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COVID19 Body Art Studio Guidelines for California (CAL OSHA)

The state of California has finally established a date for piercing (and tattoo) studios to reopen. It’s contingent on the individual counties to approve body art for resuming (for us the city of Long Beach), but Friday, June 19th is the earliest date anyone should be offering services like tattooing and body piercing in our state.

Our great clients have been patient during this process and so has our staff. At this time, June 14th, we haven’t yet heard from the City of Long Beach about whether or not studios in our city can open. Once we know we’ll be updating our site to reflect the updated information.

New Flower Studio Body Piercing and its staff have experienced the consequences of the COVID19 pandemic like everyone else. Health and safety are within our corporate values and worldview, and we promise that when allowed to return to piercing we’ll exceed all expectations of the city of Long Beach, County of Los Angeles, and state of California.

Below you can see the official statement (13 pages) from CAL OSHA. The first 9 pages apply universally to all personal services like tattooing and piercing. Body art is specifically addressed on page 12.

OVERVIEW
On March 19, 2020, the State Public Health Officer and Director of the California Department of Public Health issued an order requiring most Californians to stay at home to disrupt the spread of COVID-19 among the population.

The impact of COVID-19 on the health of Californians is not yet fully known. Reported illness ranges from very mild (some people have no symptoms) to severe illness that may result in death. Certain groups, including people aged 65 or older and those with serious underlying medical conditions, such as heart or lung disease or diabetes, are at higher risk of hospitalization and serious complications. Transmission is most likely when people are in close contact with an infected person, even if that person does not have any symptoms or has not yet developed symptoms.

Precise information about the number and rates of COVID-19 by industry or occupational groups, including among critical infrastructure workers, is not available at this time. There have been multiple outbreaks in a range of workplaces, indicating that workers are at risk of acquiring or transmitting COVID-19 infection. Examples of these workplaces include long-term care facilities, prisons, food production, warehouses, meat processing plants, and grocery stores.

As stay-at-home orders are modified, it is essential that all possible steps be taken to ensure the safety of workers and the public.
Key prevention practices include:
✓ physical distancing to the maximum extent possible,
✓ use of face coverings by employees (where respiratory protection is not required) and fitness facility patrons,
✓ frequent handwashing and regular cleaning and disinfection,
✓ training employees on these and other elements of the COVID-19 prevention plan.
In addition, it will be critical to have in place appropriate processes to identify new cases of illness in workplaces and, when they are identified, to intervene quickly and work with public health authorities to halt the spread of the virus.

COVID-19 INDUSTRY GUIDANCE: Expanded Personal Care Services
Release date: June 12, 2020
Recommended effective date no sooner than: June 19, 2020
All guidance should be implemented only with county health officer approval following their review of local epidemiological data including cases per 100,000 population, rate of test positivity, and local preparedness to support a health care surge, vulnerable populations, contact tracing, and testing.

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PURPOSE
This document provides guidance for expanded personal care services, which includes personal care that requires touching a client’s face, e.g. facials, electrolysis, and waxing. This guidance applies to esthetician, skin care, and cosmetology services; electrology; nail salons; body art professionals, tattoo parlors, and piercing shops; and massage therapy (in non-healthcare settings). This guidance is intended to support a safe, clean environment for workers and customers. Operators must acknowledge that lessees should only resume operations when they are ready and able to implement the necessary safety measures to provide for their safety and that of their customers.

The guidance is not intended to revoke or repeal any employee rights, either statutory, regulatory or collectively bargained and is not exhaustive, as it does not include county health orders, nor is it a substitute for any existing safety and health-related regulatory requirements such as those of Cal/OSHA or the California Board of Barbering and Cosmetology.1 Stay current on changes to public health guidance and state/local orders, as the COVID-19 situation continues. Cal/OSHA has more comprehensive guidance on their Cal/OSHA General Guidelines on Protecting Workers from COVID-19 webpage. CDC has additional requirements in their guidance for businesses and employers.

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Worksite Specific Plan
• Establish a written, worksite-specific COVID-19 prevention plan at every location, perform a comprehensive risk assessment of all work areas and work tasks, and designate a person at each facility to implement the plan.
• Identify contact information for the local health department where the facility is located for communicating information about COVID-19 outbreaks among employees.
• Train and communicate with employees and employee representatives on the plan.
• Regularly evaluate the workplace for compliance with the plan and document and correct deficiencies identified.
• Investigate any COVID-19 illness and determine if any work-related factors could have contributed to risk of infection. Update the plan as needed to prevent further cases.
• Identify close contacts (within six feet for 15 minutes or more) of an infected employee and take steps to isolate COVID-19 positive employee(s) and close contacts.
• Adhere to the guidelines below. Failure to do so could result in workplace illnesses that may cause operations to be temporarily closed or limited.
Topics for Employee Training
• Information on COVID-19, how to prevent it from spreading, and which underlying health conditions may make individuals more susceptible to contracting the virus.
• Self-screening at home, including temperature and/or symptom checks using CDC guidelines.
• The importance of not coming to work if employees have symptoms of COVID-19 as described by the CDC such as a frequent cough, fever, difficulty breathing, chills, muscle pain, sore throat, recent loss of taste or smell, or if they or someone they live with have been diagnosed with COVID-19.

