should be available.
Equipment for Sterilisation and Disinfection:
1. ‘Hard’, reusable implements e.g. commodone extractors, metal scissors, tweezers, cuticle knives etc. used to cut or pierce the skin should be sterilised using suitable sterilisation equipment such as a glass-bead steriliser or an autoclave. The provision of equipment for sterilising such implements between use on clients is recommended.
Traditional benchtop steam autoclaves (non- vacuum) require training in correct use and maintenance. They are considered suitable for solid instruments. A vacuum autoclave is needed for hollow instruments or tubes. It is important that a vacuum autoclave has a vacuum drying cycle incorporated. It is essential that instruments are thoroughly cleaned before they are sterilised.
2. Please note that Ultraviolet (UV) cabinets do not sterilise and have limited disinfection properties – they are efficient in storing previously disinfected equipment. UV light inactivates microorganisms on the surface that it hits and is not suitable for the disinfection of tools such as make-up brushes, sponges or items with hidden surfaces.
3. UV light cabinets require maintenance e.g. bulbs in UV cabinets have a limited lamp life and bulbs should be changed according to manufacturers’ instructions. Although it may appear that bulbs are working efficiently, their output depletes over time. The life expectancy of the bulb in your UV cabinet should be checked with your supplier.
4. A note or record should be kept of the date each time the UV bulb(s) in the UV cabinet(s) is / are replaced.
The following cleaning and disinfection procedure is recommended:
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After each client:
1. drain the water from the foot spa basin or bowl and remove any visible debris.2. clean the surfaces of the foot spa with warm water and detergent3. rinse with clean water and drain4. after cleaning, disinfect the surfaces with a suitable disinfectant for 10 minutes
or the minimum contact time required on the label of the disinfectant, turning the unit on circulate the disinfectant for the entire contact time.
5. drain and rinse with clean water
Nightly:
1. remove the filter screen, inlet jets and all other removable parts from the basin and clean out any debris trapped behind or in them.
2. using a brush, scrub these parts with warm water and detergent3. rinse the removed parts with clean water and place them back into the basin
apparatus4. fill the basin with clean water and disinfectant, following label directions.
Turn the unit on and circulate the system with the liquid for 10 minutes or follow the minimum contact time required on the label of disinfectant.
5. after disinfection, drain, rinse and allow to air dry or dry with disposable paper towel.
For Simple Basins:
1. drain the basin and remove any visible debris2. scrub the bowl with a clean brush in warm water and detergent.3. rinse and drain4. disinfect the basin surface with a suitable disinfectant, preferably by steeping
(i.e. rather than spraying) in a disinfectant solution for 10 minutes or the minimum contact time required on the label of disinfectant.
5. drain the basin, rinse with clean water and allow to air dry or dry with disposable paper towel.
2. Other Equipment:
The following relates to equipment such as UV cabinets, hot towel cabinets, trolleys, wax pots, steamers, electrical equipment (e.g. microdermabrasion machines, laser machines, body electrical equipment), hot stone massage tank, platinum detox basin, spray tanning equipment, goggles etc:
Equipment should be adequately cleaned and disinfected, by washing all surfaces in soapy water (or wiping with a clean cloth in warm soapy water) followed by rinsing in clean water and, most importantly, disinfection e.g. by chemicals such as surgical spirits.
Practices:
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1. Suitable covering e.g. couch roll, should be placed on floor areas upon which clients walk barefooted. Alternatively, disposable foot covers should be provided for use by the client.
2. The use of single use disposable tools / items, where possible, is recommended e.g. use of cotton wool in lieu of toe separators / wooden spatulas in lieu of metal ones
3. The use of single client tools is recommended e.g. use of single client pots, cartridges and disposable applicator heads for waxing.
4. In all cases, in order to reduce the risk of cross infection, applicators should not be put into a cosmetic product again once it has touched the clients skin, whether using either disposable or washable applicators i.e. double dipping must be avoided. This practice relates to the application of make-up (when using either disposable applicators or washable brushes) or waxing (using a new spatula for each dip into the wax pot or using a single spatula to take wax from the pot and then allowing the wax to drop onto another spatula for application on the client - sometimes referred to as the ‘spooning method’)
5. Creams, lotions and sprays should be dispensed from pump or spray bottles where possible. Otherwise, products must be distributed with a disposable spatula.
6. Wax remaining in the base of a wax pot should not be decanted into a fresh pot of wax.
7. Towels should be changed after every client
After-Care Leaflets:
After care leaflets should be provided for first time clients having availed of the following treatments:
Microdermabrasion (after care & home care advice) Semi-permanent make-up (after care advice) Ultrasound (home care advice) Waxing (home care advice) Electrolysis (home care advice) Laser and pulsed light treatment (home care advice) Artificial nail systems (after care advice) Self-Tanning Treatments (after care advice) Red vein removal (after care & home care advice) Body electrical treatments (home care advice) Spa treatments (home care advice)
Client Record Cards:
Updated records outlining the treatments given to each client together with dates, patch / sensitivity tests and any contra-indications should be kept for the following treatments:
electrical epilation laser and pulsed light treatments eye lash and eye brow tinting manicure and pedicure waxing
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nail art body and facial electrical treatments microdermabrasion
Training:
The qualifications of and documents relating to training received by all Therapists, whether whole-time or part-time, should be available on the premises for inspection by members of the public. This could be achieved by public display within the salon or by being available in a display folder.
