Spray Tanning Professional Certification Course
Module 6: Client Safety, Health, and Hygiene
Section 6.1: Sanitation and Infection Prevention Standards
Introduction
Safety and hygiene are the foundation of any professional spray tanning business. Beyond creating beautiful results, your duty as a certified spray tan artist is to protect both clients and yourself from possible contamination, infection, or cross-contact of products and tools.
Unlike hair or nail salons, spray tanning may not always fall under cosmetology oversight in every region, but the same sanitation standards must apply. Cleanliness builds trust, prevents illness, and positions you as a professional who values health as much as aesthetics.
This section provides the full professional protocol for sanitation, disinfection, infection prevention, and workspace hygiene — ensuring every client experience meets top-tier safety standards.
1. The Importance of Hygiene in Spray Tanning
Spray tanning involves close physical proximity, shared equipment, and frequent skin exposure. Without strict hygiene, bacteria, fungi, and viruses can easily transfer between clients via tools, hands, or contaminated surfaces.
Poor hygiene can lead to:
Skin irritations and infections.
Cross-contamination of tanning solution bottles.
Respiratory irritation from aerosolized mist.
Damage to your professional reputation and legal liability.
Cleanliness is not optional — it’s a client safety requirement and a marker of professionalism.
2. Understanding Infection Pathways
Contamination can occur in several ways during spray tanning:
Direct contact: Technician touches client skin without gloves.
Indirect contact: Shared equipment (spray guns, towels, tents) not properly sanitized.
Airborne: Mist particles or droplets inhaled or settling on surfaces.
Environmental: Moisture or residue promoting bacterial growth in poorly ventilated rooms.
Recognizing these pathways allows you to break the chain of infection before it starts.
3. Hand Hygiene Protocol
Your hands are your most frequently used tools — and the most common carriers of germs.
Professional Hand Hygiene Standards:
Wash hands with warm water and antibacterial soap before and after every client.
Dry thoroughly using disposable towels or air dryers.
Use 60–70% alcohol-based sanitizer immediately before gloving.
Always wear new disposable nitrile or latex-free gloves for each client.
Avoid touching your face, phone, or other surfaces while gloved.
Never reuse gloves. Dispose of them in a sealed waste bin after each session.
4. Personal Protective Equipment (PPE)
PPE protects both you and your clients from airborne particles and cross-contamination. Always have the following available:
Face mask or respirator: Use during all spray applications.
Eye protection: Recommended when mixing or refilling solutions.
Apron or smock: Prevents solution residue on clothing.
Hair cap or tie: Keeps hair free from aerosol mist.
Closed-toe shoes: For safety and professionalism.
For mobile tanning, carry extra masks and gloves for every appointment to maintain consistency.
5. Cleaning and Disinfecting Equipment
Spray tanning equipment requires regular maintenance to remain sanitary and functional. DHA residue, oils, and bronzers can harbor bacteria if not cleaned promptly.
After Every Client:
Flush the spray gun with warm water or cleaning solution.
Wipe the exterior with disinfectant spray or alcohol wipes.
Empty leftover solution — never reuse or top up old product.
Disinfect air caps, hoses, and nozzles with professional-grade sanitizers.
End of Each Day:
Deep clean your spray gun using manufacturer’s disassembly instructions.
Soak removable parts (metal only) in mild disinfectant for 10–15 minutes.
Wipe down tent walls, floors, and fans.
Mop or disinfect floors around the spray area.
Regular cleaning ensures even spray performance and maintains professional hygiene standards.
6. Surface and Workspace Disinfection
Your tanning environment must always look and be spotless. Clients will instantly notice clutter, sticky floors, or residue buildup.
Between Clients:
Wipe chairs, handles, tables, and mirrors with disinfectant.
Replace disposable towels, sticky feet, and nose filters.
Empty and replace trash liners as needed.
End-of-Day Deep Clean:
Sanitize walls and tent interiors with DHA-safe cleaners.
Vacuum or mop floors using non-slip disinfectant solutions.
Clean extractor fans and replace filters as scheduled.
Always allow surfaces to dry completely before the next client — moisture promotes bacterial growth.
7. Tool and Supply Management
Organize tools and disposables to prevent cross-contact.
Keep clean and used items separated at all times.
Store clean tools in closed containers.
Dispose of sponges, blending mitts, and barrier wipes after one use.
Label bottles and containers clearly (“clean,” “used,” “solution only”).
A tidy, well-labeled workstation signals professionalism and prevents costly mistakes.
8. Ventilation and Air Quality Control
Proper airflow prevents accumulation of overspray particles and maintains air quality.
Professional Standards:
Use an extraction fan or filtration system to remove mist from the air.
Change filters weekly or as directed by manufacturer.
Open windows when possible to allow fresh air circulation.
Wear a protective mask when spraying in confined spaces.
Clean air protects respiratory health — yours and your clients’.
