PA Esthetician Scope of Practice 2026: What You Can Legally Do

Most states make you infer the esthetician boundary from a vague definition and a board that has never said anything. Pennsylvania is the rare state where the regulator has been explicit, at least about the procedure that matters most, so you can read the paper trail instead of guessing.

This guide answers the seven questions Pennsylvania operators actually ask, verdict first. Where the Commonwealth has settled a question we cite it; where it has not — and Pennsylvania has left more open than its neighbours — we say so and give the reading that survives a board inquiry. The scaffolding underneath a defensible menu is in our med spa SOP and compliance library.

Three neighbouring questions belong elsewhere: who may inject neurotoxin and filler here, who may own a med spa, and the regulatory framework as a whole. For national context, see the esthetician scope of practice by state pillar.

What a Pennsylvania Esthetician Licence Actually Authorises

Every answer below is downstream of two short regulations.

The definition that decides everything: 49 Pa. Code § 7.1

The State Board of Cosmetology defines esthetics at 49 Pa. Code § 7.1 as massaging the face; applying cosmetic preparations, antiseptics, tonics, lotions or creams to the face; removing superfluous hair by tweezers, depilatories or waxes; eyelash perming; and dyeing eyelashes and eyebrows — plus industry standard mechanical and electrical apparatus used in the practice of esthetics.

Notice what it is not. It is not a statement of purpose, and it is not a depth test. It is a list of physical acts containing no needle, no blade, no energy source and no reference to the dermis.

“Esthetician services only” — § 7.14a

The companion rule, 49 Pa. Code § 7.14a, is one sentence: an individual holding an esthetician licence is qualified to perform esthetician services only. The word only closes the list rather than opening it. Beneath both sits the Cosmetology Law of 1933, whose section 2 (63 P.S. § 508) makes it unlawful to practise esthetics without the corresponding licence.

The phrase operators misread: “industry standard apparatus”

If someone has told a Pennsylvania esthetician a device is fine, this clause is why, and the misreading is predictable: people quote the first eight words and stop. The clause covers apparatus used in the practice of esthetics — carrying out an act the definition already named, as a steamer helps you cleanse the face. A device whose purpose is to puncture, ablate or heat the dermis assists no listed act; it performs an unlisted one.

Operators arriving from Florida or Texas assume a definition sets a floor, so anything gentler than the harshest listed act must be permitted by implication. Pennsylvania does not work that way: the Board has treated microblading as outside cosmetology, and the Bureau has treated microdermabrasion as a violation. Being outside the list ends the analysis before it reaches risk.

Esthetician Versus Cosmetologist in Pennsylvania

§ 7.14 runs one way only

Under 49 Pa. Code § 7.14, a cosmetologist licence qualifies the holder, without further licensure, to perform the functions of a cosmetologist, esthetician, nail technician or natural hair braider. The esthetician rule has no mirror image, so a cosmetologist may perform every service an esthetician may, and an esthetician may not reciprocate.

The face-versus-upper-body gap

Here is the difference almost nobody notices, visible in the same regulation. The esthetics definition says the face, repeatedly; the cosmetology definition in that same section reaches the scalp, face, arms or hands, or the upper part of the body. Follow that through and a “back facial” is awkward to defend under an esthetics licence while a cosmetologist has express language to point at. Neither reaches the legs.

What neither licence reaches

Both stop at the same wall: neither authorises puncturing skin, injecting, operating an energy-emitting device, or wounding the dermis. A cosmetology licence is broader in body coverage; it is not one inch closer to the practice of medicine.

Can an Esthetician Do Microneedling in Pennsylvania?

No. A Pennsylvania esthetician licence does not authorise microneedling, and unlike most states, Pennsylvania has not left you to infer it. The evidence runs from three directions: the text, a written position the Bureau took with salons, and a disciplinary order.

