Improving Boston Nail Salon Indoor Air Quality Through Local Public Health Regulation, 2007–2019

Abstract

In 2011, following years of outreach and training, Boston, Massachusetts, enacted regulations to improve health and safety in nail salons. These were amended in 2013 to require mechanical ventilation, including dedicated exhaust for each manicure and pedicure station. As of June 2019, 185 of 190 salons have satisfied the regulatory requirements. Regulations can help ensure that environmental health benefits are widespread and that small businesses’ investment in occupational health does not result in a competitive disadvantage.

There has been recent attention to the poor health outcomes associated with environmental exposure to the chemicals in nail salon products, particularly for nail salon employees.¹ Salon products, including gel polishes, acrylic nail preparations, polish removers, and cleaners, contain potentially hazardous ingredients that can contaminate salon air.²

INTERVENTION

Despite outreach efforts to Boston, Massachusetts, nail salons through the Safe Shops Program, a program of the City of Boston’s health department, the Boston Public Health Commission (BPHC), salon owners generally did not invest in ventilation to improve air quality, fearing that the cost would outweigh the perceived benefits. To level the playing field for investment in environmental health, BPHC implemented an innovative combination strategy of regulation and outreach to promote health equity by reducing chemical exposures and poor health outcomes associated with nail salon employment.³ Outreach efforts included linguistically and culturally appropriate printed materials, videos, and in-salon trainings to promote adoption of health and safety best practices. Outreach workers also connected salon owners to business assistance and other resources.

Following hundreds of outreach visits, BPHC promulgated regulations in 2011 establishing nail salon permits and inspections and setting standards for sanitation, chemical storage, and safety. These regulations were amended in 2013 to adopt the ventilation requirements of the International Mechanical Code (IMC), referenced in the Massachusetts Building Code. The IMC specifies that nail salons must have “source capture” exhaust ventilation at each manicure table and pedicure chair, and fresh air must be provided to the salon at a specified rate. Salon owners submitted ventilation design drawings stamped or signed by a state-licensed engineer ensuring that the design met the IMC requirements. Following review of submissions, BPHC inspected the installed systems and verified compliance.

PLACE AND TIME

Safe Shops Program staff began developing materials and conducting educational outreach to small businesses in 2007.³ Work with Boston’s nail salons began in 2009 and expanded with the new regulations in 2011. Businesses first permitted prior to the October 2013 regulation amendment had five years to comply with the ventilation requirements, whereas businesses applying for their first permit after the amendments were required to comply before they could receive their permit.

PERSON

Permit records show 190 businesses covered by the BPHC Nail Salon Regulation as of June 2019. We estimate that these businesses employ about 950 nail technicians and serve thousands of customers. Family members (including children) of customers and technicians also visit the salons. Outreach staff observations showed that even though both women and men work in salons, most Boston nail technicians are women, many of childbearing age. In addition, staff observations indicated that many of Boston’s nail salons are owned and staffed by Vietnamese immigrants. Outreach was provided in Vietnamese and English.

PURPOSE

Poor indoor air quality is a common problem in salon environments.^4,5 Contaminants can include methacrylates, acetone and other organic solvents, formaldehyde, and fine particulate matter.^2,4,5 Studies have shown that nail technicians report negative work-related health outcomes, including asthma; respiratory tract, skin, and eye irritation; headaches; and dizziness; and may have excessive rates of reproductive harms, neurological damage, and cancer.^6,7 Few standards are relevant to the control of air quality in nail salons, and enforcement in this sector is limited. To fill this gap, both the US Occupational Safety and Health Administration and the US Environmental Protection Agency have developed “best practices” guidance. Advocates and product manufacturers are also working to reduce hazardous ingredients in nail products. However, ventilation is currently the most viable industrial hygiene intervention to reduce the potential for exposure to toxic chemicals by this vulnerable salon worker population, advancing the BPHC’s mission to promote health equity.