9. Waste Disposal and Environmental Hygiene
Safe waste disposal is both ethical and often required by law.
Dispose of gloves, wipes, barrier cream applicators, and disposable items immediately after use.
Never pour leftover solution down sinks unless allowed by local regulation.
Seal all trash bags tightly before removal.
Clean and disinfect bins daily.
For mobile tanners, carry portable waste bags and return all disposables to your base for proper disposal.
10. Skin Contact and Cross-Contamination Prevention
Always minimize skin-to-skin contact during services. When contact is necessary, ensure gloves are worn and replaced after any interruption (e.g., touching your face, phone, or surfaces).
Never reuse towels or mitts between clients — even if “clean looking.” Spray tanning involves invisible residue that can harbor bacteria and odor.
11. Managing Accidental Contamination
If you accidentally touch an unclean surface mid-session:
Stop spraying immediately.
Safely remove gloves.
Sanitize hands and put on new gloves.
Wipe affected surfaces before continuing.
In case of equipment contamination (e.g., spray gun dropped or solution spilled), pause service and re-sanitize before resuming.
Clients notice how professionals handle small errors — careful correction demonstrates responsibility.
12. Personal Hygiene and Presentation
Your personal cleanliness reflects your brand. Maintain professional grooming standards:
Freshly washed hands, hair tied back, and clean uniform.
No strong perfumes or scented lotions (they can interfere with DHA).
Fingernails short and clean.
No jewelry that could touch or scratch the client.
Clean appearance builds immediate trust and conveys respect for health standards.
13. State and Local Sanitation Regulations
Even if spray tanning isn’t directly regulated by cosmetology laws in your area, always meet or exceed those hygiene standards.
Check with your state or provincial health department for:
Local salon sanitation codes.
Waste disposal rules.
Required signage or cleaning logs.
Ventilation system regulations.
Documenting your cleaning schedule protects you from inspection or liability issues.
14. Client Confidence Through Visible Cleanliness
Clients feel safer when they see visible sanitation practices. Make cleaning part of the show — wiping surfaces and sanitizing tools in front of them communicates transparency and care.
Consider posting a framed “Cleanliness Commitment” in your studio, listing your sanitation promises and safety certifications.
15. Recordkeeping and Sanitation Logs
Maintain a written log of your cleaning routines, product lot numbers, and replacement schedules. This is especially useful for:
Inspections or insurance audits.
Tracing product issues or allergic reactions.
Building client trust through professionalism.
A well-documented sanitation system also supports your business reputation during growth and training of future employees.
Conclusion
Cleanliness is more than a checklist — it’s the heartbeat of your professional reputation. Every sanitized surface, replaced glove, and cleaned spray gun reflects your dedication to client health and ethical standards.
By maintaining top-tier sanitation and infection control, you not only protect your clients but also elevate your brand into a trusted, safety-conscious leader in the spray tanning industry.
Section 6.2: Proper Ventilation and Personal Protective Equipment (PPE)
Introduction
Spray tanning is generally safe when performed correctly, but the process involves aerosolized mist containing DHA, bronzers, and additives that can linger in the air. Without proper ventilation and protective gear, these airborne particles can be inhaled or settle on surfaces, posing health risks to both clients and technicians.
This section covers the essential professional standards for ventilation, air quality management, and personal protective equipment (PPE) — ensuring every service is performed in a safe, compliant, and health-conscious environment. Proper air control and protective practices are the foundation of a truly professional studio.
1. Why Ventilation Matters
When spray solution is atomized by an HVLP or airbrush gun, it becomes a fine mist suspended in the air. While DHA is non-toxic and approved for topical use, inhalation or prolonged exposure to airborne mist can irritate the lungs, throat, or eyes.
Good ventilation ensures:
Safe air quality for both technician and client.
Reduced overspray buildup on surfaces and walls.
Cleaner, more comfortable studio conditions.
Compliance with OSHA and local health safety guidelines.
In short — ventilation protects your lungs, your professionalism, and your equipment.
2. Understanding Spray Mist Behavior
A spray tan gun releases a continuous mist under air pressure. Particles that don’t land on the client disperse in the air and can settle on floors, furniture, or your respiratory system.
Factors that influence overspray:
Air pressure settings: Too high causes excess misting.
Room size: Small rooms trap particles faster.
Airflow pattern: Poor airflow allows recirculation.
Frequency of service: More sessions per day = higher exposure risk.
Understanding how air moves in your workspace allows you to strategically control contamination and maintain clean air.
3. Recommended Ventilation Setup for Studios
Every professional spray tanning studio should have a ventilation system designed to remove airborne particles effectively.
Essential Components:
Extractor Fan or Filtration Unit: Draws mist away from the air and filters it through carbon or HEPA filters.
Air Intake and Exhaust: Allows fresh air to replace filtered air, maintaining circulation.
Tanning Tent or Booth with Back Vent: Helps contain overspray and directs it toward filters.