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• To seek medical attention if their symptoms become severe, including persistent pain or pressure in the chest, confusion, or bluish lips or face. Updates and further details are available on CDC’s webpage.
• The importance of frequent handwashing with soap and water, including scrubbing with soap for 20 seconds (or using hand sanitizer with at least 60% ethanol (preferred) or 70% isopropanol (if the product is inaccessible to unsupervised children) when employees cannot get to a sink or handwashing station, per CDC guidelines).
• The importance of physical distancing, both at work and off work time (see Physical Distancing section below).
• Proper use of face coverings, including:
o Face coverings do not protect the wearer and are not personal protective equipment (PPE).
o Face coverings can help protect people near the wearer, but do not replace the need for physical distancing and frequent handwashing.
o Face coverings must cover the nose and mouth.
o Employees should wash or sanitize hands before and after using or adjusting face coverings.
o Avoid touching eyes, nose, and mouth.
o Face coverings should be washed or discarded after each shift.
• Ensure temporary or contract workers at the facility are also properly trained in COVID-19 prevention policies and have necessary supplies and PPE. Discuss these responsibilities ahead of time with organizations supplying temporary and/or contract workers.
• Information on employer or government-sponsored leave benefits the employee may be entitled to receive that would make it financially easier to stay at home. See additional information on government programs supporting sick leave and worker’s compensation for COVID-19, including employee’s sick leave rights under the Families First Coronavirus Response Act and employee’s rights to workers’ compensation benefits and presumption of the work-relatedness of COVID-19 pursuant to the Governor’s Executive Order N-62-20.

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Individual Control Measures and Screening
• Provide temperature and/or symptom screenings for all employees at the beginning of their shift and any vendors, contractors, or other workers entering the establishment. Make sure the temperature/symptom screener avoids close contact with workers to the extent possible. Both screeners and employees should wear face coverings for the screening.
• If requiring self-screening at home, which is an appropriate alternative to providing it at the establishment, ensure that screening was performed prior to the worker leaving the home for their shift and follows CDC guidelines, as described in the Topics for Employee Training section above
• Encourage workers and customers who are sick or exhibiting symptoms of COVID-19 to stay home.
• Employers should provide and ensure workers use all required protective equipment, including eye protection, gloves, and face shields where necessary.
• Employers should consider where disposable glove use may be helpful to supplement frequent handwashing or use of hand sanitizer; examples are for workers who are screening others for symptoms or handling commonly touched items.
• Disposable gloves should be worn for services that require them. Wearing gloves should be done in conjunction with regular hand washing and is not a substitute for regular hand washing.
• Workers must wear a face covering throughout the entire interaction with the customer. Customers must wear face coverings at all times while in the facility, except when the face covering must be removed for the performance of services involving that part of the face. Facilities should provide clean face coverings for staff and make them available to customers, if possible.
• Contact customers before visits to confirm appointments and ask if they or someone in their household is exhibiting any COVID-19 symptoms. If the customer answers in the affirmative reschedule the appointment. Such communication can be also be done via phone, app, email, or text to remind customers that they should only come to the facility for their appointment if they do not pose a health risk to other customers or workers. In order to implement pre-screening protocols and ensure physical distancing protocols, consider suspending walk-in appointment availability.