IMPLEMENTATION

Table 1 details implementation milestones. Following the regulation amendments in 2013, the Safe Shops Program’s two health advocates and their supervising coordinator executed an educational outreach plan to assist salon owners with the transition, intensifying outreach as the deadline approached. Between January 1, 2016, and June 18, 2019, program staff conducted almost 4000 outreach visits, including more than 200 health and safety trainings. They conducted 1044 outreach visits in the first 10 months of 2018 alone as the October 17, 2018, deadline approached. Program staff also assisted salon owners and employees by telephone and in walk-in visits to the BPHC office, conducted mass mailings, distributed materials to all salons, and held three community meetings in locations around Boston to increase understanding of the ventilation requirements. The BPHC also provided financial assistance packages on a competitive basis to assist “early adopter” owners with design and installation costs.

TABLE 1—

Nail Salon Ventilation Compliance as of June 18, 2019: Boston, MA

Inputs	Outputs	Outcome
190 nail salons in Boston	146 (76.8%) have compliant ventilation	890 of an estimated 950 nail technicians (based on ∼5 employees per shop, on average) are protected from chemical exposure
5 years to comply with IMC ventilation requirements	32 (16.8%) have received waivers
3.25 staff devoted to nail salons	5 (2.6%) have taken no action
1600 educational materials printed	7 (3.7%) have no permit or are not open
$76 000 in financial support given
3 public meetings held to discuss ventilation requirements
3194 outreach visits conducted between January 1, 2016, and June 18, 2019, including 1197 in 2018 as the deadline approached
4 letters sent to remind all nail salons of ventilation deadline

Note. IMC = International Mechanical Code. This table shows the multipronged effort put forth to support Boston’s nail salons in complying with the IMC’s ventilation requirements. As of June 18, 2019, 8 months after the October 17, 2018, compliance deadline, the majority (76.8%) of Boston’s nail salons had achieved compliance, and an additional 16.8% had received waivers from these requirements.

EVALUATION

Within eight months after the October 17, 2018, compliance deadline, almost all businesses offering nail services in Boston either had built compliant ventilation systems or had received waivers because of extenuating circumstances, such as historic building designation or salons losing their lease and scheduled to close within six to nine months after the deadline, preventing installation. Only 5 of 190 salons had taken no action and have been subject to enforcement follow-up. The combination of environmental health regulation and outreach contributed to the successful implementation and resulted in improved air quality for salon owners, workers, clients, and visitors.

ADVERSE EFFECTS

Compliant ventilation design and installation are a significant business investment, and ongoing operation (heating and cooling air, electricity for fans) and maintenance costs may have a financial effect on businesses. Analysis of permit data found that the rate at which salons closed and new salons opened remained relatively constant leading up to and following the compliance deadline. Some salon owners reported difficulties complying with the requirements because they lacked leases, their lease ended shortly after the deadline, or their landlords did not permit them to make any changes to the building.

SUSTAINABILITY

The Safe Shops Program was launched with support from grants, including an Environmental Protection Agency Community Action for a Renewed Environment grant, a Centers for Disease Control and Prevention cooperative agreement, and a University of Massachusetts Lowell Toxics Use Reduction Institute grant. In 2016, the program expanded to include hair salons, with support from an Environmental Protection Agency Healthy Communities grant.

Today, the Safe Shops Program is funded by the City of Boston as a permanent program of the BPHC. The BPHC Nail Salon Regulation includes an annual permit fee that supports administrative and enforcement activities, supports production of educational materials, and partially supports the outreach staff positions. Periodic inspections ensure that salons are operating their ventilation systems and have no other violations. Nail salons that fail to meet the requirements are provided outreach and technical assistance from the Safe Shops Program but are ultimately subject to enforcement action, which may include fines and denial of a permit.

PUBLIC HEALTH SIGNIFICANCE

The BPHC is among the first in the nation to direct public health inspectors to enforce IMC-compliant ventilation in nail salons as a means of protecting employees, clients, and children of employees and clients from exposure to harmful chemicals. BPHC’s success in implementing this regulation, achieved through outreach efforts that increased over the five years leading up to the regulatory deadline, shows feasibility and effectiveness of regulatory strategies despite challenges such as language and cultural barriers, financial considerations of small businesses, negotiations between salons and landlords, and limitations in local public health resources. Further research is planned to assess the effect of the regulation on exposures and health. The BPHC Nail Salon Regulation, and the education, compliance assistance, and enforcement strategy associated with it, may serve as a model for local public health initiatives to improve environmental health.