Public Comments for Events Organized by the FTC's Economic Liberty Task Force #00040

Submission Number:
Myra Reddy
Professional Beauty Association
Initiative Name:
Public Comments for Events Organized by the FTC's Economic Liberty Task Force
October 31, 2017 Federal Trade Commission Economic Liberty Task Force - Occupational Licensing, Economic Opportunity Re: November 7, 2017 Meeting - Empirical Research Dear Economic Liberty Task Force, Please accept the following comments and attached documents submitted online today regarding the upcoming November 7, 2017 meeting, The Effects of Occupational Licensure on Competition, Consumers, and the Workforce: Empirical Research and Results. The Professional Beauty Association (PBA) is the largest national organization of salon professionals and provides education, government advocacy, charitable outreach, and events. PBA is also a proud member of the Future of the Beauty Industry Coalition (FBIC), whose efforts include reform recommendations to streamline the requirements for occupational licensing and support for license mobility/portability. PBA and FBIC agree there are occupations where the requirement of mandatory education and obtaining a license is necessary and appropriate. We support the occupational license for cosmetologists however we agree that these requirements can be sensibly reduced while maintaining health and safety standards. FBIC's research and reports include an Examination of Cosmetology Licensing Issues, an independent study conducted by the American Institutes for Research. This study reviews cosmetology school program length, graduation rates, exam performance, student loan debt, employment rates and wages. This data was examined across multiple states with varying, inconsistent requirements to obtain a cosmetology license. A second study, The Value of Cosmetology Licensing to the Health, Safety, and Economy of America, was produced by NDP Analytics. This report explores the health, safety, and economic impact of occupational licensing for the professional beauty industry. According to the United States Department of Labor Bureau of Labor Statistics' Occupational Outlook Handbook (published online October 2017), "Employment of barbers, hairstylists, and cosmetologists is projected to grow 10 percent from 2016 to 2026, faster than the average for all occupations. Population growth will lead to greater demand for hair care services." The job demand is clear. While regulation of the industry protects public health and safety, there should never be a restriction on someone's ability to earn a living. Sensible reforms like streamlining standards and increasing license mobility can boost career opportunities while also maintaining the high standards that protect and serve the public. Respectfully, Myra Y. Reddy Director of Government Affairs and Industry Relations Professional Beauty Association (PBA) Future of the Beauty Industry Coalition (FBIC) -- Member