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:
Potential Health Risks
Role of the Environmental Health Officer
Scope & Limitations
4.3 Survey development and conduct
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
5.3.4. Storage of Equipment
5.3.5. Services – sanitary accommodation, heating, lighting and ventilation
5.3.6. Policies – disposable gloves, patch tests, personal hygiene
5.3.9. Equipment for Sterilisation and Disinfection
5.3.10. Cleaning of Implements / Tools
5.3.12. After-Care Leaflets:
5.3.13. Client Record Cards:
5.3.15. First Aid Kit:
5.3.16. Laser and Intense Pulsed Light Treatment:
5.3.17. Medical Clinic
5.3.18 General Observations
9.1 Description of beauty treatments
9.2 Extracts from EC (Cosmetic Products) Regs., 2004 – 2006
9.3. Letter issued to operators prior to survey
Information sheet accompanying microbiological results
Information sheet accompanying chemical analysis results
Detailed Breakdown of Microbiological Results Obtained
Treatments Offered by Beauty Salons
9.8 Implementation of Report Recommendations
9.10 Draft Guide to Good Practice in Beauty Salons
References and Bibliography
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.
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.
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:
Potential cause / source
Skin and other infection
Re-use of towels, tools, materials without proper cleaning and disinfection
Re-use of disposable tools, materials
Hepatitis / HIV
Re-use of crystals during medical microdermabrasion
Manicures / pedicures / application of acrylic nails / poor cleaning / poor training /
Mouth and gum irritation / tooth damage
Allergic reaction / skin irritation
Failure to carry out patch testing prior to application of e.g. dye, bleach
Fungal 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.
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
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.
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.
To determine compliance levels with the EC (Cosmetic Products) Regs., 2004 - 2006 among beauty / nail salons in Co. Donegal and
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
To make recommendations as to any improvements that could be made and
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.
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
provision of information on treatments to customers
compliance with EC (Cosmetic Products) Regs., 2004 - 2006
training of therapists employed
To assess the standard of hygiene by taking environmental swabs & / or samples for microbiological analysis.
To sample cosmetic products used in beauty salons for analysis under the EC (Cosmetic Products) Regs., 2004 - 2006
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.
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.
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.
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:
cleaning facilities and equipment available
cleaning techniques applied
policies on hand washing, disposal glove use and patch testing
practices relating to use of delivery of treatments including use of tools, towels, cosmetics,
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.
Enterobacteriaceae (not tested for regarding foot spas)
Pseudomonas spp. (tested in swabs from foot spas only)
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 theexterior 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.
Enterobacteriaceaeare 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 analysis
5.3 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
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.
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:
Moisturiser / tanning cream / cleanser / body butter / foundation make-up
Lead and cadmium
9 out of 9 compliant
Table 220.127.116.11 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 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.
No. of swabs
Make-up brush, Eye shadow /
Make-up Lip & eye pencil Lipstick
Sinks / WHBs
Wax from wax pot
Toe separators /
Manicure & Pedicure tools
Heads of facial machine / Interior of UV cabinet /
Hot towel cabinet / Towels /Surface of trolley /Bowl / Plastic sheet for waxing /
Hot stone in tank
Sun bed surface
Total N =
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.