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HLO News Details


Practice Clarification on Cosmetic Injectables (e.g. Botox)

Wednesday, March 21, 2018

​Updated: March 14, 2018

The Health Licensing Office (HLO) has received numerous questions and inquiries regarding the use of cosmetic injectables with trade names such as Botox, Restylane and Juvederm by basic and advanced estheticians.

Question: Is it within the scope of practice for basic or advanced estheticians to provide cosmetic injection services to clients (e.g. Botox)?

Short Answer: No, providing cosmetic injections to clients is NOT in the scope of practice for basic or advanced esthetics.

Long Answer: The Board of Cosmetology and the Board of Certified Advanced Estheticians do not regulate the practice of medicine, nor does it have the authority or expertise to define what is and what is not considered to be the practice of medicine. The Board does have the authority to issue certificates to individuals who meets qualifications and define the scope of practice for basic and advanced esthetic scope of practice within the parameters of the law.

ORS 690.005(5) limits the scope of practice for advanced esthetics.
“Esthetics” means any of the following skin care or facial care practices performed on the human body or face for the purpose of keeping the skin of the human body or face healthy and attractive and not for medical diagnosis or treatment of disease or physical or mental ailments:
•    (a) use of the hands or mechanical or electric apparatuses or appliances for cleansing, stimulating, manipulating, exfoliating or applying lotions or creams
•    (b) Temporary removal of hair.
•    (c) Makeup artistry.
•    (d) Eyelash services.
•    (e) Facial and body wrapping.
•    (f) Facial and body waxing.

ORS 676.630(1) limits the scope of practice for advanced esthetics to the following modalities:
(1) “Advanced nonablative esthetics procedure” means a procedure that uses a laser or other device registered with the United States Food and Drug Administration for nonablative procedures performed on the skin or hair, including, but not limited to, procedures performed in conjunction with one of the following modalities:
Skin rejuvenation;
(b) Photo rejuvenation;
(c) Body contouring;
(d) Dyschromia reduction;
(e) Cellulite reduction
(f) Hair removal or reduction; and
(g) Nonablative tattoo removal.

The Oregon Medical Board is the entity authorized to determine what is and what not the practice of medicine is. An esthetician administering injectable cosmetics is providing a service that is outside the scope of practice for an esthetician in Oregon. Questions regarding the practice of medicine including delegation and supervision authority should contact the Oregon Medical Board.

Important Note: The HLO does not provide personal legal advice to licensees or members of the public. The responses below are specific to only those questions asked. Even slight changes in the scope or content of the question may change the applicability of these responses in a different situation. Please consult your own attorney for legal advice regarding Oregon laws and administrative rules.


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