Regular Filter Maintenance: Replace filters weekly or as specified by the manufacturer.
Position extractor fans behind or beside the client, not in front, to draw mist away efficiently.
4. Mobile Spray Tanning Ventilation
For mobile spray tanning, proper ventilation is more challenging but still essential.
Best Practices:
Always set up in a well-ventilated area, such as near open windows or doors.
Use a portable extraction fan or filtration box positioned behind the tanning tent.
Avoid spraying in bathrooms or bedrooms without airflow.
Bring a respirator mask for both you and the client.
Your goal is to minimize mist exposure in confined environments while maintaining professional results.
5. OSHA and FDA Guidelines on DHA and Air Quality
While DHA is FDA-approved for topical application, it has not been approved for inhalation or internal exposure. For this reason, safety agencies like OSHA and the FDA strongly recommend minimizing airborne contact.
Key Guidelines:
Always provide protective coverings for the eyes, nose, and mouth.
Ensure adequate air exchange rate — ideally 6–12 air changes per hour in enclosed rooms.
Maintain consistent cleaning and filter replacement schedules.
Keep MSDS (Material Safety Data Sheets) for all tanning products available in your studio.
Compliance with these guidelines protects your business legally and physically.
6. Client Protective Equipment (PPE)
Clients should never be left unprotected during the service. Offering PPE demonstrates care and professionalism.
Essential Client PPE:
Nose filters: Prevent DHA mist from entering nasal passages.
Lip balm or petroleum jelly: Shields lips from color absorption.
Disposable caps: Protect hair and scalp from solution residue.
Eye protection: Optional goggles or disposable eye covers to prevent irritation.
Undergarment covers or disposable thongs: Maintain modesty and cleanliness.
Sticky feet or disposable pads: Prevent soles from absorbing solution and staining.
Offer these items before every session and explain their purpose to reassure clients of your safety commitment.
7. Technician Protective Equipment (PPE)
As the technician, you are the one exposed most frequently — sometimes for hours every day. Proper PPE keeps you safe, comfortable, and compliant.
Recommended Technician PPE:
Respirator mask (rated N95 or higher): Protects lungs from fine DHA particles.
Protective eyewear: Shields from mist splash or rebound.
Disposable gloves: Prevents skin contact and cross-contamination.
Apron or smock: Protects clothing and skin from staining.
Closed-toe shoes: Avoids exposure to overspray residue.
Hair covering: Keeps hair free from bronzer particles.
Replace masks regularly and wash protective clothing daily.
8. Proper Use of Respirators and Masks
Many technicians wear cloth masks or surgical masks, but these do not filter DHA mist effectively. Use respirator masks with NIOSH certification (N95, N99, or P100) for true filtration.
Usage Guidelines:
Ensure a tight fit around nose and mouth — no air leakage.
Replace filters after 8–12 hours of active spraying or as recommended.
Store in a clean, dry area between uses.
Disinfect exterior if used repeatedly during the day.
This simple step can prevent long-term respiratory irritation or health issues.
9. Air Filtration and Maintenance Schedule
Air purifiers and extraction systems are only effective if properly maintained.
Weekly:
Replace pre-filters and clean surface grilles.
Vacuum and wipe around vents to prevent buildup.
Monthly:
Inspect all hoses, seals, and duct connectors.
Deep clean fans and HEPA filters.
Quarterly:
Replace HEPA or carbon filters (depending on usage).
Schedule professional system inspection for permanent booths.
Clean air means consistent, safe results and a healthier working environment.
10. Spray Booths and Automated Systems
If you operate an automated booth, ensure it includes:
Built-in exhaust fans.
Airflow sensors for mist detection.
Automatic drying cycles.
Enclosed filtration systems.
Booths reduce technician exposure but must still be cleaned and ventilated regularly to avoid residue accumulation.
11. Managing Humidity and Temperature
Environmental conditions directly affect mist dispersion and air safety.
Optimal Spray Environment:
Temperature: 68–75°F (20–24°C)
Humidity: Below 60%
High humidity can cause DHA particles to stay suspended longer and settle on surfaces or be inhaled. Use a dehumidifier if necessary.
12. Scent and Chemical Sensitivity Precautions
Some clients may have allergies or sensitivities to fragrances or DHA additives. Always:
Offer fragrance-free solutions.
Ventilate room thoroughly before and after use.
Keep antihistamine cream or cold compresses on hand for mild reactions.
Document all allergies on the client intake form.
Ensuring air cleanliness protects clients with asthma, allergies, or chemical sensitivities.
13. Mobile Tanning Health and Safety Checklist
For mobile appointments, always perform a quick environmental check:
Is there enough space and airflow?
Are windows or doors open?
Is there nearby ventilation (fan, air purifier)?
Can the tent be positioned away from furniture and fabrics?
