Texas Esthetician Studio
Compliance Manual

Regulatory Overview & Agency Guide

An esthetician studio is regulated mostly by one agency — which sounds simpler than it is, because that agency licenses three different things at once: the practitioner, the establishment, and in some cases the specific service.

The harder question is the one this chapter ends on: where esthetics stops and medicine starts. That line is not about the room you are in or the training you paid for. It is about depth, and crossing it turns a licensing question into an unlicensed-practice-of-medicine question.

1.1  Who Regulates You

These are the bodies whose rules your documentation has to satisfy. Each one can inspect, and each one asks for different evidence.

Agency	Jurisdiction	What they ask for
TDLR	Practitioners, establishments, sanitation	Occupations Code Ch. 1602/1603 and 16 TAC Ch. 83 — licenses, postings, disinfection, foot spas, waxing, booth renters, continuing education
Texas Medical Board	Anything below the dermis	22 TAC Ch. 169 — injections, medical needling, deeper peels and laser treatments are delegated medical acts requiring physician delegation, not esthetics
Federal OSHA	Employee safety and chemicals	Bloodborne Pathogens (29 CFR 1910.1030) and Hazard Communication (29 CFR 1910.1200) — peels, disinfectants and solvents all count

1.2  TDLR Licensing

TDLR licenses two separate things, and both must be current and displayed: the practitioner, under Occupations Code Ch. 1602/1603, and the establishment itself, under 16 TAC Ch. 83.

Establishment licenses come in standard, specialty, and mini variants depending on what the location offers. Operating on current practitioner licenses but a lapsed establishment license is its own violation, and it is easy to miss because nothing about the day-to-day feels different.

If you rent booths, the establishment must keep a current renter list with names and license numbers, producible to TDLR on request (§83.71). Continuing education runs on a two-year cycle and shortfalls surface at renewal.

1.3  Where Esthetics Ends and Medicine Begins

This is the boundary that carries the most risk, and it is not about the room, the equipment, or the training certificate on the wall. It is about depth.

Under 16 TAC §83.112(c), services must stay above the dermis to remain esthetics. Injections, medical needling, deeper chemical peels, and laser or IPL treatments are delegated medical procedures governed by the Texas Medical Board under 22 TAC Ch. 169 — not esthetics under TDLR.

Performing one without proper physician delegation can constitute the unlicensed practice of medicine, which is exposure for the individual practitioner and for the establishment that allowed it. The practical answer is a written scope-of-practice guide and a referral procedure, so the boundary is decided in advance rather than in the treatment room.

1.4  Sanitation and Disinfection

Most of what TDLR inspects day to day comes down to disinfection discipline and the records proving it.

Only EPA-registered bactericidal, fungicidal and virucidal disinfectants may be used, strictly per the product label (§§83.100–83.101). Immersion solutions, including bleach, are mixed fresh daily. Multi-use implements are cleaned and then disinfected before every client; single-use items are discarded.

Foot spa cleaning and disinfection records go on the TDLR-approved form and are retained for 60 days (§83.108). Waxing requires single-use applicators with no double-dipping (§83.105), and a written blood and body-fluid response protocol is required with the supplies to match (§83.111).

1.5  Federal OSHA and Chemical Safety

Federal OSHA applies from your first employee, and a salon has more chemical exposure than most people assume.

You need a written Exposure Control Plan, hepatitis B vaccination offered to at-risk staff, and documented annual bloodborne pathogens training (29 CFR 1910.1030). Under Hazard Communication (29 CFR 1910.1200), every chemical product needs a Safety Data Sheet accessible during every shift, and every container must be labeled — including anything decanted into a secondary bottle.

TDLR reinforces the same ground in §83.102(n) and §83.114, which cover labeling and safe storage. Flammable products go away from heat sources and out of client areas.

1.6  Postings and Records

Current licenses must be displayed, along with the Chapter 83 health and safety rules and the human trafficking awareness sign required by Occupations Code §1603.357.

The records an inspector can ask for without notice are the ones easiest to let slip: the daily disinfectant solution log, foot spa cleaning records on the approved form for the last 60 days, the booth renter list, and continuing education certificates for every licensee. None of them take long to keep. All of them take a long time to reconstruct.