The verdict, and why Pennsylvania is clearer than most states

The text disposes of the question before any policy argument begins. Microneedling drives fine needles through the epidermis into the dermis to create controlled micro-injuries; the injury is the mechanism, not a side effect. Look for that act in § 7.1. Massaging the face — no. Applying a cosmetic preparation — no. Removing hair by tweezers, depilatories or waxes — no. Eyelash perming or dyeing — no. There is no fifth category, and § 7.14a says only. A microneedling pen is an industry standard appliance, but it does not massage, apply, tweeze or dye. It perforates.

What the Bureau actually told salons

What lifts this from a strong reading to a settled one is that the Commonwealth put its position in writing. The Bureau of Professional and Occupational Affairs, the Department of State bureau housing the licensing boards, sent letters to salons stating that performing microneedling and microdermabrasion violates the Cosmetology Law. The legislature memorialised it: the co-sponsorship memorandum behind House Bill 1249 of the 2021–22 session recites those letters as the reason legislation was needed. This is not a rumour in a group chat; it is the stated premise of a bill.

The legislature tried twice and did not finish

House Bill 1249 was introduced on April 20, 2021 by Representatives Quinn, Rozzi and R. Brown and referred the same day to the House Professional Licensure Committee. It would have added microdermabrasion and microneedling — the latter defined as multiple tiny solid needles designed to pierce the skin to stimulate collagen production — to the Cosmetology Law’s definitions. Its predecessor, House Bill 2456 of 2019–20, went the same way. Neither was enacted, and that is the point: you do not amend a definition to permit what it already permits.

The Board has enforced this, not just said it

In its September 2023 disciplinary actions, the Commonwealth reported that a Philadelphia salon, Umbrella Beauty Center, licence number CB134551, was ordered to pay a $1,500 civil penalty and to cease and desist from offering Botox injections, lip fillers and microneedling within the licensed square footage of the salon, having allowed those prohibited services there, effective September 25, 2023.

Read the remedy carefully. It does not say “stop microneedling” — it says stop it within the licensed square footage. The hook is 49 Pa. Code § 7.77: no part of a salon may be used for other purposes. That sentence is the most under-appreciated regulation in Pennsylvania aesthetics, and it is why the room matters here in a way it does not elsewhere.

Cosmetic-depth versus medical-depth devices: Pennsylvania draws no line

In many states the fight is over depth: a 0.25 mm cartridge is marketed as “cosmetic,” a 1.5 mm cartridge is conceded to be medical, and the argument is about the space between. There is nothing here to have that argument with. The Cosmetology chapter contains no needle-depth threshold, no cosmetic-versus-medical device distinction, and no mention of epidermis or dermis; FDA classifications are federal marketing determinations, not state licensure permissions. The shallow-cartridge argument never gets a hearing, because the analysis asks only whether the act appears on a list.

Does a supervising physician change the answer?

Not for the esthetician licence, and this is where careful operators still go wrong. A physician may delegate a medical service to a health care practitioner or technician under 49 Pa. Code § 18.402, and an osteopathic physician under 49 Pa. Code § 25.217. If valid, the person performs as a delegatee — a different legal status, not an expanded licence. It does not make microneedling into esthetics, does not amend § 7.1, and because of § 7.77 it cannot happen inside licensed salon square footage.

Radiofrequency microneedling sits further out, not closer in

RF microneedling adds a second mechanism: needles penetrate the skin, then deliver radiofrequency energy to heat the dermis at depth. If a solid-needle pen is outside the esthetics definition, a device that punctures and deposits thermal energy is outside it twice over.

What is genuinely unsettled, and the conservative reading

Two things are settled: an esthetician may not perform microneedling under the esthetician licence, and it may not be performed inside a licensed salon. One thing is genuinely open. Pennsylvania has never said which delegatees a physician may lawfully delegate microneedling to. Section 18.402 names no procedures, and § 18.402(b) withholds any service requiring knowledge and skill not commonly possessed by non-physicians — a standard that decides the case without telling you the answer. Neither medical board has published microneedling-specific guidance, a depth rule, or a credential list.

The conservative reading, and the one we would defend in front of a board: treat delegated microneedling as a medical service performed by a clinically licensed delegatee — an RN, CRNP or PA — in a medical practice, on a patient the physician has evaluated, under a written protocol with a documented competency record. Treat an esthetician performing it as a position you would have to defend rather than rely on. National context is in our microneedling laws by state guide.