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• Tell customers that no additional friends or family will be permitted in the facility, except for a parent or guardian accompanying a minor.
• Customers should be temperature and/or symptom screened upon arrival. Be prepared to cancel or reschedule customers who indicate they have any signs of illness.
• Display a set of guidelines for customers that are to be a condition of entry. The guidelines must include instructions to wear face coverings, use hand sanitizer, maintain physical distance from other customers, and they should communicate changes to service offerings. The guidelines should be posted in clearly visible locations, including at entrances, include pictograms, and be made available digitally (e.g. through email).
Cleaning and Disinfecting Protocols
• Ensure that coworkers, fellow tenants, booth renters, and/or staff have coordinated and put a plan in place for cleaning and disinfection at the beginning and end of each shift and in between customers. Perform thorough cleaning in high traffic areas, such as reception areas, and areas of ingress and egress including stairways, stairwells, and handrails.
• Frequently disinfect commonly used surfaces including credit card terminals, counters, reception area seating, door handles, light switches, phones, toilets, and handwashing facilities.
• Evaluate existing hygiene and sanitation protocols and cleaning processes and update where necessary. Use hospital grade, Environmental Protection Agency (EPA)-approved products to clean and disinfect anything the client came in contact with, including treatment tables, face cradles, stools, bolsters, door knobs, side tables, chairs, etc. Follow the product manufacturer’s recommendations for contact time. Use disinfectants labeled to be effective against emerging viral pathogens, diluted household bleach solutions (5 tablespoons per gallon of water), or alcohol solutions with at least 70% alcohol that are appropriate for the surface. Provide workers training on manufacturer’s directions for cleaning and disinfecting and Cal/OSHA requirements for safe use. Workers must be trained on the hazards of cleaning and disinfecting chemicals. Workers using cleaners or disinfectants should wear gloves and other protective equipment as required by the product. Follow the asthma-safer cleaning methods recommended by the California Department of Public Health.
• Since porous surfaces such as chair seats cannot be easily disinfected, consider covering with a plastic or disposable liner and cleaning or disposing of the liner after each customer.

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• All appliances at work stations and in treatment rooms should be properly disinfected between each customer.
o For non-porous implements, such as tweezers or scissors, clean the item with hot, soapy water to remove any physical debris. Rinse and dry the implement completely. Follow by immersing the implement in an EPA-registered disinfectant for the full contact time as stated by the manufacturer’s directions. Items should be removed at the end of contact time, rinsed, and dried with a clean paper towel.
o For electrical implements such as magnifying LED lamps, hot towel warmers, and esthetic devices, clean the implement with a spray or wipe to remove any physical debris. Follow with an EPA-registered disinfectant spray or wipe for the full contact time as noted by the manufacturer’s directions. Use caution when using a spray and be sure your device is unplugged and do not spray into the motor. For electronics such as tablets, touch screens, keyboards, remote controls, and ATM machines, remove visible contamination if present. Follow the manufacturer’s instructions for all cleaning and disinfection products. Consider use of wipeable covers for electronics. If no manufacturer guidance is available, consider the use of alcohol-based wipes or sprays containing at least 60% alcohol to disinfect touch screens. Dry surfaces thoroughly to avoid pooling of liquids.
• To minimize the risk of Legionnaires’ disease and other diseases associated with water, take steps to ensure that all water systems (e.g., drinking fountains) are safe to use after a prolonged facility shutdown.
• Where linens are used, even if the customer does not get under them, the linens should still be removed and the bed or table properly disinfected. Treatment tables must be covered with either clean treatment table paper, a clean towel, or a clean sheet after each use.
• Workers should wear disposable gloves when removing used linens, towels, and other draping, including blankets, and client draping for each treatment. Do not shake the dirty laundry. Place used linens in a lined, lidded receptacle positioned outside the treatment space to minimize the possibility of dispersing virus in the air. Dirty linens should not be used again until properly laundered either by a commercial laundering service or a laundering process which includes immersion in water of at least 160 degrees Fahrenheit for at least 25 minutes. Store all clean linens in a clean, covered place.
• Where possible, do not clean floors by sweeping or other methods that can disperse pathogens into the air. Vacuum wherever possible and use a vacuum with a HEPA filter.

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• Workers should consider changing their own clothes after each customer or wearing scrubs or a clean, launderable or disposable smock, if available.
• Consider removing items (e.g., throw pillows, fabric-lined chairs, seat cushions) with surfaces that cannot be cleaned properly. Have a hard-surfaced, non-porous chair or large hard-surfaced or plastic basket for clients to put their clothes on or in.
• Amenities, including magazines, art books, coffee, water, self-serve stations (unless touchless), and other items for customers, must be removed from reception areas to help reduce touch points and customer interactions. Do not allow food or beverages to be at stations or in treatment rooms.
• Thoroughly clean any product display areas, including all shelving and display cases. Remove and discard any open “test” products and discontinue this practice to help reduce contamination. Add signage to this area to let customers know it is cleaned and disinfected daily.
• Encourage the use of credit cards and contactless payment systems. If electronic or card payment is not possible, customers should come with exact cash payment or check.
• Consider upgrading to touchless faucets, soap and paper towel dispensers, and adding touchless, automatic hand sanitizer dispensers. Ensure soap dispensers and paper towel dispensers are regularly filled.
• Equip reception areas and workstations with proper sanitation products, including hand sanitizer and sanitizing wipes.
• Provide time for workers to implement cleaning practices during their shift. Cleaning assignments should be assigned during working hours as part of the employee’s job duties.
• Workers should avoid sharing phones, tablets, laptops, desks, pens, and other work supplies, wherever possible. Never share PPE.
• Discontinue the use of shared food and beverage equipment in breakrooms (including shared coffee brewers).
• Consider opening treatment room windows, if feasible and within security protocols. Consider installing portable high-efficiency air cleaners, upgrading the building’s air filters to the highest efficiency possible, and making other modifications to increase the quantity of outside air and ventilation in all working areas.
• In addition to the above cleaning and disinfecting protocols cosmetology, barbering, and electrology businesses must follow the existing California Board of Barbering and Cosmetology rules. Additional rules may also apply for businesses at the local, county-level.