If the space is unsafe — too small, too humid, or unventilated — it’s your responsibility to politely decline or reschedule for health reasons.
14. Compliance and Documentation
Keep a written log of:
Filter replacements and ventilation maintenance.
PPE replacements and mask usage.
Air quality equipment purchases and serial numbers.
Any reported client sensitivities or respiratory complaints.
Maintaining documentation not only protects your business from liability but also demonstrates compliance during inspections or audits.
15. Professionalism Through Air Safety
Air safety is invisible — clients can’t always see mist in the air, but they can feel when your studio smells fresh and breathable. Consistent ventilation and proper PPE use create an experience that feels clean, high-end, and trustworthy.
Clients remember how comfortable they felt as much as how they looked — and that comfort begins with clean, safe air.
Conclusion
Proper ventilation and PPE are the cornerstones of a professional, safe, and ethical spray tanning business. Every session you perform contributes to your health — so protect it.
By maintaining clean air, using protective equipment correctly, and staying compliant with safety standards, you demonstrate not only your technical skill but your integrity and responsibility as a beauty professional.
Section 6.3: Allergy Testing and Sensitivity Awareness
Introduction
Every client’s skin is different — and while spray tanning is generally safe, certain ingredients in tanning solutions or pre/post-care products can cause allergic reactions or sensitivities. As a professional, it’s your responsibility to identify risks, educate clients, and perform proper patch testing before applying any product to the full body.
This section covers how to conduct allergy and sensitivity testing, recognize warning signs of adverse reactions, and handle situations where clients report irritation or allergic symptoms. Your ability to anticipate and manage these issues demonstrates professional integrity and care.
1. Why Allergy Testing Is Essential
Spray tanning solutions contain various ingredients — DHA, bronzers, preservatives, fragrances, and botanical extracts. While most people tolerate them well, clients with sensitive or compromised skin may experience redness, itching, or rash-like irritation.
Conducting a patch test before service:
Prevents severe allergic reactions.
Builds client confidence in your professionalism.
Helps identify ingredient sensitivities early.
Reduces liability in the event of a reaction.
Never assume a client has “used tanning before.” Skin sensitivities can change with age, medication, or health status.
2. Understanding Common Allergens in Tanning Products
While DHA is the active tanning agent, reactions are more commonly caused by secondary ingredients. Common irritants include:
Fragrance compounds: Perfumes or synthetic scents.
Preservatives: Such as parabens or formaldehyde-releasing agents.
Botanical additives: Aloe, walnut extract, or citrus oils.
Colorants and bronzers: Especially in darker or shimmer solutions.
Alcohol-based products: Can dry and irritate sensitive skin.
Erythrulose: A secondary tanning sugar sometimes linked to mild redness.
Always check ingredient lists and choose hypoallergenic, fragrance-free options for sensitive clients.
3. The Patch Test Procedure
A patch test should be offered to every new client or anyone with known skin sensitivities. It is simple, quick, and the best insurance against adverse reactions.
How to Perform a Patch Test:
Apply a small amount of tanning solution (approximately the size of a dime) to a discreet area — usually behind the ear, on the inner arm, or on the inner thigh.
Allow it to dry naturally.
Instruct the client to leave it untouched for 24 hours.
Advise them to monitor for redness, itching, burning, or swelling.
If no reaction occurs, it’s safe to proceed with a full spray tan.
Document the patch test results in the client file before performing a full treatment.
4. Client Consultation and Sensitivity Screening
Before every tan, conduct a brief consultation that includes the following questions:
Have you ever had a reaction to tanning products, lotions, or cosmetics?
Do you have allergies to fragrances, nuts, or aloe?
Are you currently using prescription skincare, retinoids, or acne medication?
Have you had any recent chemical peels, waxing, or exfoliation?
Do you have any open cuts, eczema, or rashes?
Record their responses. This information helps you select the correct solution and avoid irritation-prone areas.
5. Recognizing an Allergic Reaction vs. Sensitivity
It’s important to distinguish between a mild sensitivity and a true allergic reaction.
Mild Sensitivity:
Temporary redness or dryness.
Slight itching that subsides within hours.
Reaction only on contact area.
Allergic Reaction:
Persistent itching or burning.
Swelling or hives.
Rash spreading beyond the treated area.
In rare cases, difficulty breathing (anaphylaxis).
If a severe allergic reaction occurs, the client must seek medical attention immediately. Never attempt to diagnose or treat beyond basic first aid.
6. Pre-Tan Product Testing
If your studio uses multiple solutions (e.g., rapid tan, organic tan, competition tan), each formula should be patch-tested separately for sensitive clients. Ingredients differ across brands — one may contain botanical extracts or higher DHA levels that another does not.
Keep patch test swabs labeled and stored in a clean container for quick use.
7. Managing a Reaction During Application
If irritation appears during a tanning session:
Stop spraying immediately.
Wipe affected area with cool, damp towel.
