Texas Esthetician Studio Compliance: The Complete TDLR Guide

What licenses does a Texas esthetician studio need?

A Texas esthetician studio generally needs two things: a licensed practitioner and a licensed establishment. These are separate licenses.

• Esthetician license (individual). Every person performing esthetics services (facials, superficial exfoliation, hair removal, makeup, extractions) must hold a current TDLR esthetician license. The standard esthetician license is based on completing 750 hours of TDLR-approved training and passing the required written and practical exams; a master esthetician license reflects a broader authorized scope and requires 1,000 total training hours (versus 750 for a standard esthetician). Licenses are issued for a two-year term.
• Establishment license. The physical location where esthetics services are performed must hold a TDLR establishment license (standard, specialty, or mini, depending on setup). You cannot legally operate an esthetics business to the public from an unlicensed location. Establishment licenses are also issued for two years.
• Booth rental / independent contractors. If you rent a room or chair rather than employing staff, the studio may lease space to you as an independent contractor only if the studio itself is a TDLR-licensed establishment. Under 16 TAC §83.71, the establishment (lessor) must maintain a list of all renters with each renter's name and license number and provide that list to a TDLR representative on request.

The statutory foundation for all of this is Texas Occupations Code Chapter 1602 (Cosmetologists) and Chapter 1603 (Regulation of Barbering and Cosmetology), implemented by the rules in 16 TAC Chapter 83. TDLR consolidated many barbering and cosmetology license types under this framework, so an "establishment" license now covers the location regardless of the specialty performed there.

Which agency regulates esthetician studios, and what must you post?

The Texas Department of Licensing and Regulation (TDLR) is the state agency that licenses, regulates, and inspects esthetician studios in Texas. There is no separate "Texas board of esthetics" — TDLR absorbed the former cosmetology board, and its Barbering and Cosmetology program administers the rules.

The governing authorities are:

• Texas Occupations Code Chapters 1602 and 1603 — the statutes that create the licensing scheme and give TDLR enforcement authority.
• 16 TAC Chapter 83 — the administrative rules covering licensing, establishment responsibilities, curriculum, and the health and safety standards (§§83.100–83.115).

Required posting. Under Texas Occupations Code §1603.357, the barbering and cosmetology health and safety rules must be posted in every licensed establishment and school. TDLR publishes a printable version of these rules for exactly this purpose. Current practitioner and establishment licenses must also be displayed at the establishment. Separately, Texas law requires many TDLR-licensed establishments to display a human-trafficking awareness sign, and continuing education now includes a human-trafficking awareness component — confirm the current posting list with TDLR.

Sanitation and disinfection requirements (16 TAC §§83.100–83.102)

Texas defines its sanitation vocabulary and disinfection standards precisely in 16 TAC §§83.100–83.102, and inspectors check against these exact definitions. Getting the terminology right matters, because "clean," "disinfect," "sanitize," and "sterilize" are not interchangeable under the rule.

Key definitions (§83.100):

• Clean/cleansing — washing with soap and water or another adequate method to remove all visible debris. Cleaning is not disinfection.
• Disinfect — using chemicals to destroy pathogens on hard, non-porous surfaces to make an item safe to handle, use, and dispose of.
• Disinfectant — either an EPA-registered bactericidal, fungicidal, and virucidal disinfectant used per the manufacturer's instructions, or a chlorine bleach solution used as specified in the chapter.
• Multi-use items — hard, smooth items (metal, glass, plastic) that can be cleaned and disinfected between clients (e.g., metal tweezers, comedone extractors).
• Single-use items — porous or absorbent items (cotton, gauze, wooden applicators, extension pads) that must be discarded after use on one client.

Core disinfection standards (§§83.101–83.102):

• Implements and surfaces must first be cleaned of all visible debris before disinfection — EPA-registered disinfectants are inactivated by hair, dirt, and residue.
• Disinfectant solutions used for immersion must be prepared fresh daily (or more often if diluted or soiled), and used strictly per the manufacturer's directions.
• Chlorine bleach solutions, if used, must be mixed daily, kept in a closed covered container away from sunlight and other chemicals, and properly disposed of each day.
• Multi-use equipment not otherwise addressed must be cleaned and disinfected before use on each client; single-use items must be discarded after one client.
• Electrical equipment that cannot be immersed must be wiped clean and disinfected before each use.
• Clean, disinfected implements must be stored in a clean, dry, debris-free, covered environment, separate from soiled items.
• Clean towels must be used for each client and washed in hot water and chlorine bleach; soiled towels must be removed and placed in a covered receptacle.
• Hand-washing facilities with hot and cold running water must be provided.