Can an Esthetician Perform Chemical Peels in Pennsylvania?

Superficial peels: defensible. Medium-depth and deep peels: no. Unlike microneedling, Pennsylvania has issued no statement, rule or order on peels at all, so this answer is reasoned from two definitions rather than read off a regulation — treat it accordingly.

Superficial peels are the defensible category

The best textual home for a light peel is the phrase covering application of cosmetic preparations to the face. A professional-strength glycolic, lactic, mandelic or salicylic formulation is a cosmetic preparation applied to the face to lift dead surface cells. That fits the words the Board wrote, and superficial peeling has been part of Pennsylvania practice for decades without the Bureau taking the position it took on needling.

Medium-depth and deep peels leave the definition behind

A medium-depth peel — trichloroacetic acid at working strength, or Jessner plus TCA — is not designed to exfoliate. It is designed to destroy the epidermis and part of the papillary dermis so the skin rebuilds. That maps onto the Medical Practice Act’s definition of medicine and surgery at 63 P.S. § 422.2: the art and science whose objectives are the cure of diseases and the preservation of the health of man, including the practice of the healing art with or without drugs. Phenol formulations carry systemic cardiac risk and produce full-thickness injury; nobody argues those sit inside a cosmetology licence.

There is no percentage rule — and no depth rule either

Charts claiming an esthetician may go to 30 per cent glycolic have no basis in Pennsylvania law. Neither does a depth rule, the more important absence: several states expressly limit estheticians to the epidermis, and Pennsylvania is not one of them. That cuts against the aggressive operator — where a state writes an epidermal limit, a practitioner staying inside it has a rule to point at. Here the only argument available is that the service fits a listed act. The defensible position is a documented, self-limiting protocol whose endpoint is surface exfoliation; the general framework is in our complete skin and laser compliance guide.

Prescription-strength agents are a separate problem

If a formulation is a prescription product, scope is not the only obstacle: selecting and applying a prescription agent implicates drug law and the prescriber relationship however shallow the exfoliation.

Can an Esthetician Use Lasers or IPL in Pennsylvania?

No, not under the esthetician licence — and the reason is not that Pennsylvania has a laser rule. It is that Pennsylvania has no laser rule at all, which is the opposite of permission.

The verdict under the cosmetology licence

Firing a laser or intense pulsed light device appears nowhere in § 7.1, and the apparatus clause fails for the same reason it fails on needling. A hair-removal laser destroys follicular structures in the dermis; an ablative device vaporises tissue. Each is a deliberate alteration of living tissue the Cosmetology Law never contemplated.

What Pennsylvania does not have

Pennsylvania has no laser operator statute, no state laser safety certification, no technician registry and no minimum training hours for cosmetic device operation. Practitioners hear that and conclude the field is open. It is the reverse: the absence of an authorising provision is not a gap you may occupy — your authority must come from somewhere else, and the only other source is the practice of medicine. A vendor’s “certified laser technician” card is evidence of training, not a licence.

How a laser lawfully gets fired in a Pennsylvania med spa

The lawful route is a physician-directed practice where a physician has evaluated the patient and delegated the treatment under § 18.402 or § 25.217 to someone whose training and continued competency the physician actually knows. That delegatee is usually an RN, CRNP or PA, whose own practice act already authorises clinical procedures — the general functions of a registered nurse appear at 49 Pa. Code § 21.11. They operate as a delegatee, not as an esthetician, and § 7.77 keeps the treatment out of licensed salon square footage.

The genuinely unsettled part: how close the physician must be

Section 18.402 requires the delegating physician to be available to the delegatee as appropriate to the difficulty of the procedure, the skill of the delegatee and the risk to the patient. It does not say “on the premises,” sets no response time, and Pennsylvania has published no laser-specific interpretation of it. The honest reading is a sliding scale the physician must justify per procedure.

Can an Esthetician Perform Dermaplaning in Pennsylvania?