Remove any residue using gentle, fragrance-free cleanser.
Apply aloe vera gel or a mild hydrocortisone cream (if client consents and no known allergy).
Advise the client to rinse the skin and monitor symptoms.
If symptoms persist, instruct the client to contact their healthcare provider and report the product name and ingredients.
Document every detail — what product was used, where applied, and the time of reaction.
8. Communicating with Clients About Allergies
Approach allergy discussions with empathy and professionalism. Clients may feel embarrassed or nervous about sensitive skin, so reassure them that testing is standard and responsible practice.
You might say:
“Everyone’s skin reacts differently, and we want your tan to be both beautiful and safe. Let’s do a small patch test first — it only takes a minute and ensures your skin is fully comfortable with the solution.”
This builds trust and positions you as a professional who prioritizes safety.
9. Offering Hypoallergenic and Sensitive-Skin Solutions
Many professional brands now produce hypoallergenic, fragrance-free, and organic DHA-based solutions specifically for sensitive clients. These typically contain:
Natural DHA derived from sugar beet or cane.
No parabens, sulfates, or alcohol.
Added hydration agents like aloe, cucumber, or green tea extract.
Keep at least one gentle formula in stock to accommodate all client types. This inclusion increases your potential clientele and prevents lost business from those with allergies.
10. Environmental and Seasonal Sensitivities
Allergic flare-ups can change with the season or environment. In summer, heat and sweat can heighten skin reactivity. In winter, dryness and reduced humidity can make the skin more prone to irritation.
Encourage clients to moisturize consistently year-round and to notify you of any changes in medication or skincare that could affect skin reactivity.
11. Documentation and Liability Protection
Always document:
Whether a patch test was offered and accepted or declined.
Any reactions observed.
The product brand and lot number used.
The date and technician name.
Having written proof protects both you and your business if a client later reports an adverse reaction. Include this documentation as part of your client consent and intake form.
12. Post-Tan Reactions and Follow-Up Protocol
If a client contacts you after leaving with complaints of rash, itchiness, or irritation:
Stay calm and professional.
Request clear details (time since tan, products applied afterward, severity).
Advise them to rinse gently with cool water and apply mild moisturizer or aloe gel.
If symptoms worsen, recommend contacting a doctor or dermatologist.
Follow up the next day to check on their condition and document your communication.
Professional follow-up demonstrates genuine care and strengthens your reputation even in challenging circumstances.
13. Training Staff and Consistency in Testing
If you manage a team, ensure every technician follows the same allergy-testing procedure. Provide in-house training on:
Identifying allergic symptoms.
Handling sensitive clients respectfully.
Maintaining proper documentation.
Using clean applicators for patch testing.
Consistency ensures all clients receive the same high safety standard regardless of who performs the service.
14. When to Decline Service
As a professional, it’s acceptable — and sometimes necessary — to decline a spray tan if you suspect the client’s skin is unsafe for treatment. This includes:
Active rashes, eczema, or infections.
Open wounds or abrasions.
Severe allergic history without a completed patch test.
Politely explain that your goal is to protect their health and that the service can be rescheduled after testing or medical clearance.
15. Your Ethical Responsibility as a Professional
Your responsibility is not just to make clients look great — but to protect their skin health. Taking allergy testing seriously sets you apart from amateur technicians. It demonstrates medical awareness, professionalism, and a deep respect for client well-being.
Even if local regulations don’t require testing, following this standard builds trust and positions your studio as a safe, client-first business.
Conclusion
Allergy testing and sensitivity awareness are pillars of professional spray tanning safety. Taking a few extra minutes to perform a patch test can prevent discomfort, protect your client’s skin, and safeguard your business.
Professionalism is defined not just by artistry — but by care, precaution, and accountability. Always prioritize your client’s comfort and safety above speed or convenience.
Section 6.4: OSHA and FDA Guidelines for Spray Tanning Safety
Introduction
Every professional spray tanning business must operate within the framework of established health and safety standards. Two of the most important governing bodies in the United States are OSHA (Occupational Safety and Health Administration) and the FDA (Food and Drug Administration).
These organizations set the rules that protect both technicians and clients from exposure risks, chemical hazards, and unsafe working environments. Adhering to these standards not only safeguards health but also demonstrates professionalism, compliance, and respect for the science behind your craft.
This section explains OSHA and FDA requirements, practical safety measures, and how to implement them daily in your spray tanning practice.
1. The Role of OSHA and FDA in Spray Tanning
While spray tanning is not classified as a medical procedure, it still involves chemical exposure, aerosolized mist, and direct skin contact, all of which fall under workplace and consumer safety oversight.
OSHA protects employees and technicians, setting standards for air quality, ventilation, protective gear, and safe product handling.
The FDA regulates cosmetic ingredients, ensuring that tanning solutions are formulated with approved, safe substances for topical use.
Together, they form the framework of health standards every professional must follow — whether working in a salon, spa, or mobile tanning business.