Note that under §83.100, an ultraviolet unit only "sanitizes" (reduces microorganisms) — it is a storage aid, not a substitute for disinfection.

Esthetician-specific infection control: extractions, waxing, and lashes

Beyond the general rules, 16 TAC Chapter 83 has service-specific infection-control requirements that apply directly to esthetics work.

Esthetician services (§83.104).

• Practitioners must wash hands with soap and water (or use a liquid hand sanitizer) before performing any service.
• Gloves must be worn during any type of extraction.
• Products subject to cross-contamination — creams, cosmetics, astringents, lotions, waxes, moisturizers, masks, and oils — must be handled so the remaining product is not contaminated. Applicators may not be re-dipped into product. Permitted methods include discarding the leftover product before starting the next client, using a single-use disposable applicator and discarding it, or dispensing from an applicator bottle.

Temporary hair removal / waxing (§83.105).

• Wax pots must be cleaned and disinfected per the manufacturer's recommendations.
• No applicator may be left standing in the wax, and wax may not be reused under any circumstances — no double-dipping.
• Products or single-use items that have contacted a client's skin during depilatory, preparation, or tweezing services must be disposed of after each use.

Eyelash extension services (§83.115).

• Single-use items such as disposable applicators, brushes, and extension/eye pads must be discarded after each client.
• Extensions must be stored in a sealed bag or covered container in a clean, dry, debris-free area.
• Semi-permanent glue and remover must be properly labeled and used per the manufacturer's instructions.

Across all of these, tweezers, comedone extractors, and other multi-use metal implements must be cleaned and disinfected after each client (§83.104(d)).

Scope of practice: the "dermis" line that separates esthetics from medicine

The single most important compliance boundary for a Texas esthetician studio is this: an esthetician may not perform any procedure that penetrates or comes into contact with the dermis. This is stated directly in 16 TAC §83.112(c), which prohibits "the use of any product, preparation or procedure that comes into contact with or penetrates the dermis layer of the skin."

What this means in practice:

• Generally within esthetics scope: facials, cleansing, superficial exfoliation, extractions, makeup, brow and lash services, and hair removal (waxing, tweezing, threading, sugaring). Master estheticians have additional authorized advanced services based on their training.
• Not within esthetics scope (crosses into the practice of medicine): injectables (Botox, dermal fillers), medical-grade microneedling that penetrates the dermis, deep chemical peels, laser and IPL procedures used for medical purposes, and prescription-strength treatments. These generally require a physician's involvement and delegation.

When a studio moves into those medical territories, it becomes a medical spa, and a different body of law applies — including the Texas Medical Board's rules on delegation of cosmetic medical procedures (22 TAC Chapter 169, which requires signed written protocols reviewed at least annually) and 2025 statutory changes affecting IV therapy and delegation that took effect September 1, 2025. Note also that §83.112 bans certain items outright for cosmetology use, including liquid monomer methyl methacrylate (MMA), razor-type callus/credo blades, alum in stick form, and formalin (formaldehyde) fumigants.

If you are unsure which side of the dermis line a service falls on, treat it as a medical question and get physician oversight or a professional opinion before offering it. Advertising or performing dermis-penetrating procedures under only an esthetician license is a common and serious enforcement trigger.

Blood and body fluids, and when OSHA applies

Because extractions and hair removal can occasionally break the skin, esthetician studios need a blood-and-body-fluid protocol under both Texas rules and — for studios with employees — federal OSHA standards.