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Physical Distancing Guidelines
• Implement measures to ensure physical distancing of at least six feet between and among workers and customers, except while providing the services that require close contact. This can include use of physical partitions or visual cues (e.g., floor markings, colored tape, or signs to indicate to where workers and/or customers should stand).
• Maintain at least six feet of physical distance between each work station area, and/or use impermeable barriers between work stations to protect customers from each other and employees.
• Stagger appointments to reduce reception congestion and ensure adequate time for proper cleaning and sanitation between each customer visit. Consider servicing fewer customers each day or expanding operating hours to allow for more time between customers and suspending walk-in appointments.
• If possible, implement virtual check-in technology to ensure that workers are notified when a customer arrives. Ask customers to wait outside or in their cars rather than congregating in reception areas. Reception areas should only have one customer at a time or the area should be modified to support adequate physical distancing, including removing chairs and sofas or spacing them further apart.
• Take measures at reception desks or other areas where physical distancing cannot be maintained to minimize exposure between workers and customers, such as Plexiglas or other barriers.
• Consider offering workers who request modified duties options that minimize their contact with customers and other workers (e.g., managing inventory or managing administrative needs through telework).
• Require workers to avoid handshakes, fist bumps, hugs, or similar greetings that break physical distance.
• Discourage workers from congregating in high traffic areas, such as bathrooms, hallways, or credit card terminals.
• Close breakrooms, use barriers, or increase distance between tables/chairs to separate workers and discourage congregating during breaks. Where possible, create outdoor break areas with shade covers and seating that ensures physical distancing.
• Adjust any staff meetings to ensure physical distancing. Hold meetings over the phone or via webinar for workers wherever possible.

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Additional Considerations for Esthetician, Skin Care, and Cosmetology Services
• Workers must wear face coverings at all times. Workers should wear a face shield for eye protection (with a face covering) when they are providing services that do not enable the client to wear a face covering.
• Disposable gloves should be worn throughout the entire esthetic service and while performing cleaning and disinfection of all implements and surfaces after each client session.
• Before leaving the treatment room, remove and dispose of gloves, apply proper hand sanitizer or wash hands with soap and water, and use a previously readied disposable barrier, such as a paper towel or sanitizer wipe, to open and close the treatment room door while leaving the room.
• When wax pots are running low and new wax needs to be added, empty any remaining wax and clean and disinfect the wax pot before refilling with new wax. Single use applicators must be disposed of immediately after use in a lined trash bin. The trash bin should have a lid and should be lined with a disposable plastic bag.
Additional Considerations for Electrology Services
• Electrologists must wear face coverings at all times and use disposable gloves during the client’s entire treatment. Electrologists should wear a face shield for eye protection (with a face covering) when they are providing clients treatment on facial or neck areas that do not enable the client to wear a face covering.
• Clients having any other areas treated should be required to wear a face covering throughout the service.
• Tweezers, rollers, and needle holder caps should be properly cleaned and sterilized between each client. This could include the use of an autoclave or placing the items in a sealed pouch and sterilizing them in a dry heat sterilizer. The pouch should not be reopened until the next client’s treatment session begins.
• Where possible, use disposable probes that do not require a probe tip or cap, which will reduce exposure points. If not using disposable probe tips