2. FDA Regulation of DHA (Dihydroxyacetone)
The FDA classifies DHA, the active ingredient in spray tanning solutions, as a color additive approved for external application only.
Key FDA Guidelines:
DHA is safe when applied topically to the skin.
DHA should not be inhaled, ingested, or exposed to mucous membranes (eyes, nose, mouth, or internal organs).
Proper protective measures must be used during spray tanning to prevent internal exposure.
Clients should always be offered eye protection, nose filters, and lip balm during each session.
Important Note: No spray tan solution has been formally approved by the FDA for use in a booth or misting system that allows inhalation. Therefore, it is the technician’s responsibility to minimize exposure through safe technique and ventilation.
3. Understanding OSHA’s Role in Spray Tan Safety
OSHA governs workplace safety standards, including chemical handling, ventilation, and personal protective equipment. Even if you are self-employed, following OSHA’s best practices protects your health and establishes your credibility.
Core OSHA Standards Relevant to Spray Tanning:
Air Quality Standard (29 CFR 1910.1000): Maintain proper ventilation to reduce airborne mist concentration.
Hazard Communication Standard (29 CFR 1910.1200): Label and store all chemicals correctly; keep Safety Data Sheets (SDS) accessible.
Personal Protective Equipment Standard (29 CFR 1910.132): Require masks, gloves, and eye protection during spray operations.
Sanitation Standard (29 CFR 1910.141): Maintain clean, hygienic facilities with appropriate disposal systems.
Implementing these standards demonstrates your business’s commitment to workplace safety and compliance.
4. Safety Data Sheets (SDS) — Your Legal Obligation
Every tanning product you use — from DHA solution to barrier cream — must have an accompanying Safety Data Sheet (SDS).
Why It Matters:
SDS documents outline potential hazards, safe handling instructions, first-aid measures, and disposal procedures.
OSHA requires all workplaces to maintain accessible SDS records for every chemical product used.
You are legally obligated to provide SDS information to clients or employees upon request.
Professional Tip: Keep a dedicated “Safety Binder” in your studio containing:
SDS for all products and cleaning agents.
Manufacturer contact information.
Emergency procedures.
PPE maintenance logs.
This not only protects your business legally but also reassures clients that your studio meets professional health standards.
5. Client Protection Under FDA Guidelines
Because DHA is only approved for external use, you must prevent it from entering sensitive areas. Always provide and encourage use of protective items:
Eye shields or disposable eye stickers.
Nose filters to block mist inhalation.
Lip balm or petroleum jelly to seal lips.
Undergarment coverage to prevent mucosal exposure.
If a client declines PPE, document it in their file and have them sign a waiver acknowledging their choice.
Example Disclaimer:
“I have been offered protective eyewear, nose filters, and lip balm and understand that DHA is not approved for internal exposure. I decline use at my own discretion.”
Documentation protects your business while respecting client autonomy.
6. Safe Handling and Storage of Spray Tanning Products
Both OSHA and the FDA emphasize proper chemical storage to maintain safety and product quality.
Storage Guidelines:
Keep products in a cool, dry, ventilated area (between 60–75°F).
Avoid direct sunlight or high heat — DHA breaks down under UV exposure.
Label all bottles clearly with product name, brand, and expiration date.
Keep products in their original containers with intact manufacturer labels.
Store away from food, drink, or cosmetics to avoid contamination.
Discard expired or discolored solutions immediately — degraded DHA can cause streaking or unwanted orange tones.
7. Air Quality and Ventilation Requirements (OSHA Standard)
Air quality is one of OSHA’s top concerns for spray technicians. You must maintain safe levels of airborne mist during operation.
Requirements:
Maintain at least 6 to 12 air exchanges per hour in enclosed rooms.
Use extraction fans, HEPA filters, or dedicated spray booths with airflow directed away from the technician’s breathing zone.
Avoid spraying in rooms smaller than 8x8 feet without a ventilation system.
Clean and replace air filters regularly.
Monitoring air quality ensures a comfortable, hazard-free environment for both technician and client.
8. Waste Disposal and Environmental Safety
All waste — including wipes, gloves, used filters, and residual solution — must be disposed of according to OSHA’s general waste management rules.
Guidelines:
Dispose of used PPE and cleaning materials in a sealed, lined bin.
Never pour unused or leftover solution into drains unless approved by local wastewater authorities.
Wipe spills immediately and sanitize affected surfaces.
Use eco-friendly cleaners that comply with EPA and OSHA standards.
Sustainable waste management demonstrates your business’s environmental responsibility and safety awareness.
9. Labeling and Consumer Transparency
Under FDA law, all tanning products must list:
Ingredient contents (in descending order).
Manufacturer information.
Expiration date or batch code.
Usage warnings (e.g., “for external use only”).