Pennsylvania has not answered this, and the conservative reading places it outside the esthetician licence. This is the question with the least authority behind it in either direction; a source giving you a confident yes or no is telling you what it hopes.

Pennsylvania has no blade rule — which cuts both ways

Some states expressly prohibit cosmetology licensees from using a blade, scalpel or lancet on a client. Pennsylvania has no such prohibition, and anyone told otherwise has been misinformed. The difficulty is the other half: there is no express authorisation either, and in a state whose scope rule ends with the word only, silence is not neutral. Drawing a blade across the face is not removal of superfluous hair by tweezers, depilatories or waxes — the one hair-removal category the definition names, and it names three techniques, none of them a blade.

How the Board’s demonstrated reading applies

Since the text cannot answer it, look at how the same list has been read before. Microdermabrasion removes only dead surface cells with a machine, and the Bureau called it a violation; microblading is a surface-level technique the Board treated as outside cosmetology. Neither reaches living tissue meaningfully; both were placed outside the licence anyway. Dermaplaning is the same shape of question, and an operator reasoning “it only removes dead cells, so it must be fine” is applying the very depth test the microdermabrasion position rejected.

What a cautious Pennsylvania operator does

If dermaplaning is a small part of the menu, the risk-adjusted move is to drop it or move it to the medical side under a documented delegation. If it is a material revenue line, put the question to a Pennsylvania healthcare attorney and consider seeking written guidance from the Board. What you should not do is rely on a competitor’s menu or a blade manufacturer’s certificate.

Can an Esthetician Do HydraFacials and Extractions in Pennsylvania?

Manual extraction during a facial is the defensible half; machine resurfacing is the exposed half. This one splits down the middle, because the Commonwealth has taken a harder line on exfoliation devices than almost anywhere else.

Manual extractions

Cleansing the face and clearing comedones with gloved fingers, cotton or a wrapped tool is ordinary facial work and fits the massaging and cosmetic-preparation language comfortably. The caution is clinical: extraction pursued into inflamed cystic lesions becomes treatment of a skin condition. Lancets are a harder call — Pennsylvania names no instrument prohibitions, but a lancet exists to puncture skin, and puncturing is the act the Bureau already positioned outside the Cosmetology Law.

The microdermabrasion problem

Here Pennsylvania departs sharply from operator expectations. In most states microdermabrasion is the textbook in-scope esthetician service — a diamond tip abrading dead cells, penetrating nothing. In Pennsylvania, the Bureau told salons in writing that performing it violates the Cosmetology Law, and the bills filed to fix that were not enacted. If you run an esthetics room with a microdermabrasion machine in it, you are operating against a stated Bureau position.

Where hydradermabrasion devices and infusion serums sit

Branded hydradermabrasion platforms — the category most people mean by HydraFacial — combine a vacuum handpiece, a spiral tip and simultaneous fluid delivery: machine-driven mechanical exfoliation with a serum step attached. Pennsylvania has never addressed it by name, so its status is genuinely unresolved. What we can say is that a brand name is not a legal category — if machine exfoliation is what the Bureau objected to, do not assume water and a trademark move the device across the line. That may be right, but it is an argument, not a rule. The serum step raises its own question: a cosmetic serum is expressly within § 7.1, while a prescription-strength infusion pressed into freshly abraded skin is closer to transdermal delivery.

Can an Esthetician Perform Radiofrequency or Ultrasound Skin Tightening in Pennsylvania?

No. These devices sit outside the esthetician licence for the same reason lasers do, and the counter-argument people reach for is the apparatus clause — which does not survive contact with its own final words.

Why the apparatus clause does not save it

The clause permits industry standard apparatus in the practice of esthetics. A radiofrequency platform is not helping you massage the face or apply a cream; its purpose is to raise dermal temperature into a range that denatures collagen and triggers a remodelling response, and focused ultrasound deposits thermal coagulation points at fixed depths. Neither assists a listed act; each performs a distinct, unlisted one whose value proposition is a controlled thermal injury below the surface. An electrical appliance is not automatically an esthetics appliance.