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or caps, the removable tip or cap of the epilator needle/probe holder must be cleaned and disinfected after each client.
• Needles used for electrolysis must be single-use, disposable, pre-packaged, and sterile and disposed of in an approved sharps container immediately after use. Sharps containers must be discarded in accordance with biomedical waste regulation.
• Heat produced by the electrical current passing through an electrolysis needle is not sufficient to sterilize it.
• Ultrasonic cleaning units, forceps, and all containers, including their removable parts, must be cleaned and disinfected between each client according to the manufacturer’s instructions.
Additional Considerations for Nail Salons
• Workers must wear face coverings at all times, or a respirator where required. Respirators are required where ventilation is insufficient to reduce exposure below permissible exposure limits established in title 8 section 5155. In cases of chemical exposure, only elastomeric respirators with the correct chemical cartridge combined with a particulate filter are appropriate for use.
• During procedures, workers should consider wearing a face shield for eye protection (with a face covering), if available.
• Customers must wear face coverings during the entirety of the service.
• Disposable gloves should be worn throughout the entire service and while performing cleaning and disinfection of all implements and surfaces after each client. Once cleaning is finished, remove and dispose of gloves and apply proper hand sanitizer or wash hands with soap and water.
• Pedicure bowls must be disinfected with an EPA-registered liquid disinfectant that is labeled as a bactericide, fungicide and virucide. Refer to manufacturer’s instructions on mixture. For whirlpool foot spas, air-jet basins or pipeless foot spas, disinfectant must be circulated for at least 10 minutes. For non-whirlpool foot basins and tubs, soak disinfectant in the basin or tub for at least 10 minutes. Foot-spas, basins and pedicure bowls must be properly cleaned and disinfected after every client even if a disposable plastic liner is used.
• Nail salons should use disposable supplies whenever possible. Any non-disposable supplies must be fully disinfected between customers according to the California Board of Barbering and Cosmetology guidelines.

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• All single use items, such as cardboard files, sand-bands for drills and buffers, disposable sandals, toe separators, and applicators, must be used once and immediately thrown away in a lined, lidded trash can.
• To reduce the number of touchpoints, remove the nail polish displays. In the absence of a nail polish display, use a color palette, which is to be cleaned and disinfected after each client use. If the nail polish display is not removed, nail polishes should be cleaned and disinfected before being returned to the display.
• Consider whether it is feasible to install a plastic partition between the worker and client with ample space cut out where hands or feet can be slid underneath to conduct the manicure or pedicure.
• Allow only one manicurist to work at each station and do not allow clients to get multiple services at the same time, such as a manicure and pedicure.
• If fans, such as pedestal fans or hard-mounted fans, are used in the salon, take steps to minimize air from fans blowing directly from one person toward another. If fans are disabled or removed, employers should remain aware of possible heat hazards and take steps to mitigate them.
• Nail salons should consider upgrading existing ventilation to include locally exhausted nail tables.

Additional Considerations for Body Art Professionals, Tattoo Parlors, and Piercing Shops
• Workers must wear face coverings at all times. During procedures, workers should also consider wearing a face shield for eye protection (with a face covering), if available.
• Customers must wear face coverings during the entirety of the tattooing or piercing service.
• Disposable gloves are required throughout the tattooing or piercing service and while performing cleaning and disinfection of all implements and surfaces after each customer session.
• Workers should ensure they wash their hands thoroughly with soap and water or use hand sanitizer immediately before putting on and after removing gloves.
• Suspend piercing and tattooing services for the mouth/nose area.

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• Chairs should be arranged to ensure at least six feet of space between customers. Establishments should consider additional divider shields or other impermeable barriers where appropriate.
• Workers should provide tattooing or piercing services for only one customer at a time.
Additional Considerations for Massage Services (Non-Healthcare Settings)
• Ask clients to wash their hands before any services are provided.
• Workers must wear face coverings at all times and should consider wearing a face shield for eye protection (with a face covering), if available.
• Customers must wear face coverings during the entirety of the massage service.
• Consider alterations to the treatment table setup to support the required cleaning and disinfecting protocols. This could include using disposable face cradle covers and/or protecting the table, table warmers, bolsters, and other items with washable barriers like pillowcases that can be removed and replaced between each client. Barriers are not a substitution for the required cleaning and disinfecting protocols.
• Evaluate whether facial massages or other hands-on work to the face will be offered. If providing such services, use non-latex gloves for this part of the treatment. Facial massages should not be performed if it requires removal of the client’s face covering.
• Provide any hand treatments as the last part of the service.
• Workers should wash their hands immediately upon finishing massage services.


Additional requirements must be considered for vulnerable populations. Personal care providers must comply with all Cal/OSHA standards and be prepared to adhere to its guidance as well as guidance from the Centers for Disease Control and Prevention (CDC) and the California Department of Public Health (CDPH). Additionally, employers should be prepared to alter their operations as those guidelines change.

John Johnson
John Johnson is a professional body piercer at New Flower Studio and a resident of Long Beach, CA. He's also a Red Cross instructor and authorized OSHA trainer. He manages the online curriculum for the Association of Professional Piercers and is a member of AFDO.