First Aid Kit:
A first aid box should be provided for use in the salon. The minimum contents of a first aid box is:
- guidance leaflet- 20 individually wrapped, sterile adhesive dressings of various sizes- 2 sterile eye pads- 4 individually wrapped triangular badges- 6 safety pins- 6 medium sized and 2 large individually wrapped, sterile, unmedicated
Salons with laser and / or intense pulsed light equipment are advised to follow manufacturers’ guidelines in carrying out specific risk assessment to highlight all safety risks and to put in place any remedial works or safeguards necessary to protect staff and clients.
Medical Clinic
To practice in the Republic of Ireland, a medical practicioner must be registered with the Irish Medical Council and is given a registration number. If you currently, or propose to, offer your salon as a medical clinic, you can check the qualifications of the medical practicioner concerned with the Medical Council of Ireland based at Lynn House, Portobello Court, Lower Rathmines Rd., Dublin 6 Tel. 01 4983100; E mail: [email protected]. You can also access their website at www.medicalcouncil.ie with the registation number of the person involved to assist in verifying qualifications.
These are draft recommendations only that have been identified as a result of a survey in Co. Donegal. They have been compiled from various sources and do not purport to be exhaustive. The HSE does not claim any responsibility for the consequences of acting upon the recommendations or from the omission of any recommendations.
Ref. 5: http://www.nabtetgroup.ie/index.htmlRef. 6 ‘Nail Infection - Tool Kit for Raising Awareness of the Need to Prevent Spread of Infection through Nail Bars’ accessible on the CIEH website.
Ref. 10 Winthrop, K et al “An Outbreak of Mycobacterial Furunculosis Associated with Footbaths at a Nail Salon” The New England Journal of Medicine - Volume 346:1366-1371; May 2, 2002, Number 18
Ref 11: Huijsdens et al Methicillin-resistant Staphyloccus aureus in a Beauty Salon, the Netherlands, Emerging Infectious Diseases, www.cdc.gov/eid, Vol. 14, No. 11, November 2008, pp 1797-1799
Ref 12: Bove, JP & Conrad, J Nailing the Hazards EHP 31 March 2006 pp 12-14
Ref. 13, Environmental Health News, 7 Sept 2006
Ref. 14 Beauty Bars “are health risk’’, Environmental Health News, 24 Nov., 2006
Ref. 15 Hatton, Phillip, Hygiene for Hairdressers and Beauty Therapists, 3rd Ed., (1998), Addison Wesley Longman, UK
Ref. No 16 Management of Spa Pools: Controlling the Risks of Infection, Health Protection Agency, London. March 2006
Ref 17 http://www.dow.com/productsafety
Ref. 18 http://www.jtbaker.com/msds (material safety data sheet)
Ref. 21 White, Maeve and Melia, Paul Unregulated beauty industry a time bomb, health experts warn in The Irish Independent, 21 June 2005
Ref 22 Treacy, Dr. Patrick, Condemnation of laser deregulation in the Irish Medical Times, posted in Letters on 14 June 2008
Ref. 23: Personal communication with the Irish Medicines Board, 2009
Bibliography
Ref 24: IBPA Standard of Excellence Award criteria received in personal communication
Ref 25. Antczak, Dr. Stephen and Gina Cosmetics Unmasked – your family guide to safe cosmetics and allergy-free toiletries (2001) HarperCollins Publishers, London
Ref. 26 Dunn, P.B. Worries over safety in Nail Salons’ from http://news.eltecolote.org/news
Ref. 27 Winters, Ruth A Consumer’s Dictionary of Cosmetic Ingredients (1999) 5th Ed. Three Rivers press, New York.
Ref. 25 NSAI I.S. 380:2007 Beauty and Holistic Therapy Management of Training Centres (2007) National Standards Authority of Ireland, Glasnevin, Dublin 9, Ireland.
Ref 28 Habia, Code of Practice for Waxing January 2007
END.
Disclaimer: This report is for information purposes only. While every effort has been made to ensure that all information is accurate, the HSE or its employees do not accept any responsibility or liability for direct, incidental or consequential damages as a result of the use of this information.
For further information, contact Cora Murray or Jenny Fortune, Environmental Health Dept., HSE, Co. Clinic, Letterkenny, Co. Donegal. Tel. 00 353 (0) 74 9123759 Email: [email protected] or [email protected].
Produced by: Environmental Health Department, HSE West, Co. Donegal