Never repackage tanning solutions into unmarked containers or “private label” bottles without accurate labeling — doing so violates FDA guidelines and can lead to liability issues.
If you sell tanning retail products, verify they meet the same labeling standards before resale.
10. Technician Exposure Prevention
Since technicians are exposed daily, they must take additional steps to minimize cumulative chemical contact.
Best Practices:
Wear N95 or higher respirator masks during all sessions.
Keep hair tied back or under a cap.
Change gloves between clients.
Use long sleeves or aprons when spraying multiple clients in a row.
Wash hands and exposed skin thoroughly after each session.
OSHA considers repeated unprotected exposure an occupational hazard — even when using cosmetic-grade solutions.
11. Reporting and Documentation Procedures
If a client or technician experiences a reaction, both OSHA and FDA recommend documenting and reporting the incident.
Steps:
Record the event in your client or workplace log.
Identify product name, brand, and lot number.
Photograph affected areas (if client consents).
Submit a report to the FDA’s MedWatch system for serious reactions.
Keep all records on file for at least two years.
Transparency and quick reporting protect both your reputation and consumer safety.
12. Training and Compliance Certification
If you hire staff, OSHA requires you to:
Train employees in hazard communication and chemical safety.
Keep proof of training and PPE distribution.
Ensure new hires understand SDS documentation.
Even as an independent technician, completing OSHA-certified safety courses adds authority and demonstrates commitment to high professional standards.
13. Client Communication and Ethical Transparency
Always communicate FDA limitations clearly but confidently. Phrases like:
“The tanning solution is completely safe for your skin — the DHA only interacts with the surface layer. To keep you extra safe, we’ll use nose filters and lip protection during your session.”
This reassures clients while ensuring you operate within legal compliance.
14. Inspection Readiness and Professional Image
Even if local laws don’t require formal inspections, operate as if they do. Maintain:
Sanitation checklists.
PPE stock and usage records.
SDS and cleaning documentation.
Equipment maintenance logs.
A clean, documented environment impresses inspectors, reassures clients, and elevates your brand reputation.
15. Ethical Responsibility Beyond Compliance
Laws set the minimum — professionalism sets the standard. Going beyond basic compliance means building your reputation as a safety-first expert. Clients will trust you not only for your artistry but also for your integrity.
Following OSHA and FDA guidelines demonstrates respect for your own health, your clients’ well-being, and the credibility of the entire spray tanning industry.
Conclusion
Compliance is not just paperwork — it’s protection. Every OSHA and FDA standard you follow is a safeguard for your health, your clients’ trust, and your business’s longevity.
By embedding these practices into your daily routine, you position yourself as a leader in the spray tanning profession — one who blends artistry with accountability, and beauty with safety.
Section 6.5: Client Consent, Liability Waivers, and Recordkeeping
Introduction
Professionalism in spray tanning extends far beyond the artistic skill of applying a flawless glow — it also includes thorough documentation, client consent, and legal recordkeeping. Every reputable technician must protect themselves, their business, and their clients by clearly outlining expectations, risks, and responsibilities before performing any service.
This section covers everything you need to know about obtaining client consent, writing liability waivers, maintaining accurate records, and managing documentation in compliance with business and legal standards. These practices are not just administrative — they are vital components of professionalism, safety, and trust.
1. Why Consent and Documentation Matter
Consent and documentation ensure that every client:
Understands what a spray tan involves.
Acknowledges possible side effects or limitations.
Provides accurate health information to ensure safety.
Grants permission for you to perform the service.
They also protect you legally from false claims, allergic reaction disputes, or refund demands. Proper documentation can be the difference between a minor misunderstanding and a major liability issue.
2. The Professional Standard: Signed Client Consent Form
Before every spray tanning session — especially with new clients — have them read and sign a Client Consent Form.
This form confirms that:
The client understands the process and potential risks.
They have disclosed allergies, skin conditions, or medical issues.
They understand that DHA is for external use only.
They agree to follow all pre- and post-care instructions.
They have been offered protective equipment and either accepted or declined it.
Keep these forms on file (physical or digital) for at least two years to meet business recordkeeping standards.
3. Essential Clauses to Include in Every Consent Form
Your consent form should be clearly written, easy to understand, and legally sound. Include the following sections:
A. Client Information:
Full name, phone, email, and address.
Emergency contact.
B. Medical History:
Allergies, asthma, eczema, pregnancy, or medication use.
Recent exfoliation, waxing, or chemical peels.
C. Service Disclosure:
Explain:
“Spray tanning uses DHA and other approved cosmetic ingredients that react with skin’s surface to produce color.”
“This product is for external use only and should not contact the eyes, mouth, or mucous membranes.”
D. Risk Acknowledgment:
Include statements like:
“I understand that results vary based on skin type, product, and aftercare.”
“I acknowledge that allergic reactions, uneven fading, or minor irritation are possible.”
E. PPE and Safety:
“I have been offered protective eyewear, nose filters, and lip balm and understand their purpose.”