“Non-invasive” is a marketing word, not a legal category

Pennsylvania’s Cosmetology chapter does not contain the word invasive, does not classify devices by invasiveness, and exempts nothing because the skin surface stays intact. The absence of a scab is not the presence of authority. The same logic covers cryolipolysis and electromagnetic muscle stimulation, which also fail the body-coverage test because they are applied to the abdomen, flanks or thighs rather than the face.

Can an Esthetician Administer Injections of Any Kind in Pennsylvania?

No. Not neurotoxin, not filler, not a vitamin shot, not mesotherapy, not a “skin booster” — not under supervision, not in a physician-owned practice, not with any certificate. This is the one answer with no conditions attached.

Why the answer has no conditions

Section 7.1 contains no needle, no injectable, no prescription drug and nothing that enters the body, and § 7.14a confines the licensee to esthetician services only. Pennsylvania never carved injectables out of the esthetics definition, because they were never in it — and the sequence matters: a carve-out could in principle be restored by a supervision arrangement, whereas an act never included cannot be recovered by one.

The Board has already put this in an order

The September 2023 Umbrella Beauty Center action is not only a microneedling case. The Board ordered the salon to cease and desist from offering Botox injections and lip fillers alongside microneedling inside the licensed square footage, describing all three as prohibited services. Who may inject here is a different question, worked through in our Pennsylvania injector guide — and no arrangement on that page adds an esthetician to the list.

When a Skin Procedure Becomes the Practice of Medicine

The Medical Practice Act’s boundary

The Medical Practice Act of 1985 defines medicine and surgery at 63 P.S. § 422.2 as the art and science whose objectives are the cure of diseases and the preservation of the health of man, including the practice of the healing art with or without drugs, except healing by spiritual means or prayer. That is functional rather than a list of procedures, and cosmetic work fits it more comfortably than practitioners expect. The same section defines a health care practitioner as an individual, other than a physician assistant, authorised to practise some component of the healing arts by a Commonwealth licence, permit, certificate or registration — which is why delegation is a real route here rather than a fiction.

Pennsylvania has no med spa licence — it has a delegation rule

There is no Pennsylvania medical spa licence, no facility registration for cosmetic medical practices, and no medical director statute written for the aesthetics industry. A business offering cosmetic medical procedures is simply a medical practice, subject to the ordinary rules about who may practise medicine and how physicians may delegate. Ownership and medical direction are covered in our Pennsylvania regulatory profile.

What § 18.402 requires, and where it stops

A medical doctor may delegate a medical service where: the delegation is consistent with the standards of acceptable medical practice embraced by the medical doctor community in the Commonwealth; it is not prohibited by the statutes or regulations governing the delegatee’s own profession; the physician knows the delegatee has the education, training, experience and continued competency to perform it safely; it creates no undue risk to this patient; the service has been explained and the patient does not object; and the physician assumes responsibility and is available as appropriate. Read the second condition again: an otherwise sound delegation fails if it is prohibited by the rules governing the delegatee’s own profession — precisely where a Pennsylvania esthetician sits awkwardly. Section 18.402(b) then withholds services requiring knowledge not commonly possessed by non-physicians, and no authority has located that ceiling for aesthetics.

The Delegation Trap: Presence Does Not Enlarge a Licence

Delegation reaches a person, not a licence

A delegation under § 18.402 attaches to an individual, for a specific service, in a specific practice. It does not amend the Cosmetology Law or expand what esthetics means. An esthetician performing a delegated medical service does so as a delegatee, not as an esthetician doing esthetics — and advertising it as esthetics, or performing it during a salon appointment, collapses the two back together in a way visible to a regulator without any investigation.

§ 7.77 and the square footage problem

Pennsylvania’s sleeper regulation says no part of a salon may be used for other purposes, and the Board has enforced it against a salon for hosting injections and needling. If your licensed salon and your medical treatment room are the same room, or share licensed square footage, a lawful delegation does not fix the problem — it creates a second one, because a prohibited service is now being performed in salon space.