Texas rule (16 TAC §83.111). If blood or body fluid contacts a surface (table, chair, floor), it must be cleaned immediately with an EPA-registered hospital-grade disinfectant, a tuberculocidal disinfectant, or a blood-and-body-fluid cleanup bleach solution, used per the manufacturer's instructions. A non-porous instrument that contacts blood or body fluid must be immediately cleaned and disinfected (hospital-grade/tuberculocidal disinfectant, or immersion in a 10% bleach solution for 5 minutes). Any porous item that contacts blood or body fluid must be immediately double-bagged and discarded in a closed trash container or biohazard box. Practitioners should not touch a client's open sore or wound.

Federal OSHA — Bloodborne Pathogens Standard (29 CFR 1910.1030). OSHA's rules protect employees, so they apply to studios that have employees with reasonably anticipated occupational exposure to blood or other potentially infectious materials. Where it applies, the employer must maintain a written exposure control plan, offer the hepatitis B vaccination to exposed employees, provide personal protective equipment and training, and keep the required records.

Solo and booth-rental context. OSHA generally regulates the employer–employee relationship. A genuinely solo esthetician or independent booth renter with no employees typically falls outside OSHA employer obligations — but the Texas §83.111 sanitation duties still apply to everyone, and worker classification is fact-specific. If you have any W-2 employees, assume the Bloodborne Pathogens Standard applies and build the exposure control plan.

Product and chemical safety (hazard communication)

Esthetician studios use chemicals — peel solutions, disinfectants, waxes, acetone, developers — so both TDLR and OSHA impose product-safety duties.

TDLR labeling (16 TAC §83.102(n)). Each establishment must keep all products used in the business properly labeled in compliance with OSHA requirements. Improper or missing labels are a routine inspection finding.

OSHA Hazard Communication Standard (29 CFR 1910.1200). For studios with employees, the Hazard Communication ("HazCom") standard requires:

• A written hazard communication program.
• Maintaining a Safety Data Sheet (SDS) for each hazardous chemical, readily accessible to employees.
• Ensuring manufacturer labels stay intact and secondary containers are labeled.
• Training employees on the hazards of the chemicals they use and how to read labels and SDSs.

Even a solo studio with no employees benefits from keeping SDSs on file and following manufacturer directions — many disinfection rules in Chapter 83 explicitly require use "in accordance with the manufacturer's instructions," so the SDS and product label are effectively part of your compliance record. Store chemicals away from heat and incompatible products (for example, the rules warn that chlorine bleach vapors can react with acrylic monomers, alcohol, and other products), and never store chemical supplies in a restroom, which §83.114 prohibits.

Recordkeeping, facility standards, inspections, and renewals

Texas esthetician compliance is proven through records and a compliant facility, not just intentions. TDLR conducts inspections, and having the paperwork ready is much of the battle.

Records to keep:

• Foot spa / basin cleaning logs (§83.108) — if your studio offers any pedicure or foot-soak service, cleaning and disinfecting records for foot spas, basins, liners, and jets must be recorded on a department-approved form and retained for at least 60 days for inspection.
• Booth-renter list (§83.71) — establishments leasing space must keep a current list of renters (name and license number) available to TDLR on request.
• OSHA records — if you have employees: the written exposure control plan, hepatitis B vaccination and training records, and (under the Bloodborne Pathogens Standard) employee medical records retained for the duration of employment plus 30 years.
• Licenses and product labels/SDSs — current licenses displayed; products labeled; SDSs accessible.

Facility standards (§83.114). Floors, walls, ceilings, and fixtures must be kept clean and in good repair. Floors in service areas must be non-porous and washable. The studio must have hot and cold running water, at least one restroom on or near the premises, and adequate ventilation to exhaust chemical fumes. Licensed premises may not be used for living or sleeping.

Inspections and enforcement. TDLR inspects establishments for compliance with Chapter 83. Violations can result in warnings, required corrective action, administrative penalties (assessed per violation, with each day a violation continues potentially treated separately), and license suspension or revocation for serious or repeated issues. Having documents on file does not by itself make you compliant — you must actually implement and maintain the practices.

Renewals and continuing education. Esthetician licenses renew every two years and require TDLR-approved continuing education (currently 4 hours per cycle for standard licensees, including required topics such as sanitation and human-trafficking awareness; reduced hours may apply to certain long-tenured licensees). Establishment licenses also renew on a two-year cycle. Confirm current CE hours and topics with TDLR before each renewal.