F. Consent and Signature:
“I have read and understand all information provided to me and give permission for the technician to perform this service.”
This document becomes your written proof of professionalism and client understanding.
4. Liability Waivers — Your Legal Safety Net
While consent forms protect through disclosure, liability waivers provide additional legal defense.
A liability waiver releases you from responsibility in case of normal tanning reactions, allergic responses, or color variations beyond your control.
Example Clause:
“I release the technician and business from any liability related to allergic reactions, uneven color, or results due to client non-compliance with preparation and aftercare instructions.”
Waivers should be signed before every new session or updated at least annually for returning clients.
5. Minors and Parental Consent
For clients under 18, obtain parental or guardian consent before performing any service. Include a signature line on the form such as:
“I am the legal guardian of the minor listed above and grant permission for spray tanning services to be performed.”
Some states or countries have specific age restrictions for cosmetic services — always verify local regulations and maintain written parental consent on file.
6. Medical Conditions and Contraindications Disclosure
Your consent form and verbal consultation should cover health factors that may affect spray tanning results, including:
Skin disorders (eczema, psoriasis, vitiligo).
Asthma or respiratory conditions.
Pregnancy (especially first trimester).
Open wounds or infections.
If a client discloses a medical condition, document it clearly and note any precautions you took (e.g., patch testing, adjusted formula, declined service). This protects your business if concerns arise later.
7. Photography and Media Release Forms
If you plan to take before-and-after photos for marketing, you must obtain written consent.
Include a separate photography release stating:
“I consent to the use of my images for marketing, advertising, or social media purposes. I understand my name will not be disclosed without permission.”
Always respect clients who decline photography — never pressure them. Consent builds trust; coercion destroys it.
8. Recordkeeping Best Practices
Your documentation system should be secure, organized, and accessible for quick reference.
Maintain records for each client that include:
Signed consent and waiver forms.
Service date and time.
Products and DHA percentages used.
Pre- and post-care instructions provided.
Patch test results, if applicable.
Notes on client feedback or issues.
Digital systems such as salon management software (e.g., GlossGenius, Vagaro, Square) simplify tracking and storage while keeping data protected.
9. Data Privacy and Confidentiality
Client records contain personal information and must be handled with discretion.
Confidentiality Standards:
Store physical forms in locked cabinets.
Use password-protected systems for digital records.
Never share client data or photos without written permission.
Follow applicable privacy laws (e.g., GDPR in Europe or HIPAA-inspired principles in the U.S.).
Confidentiality builds trust and demonstrates respect for client boundaries.
10. How Long to Keep Client Records
Retention requirements vary by region, but a good professional standard is:
At least 2 years for general service records.
Up to 5 years for any incident or complaint-related records.
Permanently for signed waivers if space allows (digitally stored).
Consistent recordkeeping protects you in the event of claims, audits, or product recalls.
11. Incident Reporting and Documentation
If an allergic reaction, injury, or equipment malfunction occurs, document it immediately. Include:
Date, time, and client details.
Description of incident and affected area.
Action taken (e.g., rinsed, referred to doctor).
Photos (if approved by the client).
Technician signature.
Keep these reports with your safety records for reference and potential insurance use.
12. Integrating Documentation into the Client Experience
Consent and paperwork don’t have to feel clinical or impersonal. Present them as part of your luxury experience:
“Before we begin, I’ll have you fill out a quick form that helps me customize your tan and ensure it’s 100% safe for your skin.”
When handled smoothly and with warmth, paperwork becomes a trust-building step rather than a barrier.
13. Legal Requirements for Recordkeeping
Some states require tanning businesses (especially if licensed under cosmetology) to maintain specific documentation. Check with your local licensing board for:
Minimum record retention periods.
Required consent language.
Inspection and audit procedures.
Compliance with these laws keeps your business legally sound and credible.
14. Insurance and Documentation Correlation
Your professional liability insurance will expect documentation in the event of a claim. Incomplete or missing records can void coverage.
Insurance companies typically require:
Signed consent and waiver.
Service details and product used.
Photos or written evidence of alleged issue.
Proper documentation ensures you can provide complete evidence if needed — protecting your business financially and reputationally.
15. Continuous Updates and Digital Systems
As your business grows, periodically update your forms and systems.
Review all waivers and consent language annually.
Keep digital copies backed up securely (cloud + local storage).
Train employees to use standardized forms for consistency.
Modern studios benefit from digital signature pads and automated recordkeeping — it’s faster, safer, and environmentally friendly.
Conclusion
Consent, liability, and recordkeeping are not just paperwork — they are the foundation of a safe, ethical, and professional tanning practice. By maintaining thorough documentation, you protect your clients, your business, and your reputation.
When clients see that you operate with transparency, professionalism, and legal integrity, they’ll trust you not just as a beauty service provider — but as a responsible, certified expert.