The dual-use suite

The common Pennsylvania build is a suite with a facial room, a laser room, shared reception and one licence on the wall. If the salon licence covers the whole footprint, every medical procedure in the building is arguably inside licensed salon square footage; cleaner structures license only the space where esthetics actually happens. And note what delegation never does: an esthetician who performs an unauthorised service still has a licence exposed to Board discipline, and “a physician authorised it” is the argument the Board would be evaluating.

What a Med Spa Owner Must Verify Before Assigning a Treatment

Verify the licence, not the certificate

Pull the actual licence from the Commonwealth’s verification system and record the number, type and expiry. A vendor, academy or association certificate is evidence of instruction, not a Pennsylvania permission.

Map the menu procedure by procedure

Put every live service in one of three columns: inside the esthetician licence, medical service requiring delegation, or not offered. Do it at the level of the actual service — “facials” is not one row when one of them ends with a diamond-tip handpiece.

Know which licence the room is operating under

For each treatment room, write down whether it sits inside salon licensed square footage. If it does, only esthetics happens there. This is the check almost no Pennsylvania practice performs, and the one the Board’s own orders are built around.

Fix the marketing and the booking page

Regulators read websites. If yours advertises microneedling under an “esthetics” heading, or names an esthetician as the provider of a device treatment, you have published the evidence yourself.

Write down who decided, and on what basis

For every service in the delegation column, keep a one-page record: the authorising physician, the date, the delegatee, the basis for believing that person competent, and the protocol version in force. Section 18.402 puts the physician’s knowledge of competency at the centre of the analysis, and knowledge existing only in memory is hard to demonstrate two years later.

Training and Documentation Records That Actually Matter

What the 300-hour curriculum does and does not cover

Pennsylvania requires a minimum of 300 hours of skin care instruction at a licensed school before esthetician licensure, weighted toward professional practices, sciences, facial treatments, temporary hair removal and makeup. Set that against a med spa job description including device operation and peel selection and the gap is obvious. The licence establishes a baseline in facial esthetics; it certifies nothing about procedures the Cosmetology Law never contemplated.

The competency file § 18.402 implicitly requires

For anyone performing a delegated medical service, keep a file that lets a physician demonstrate the knowledge the rule demands: initial training with dates and hours, the trainer and their credential, supervised cases with a signed sign-off, device-specific check-offs, and periodic re-verification. “Continued competency” is in the rule, so a certificate from 2021 does not discharge it. Write your own protocol for each procedure — a manufacturer’s treatment guide is written to sell a device and will not read well as your standard of care.

Consent and the referral trail

Consent should name the actual procedure, the performer and their credential, realistic outcomes, the specific risks, and the alternatives. Keep the intake, photographs, settings, product lot numbers and post-treatment contact. And keep a referral trail: an esthetician who notices a suspicious lesion or a non-healing area should document a referral rather than treating around it.

What Happens When a Pennsylvania Esthetician Exceeds Scope

Exposure for the licensee

Practising outside the licence is a Cosmetology Law problem first. Section 2 of the act, 63 P.S. § 508, makes it unlawful to practise esthetics without the appropriate licence, and the penalty provision at 63 P.S. § 526 provides for summary conviction with a fine not exceeding $300 for a first offence, rising to $600 or imprisonment not exceeding six months, or both, for subsequent offences. The Board may also levy a civil penalty of up to $1,000 for practising without proper licensure, after a hearing; the Commissioner’s schedule sits at 49 Pa. Code § 43b.5. Alongside the money runs the thing that actually costs a career: discipline against the licence itself.

Exposure for the salon

The salon is a separate licensee with separate exposure, and § 7.77 is the mechanism. The Umbrella Beauty Center order is the template: a civil penalty against the salon licence plus a cease-and-desist covering services performed inside the licensed square footage. An owner who personally performed nothing is still the licence-holder who allowed them there.

Exposure for the med spa and the physician

Where the service is a medical one, the analysis shifts to the Medical Practice Act. Unlawful practice of medicine and surgery may be enjoined by the courts on petition of the Board or the Commissioner under 63 P.S. § 422.38, and the Board may impose a monetary penalty under 63 P.S. § 422.42. A physician whose delegation did not meet the § 18.402 conditions has their own licence in the frame. We have deliberately not quoted a criminal grading for unlicensed medical practice, because we could not verify that provision’s current text against a primary source.

The insurance problem

Professional liability policies are written around the licence, and most exclude services outside the insured’s lawful scope. A patient injured during a procedure the licence did not authorise is therefore not only a claim but frequently an uninsured one.

Was There a 2026 Pennsylvania Change? The Honest Answer

What we checked

Nothing material moved in 2026. We reviewed the Cosmetology chapter of 49 Pa. Code, including § 7.1 and the scope sections at §§ 7.14 and 7.14a; the delegation rules at § 18.402 and § 25.217; the Cosmetology Law; and the legislative record. The core provisions carry amendment dates from 2009. The framework is stable, and old.

What is actually moving

The live activity is legislative rather than regulatory, and it has not landed: House Bill 2456 in 2019–20 and House Bill 1249 in 2021–22 were referred to the House Professional Licensure Committee and not enacted. If a comparable bill ever passes and the Board writes the regulations it would require, the answers here change for two procedures. Until then they do not, and anyone selling you a 2026 rule change should be asked to name the citation. For the state summary and primary source links, see our Pennsylvania med spa regulations page.

The Questions Pennsylvania Has Not Answered

An honest scope guide names its gaps. These are the questions we could not resolve against a primary source, where a cautious operator should assume the narrower reading:

• Dermaplaning. No prohibition, no authorisation, no Board statement.
• Hydradermabrasion devices. Never addressed by name, while the adjacent technique of microdermabrasion has been called a violation.
• Peel depth. No depth rule, no percentage rule, no guidance; the line is inferred from two definitions in different acts.
• Which delegatees may receive which cosmetic procedures. Section 18.402 names no procedures and lists no credentials.
• What “available to the delegatee” means. No distance requirement, no response time, no device-specific interpretation.
• Lancets and other puncture tools in facial work. No instrument rule either way.

On every one, the pattern across Pennsylvania’s actual decisions has been consistent: the list in § 7.1 is read as a list, and services outside it are outside the licence regardless of how gentle they are.

Summary

1. Pennsylvania licenses these practitioners as estheticians, and defines esthetics narrowly at 49 Pa. Code § 7.1 as a closed list of facial acts plus industry standard apparatus used in that practice.
2. Section 7.14a confines the holder to esthetician services only; § 7.14 lets a cosmetologist perform esthetician functions, but not the reverse.
3. Microneedling is out. The Bureau told salons in writing it violates the Cosmetology Law, two bills to permit it died in committee, and the Board has penalised a salon for offering it.
4. Pennsylvania draws no cosmetic-versus-medical needle depth line, so the shallow-cartridge argument has nothing to attach to.
5. Superficial peels are defensible as cosmetic preparations applied to the face; medium and deep peels fit the definition of medicine and surgery at 63 P.S. § 422.2.
6. Lasers, IPL, radiofrequency and focused ultrasound are outside the licence — not because a laser rule forbids them, but because there is none, and the apparatus clause reaches only appliances used in the practice of esthetics.
7. Injections of any kind are out unconditionally; the Board has already named Botox and lip fillers as prohibited services in a published order.
8. Dermaplaning and hydradermabrasion are genuinely unsettled; the conservative reading places both outside the licence.
9. Delegation under 49 Pa. Code § 18.402 or § 25.217 reaches a person, never a licence — and § 7.77 keeps delegated medical services out of licensed salon square footage.
10. Nothing material changed in 2026; the governing provisions carry 2009 amendment dates.

Disclaimer: This article is for educational purposes only and is not legal advice. Pennsylvania esthetician scope sits at the intersection of the Cosmetology Law, Chapter 7 of 49 Pa. Code, the Medical Practice Act and the delegation rules of two medical boards, and several of the questions above are genuinely unresolved. Verify current citations yourself and consult a Pennsylvania healthcare attorney before building a service menu, a delegation structure or a floor plan around any reading here.