Results
From 2006 to 2012, the overwhelming majority of licensed or registered braiders never received a complaint, regardless of their state and how many training hours it required for licensure. Among the more than 9,700 licensed or registered braiders in the nine states and D.C., just 95 had a complaint file, 1 the vast majority of them in Florida. Only one braider had a complaint filed against them by an actual consumer. In addition, the nine states and D.C. received only 27 complaints regarding unlicensed braiders during the seven-year period. For both licensed and unlicensed braiders, most complaints were about licensure status, not health or safety. Further, states with more onerous requirements for licensure do not appear to offer any public safety advantage over states with less onerous requirements. However, they do tend to have fewer licensed braiders.
Licensed/Registered Braiders
Between 2006 and 2012, a total of 103 complaints were filed—only one of them by a consumer—against any of the 9,731 licensed or registered braiders in the nine states and D.C. This puts a licensed or registered braider’s probability of receiving a complaint at just 0.34% (see Table 2). 2
A licensed or registered braider’s probability of receiving a complaint from a consumer is even lower at 0.0035%.
Table 2: Licensed/Registered Braider’s Probability of a Complaint File by Complainant Type
| Complainant | Complaint File |
|---|---|
| Consumer | 0.0035% |
| Other | 0.0035% |
| Licensee | 0.0840% |
| Board | 0.2696% |
| All | 0.34% |
Table 3 disaggregates complaints against licensed or registered braiders by state and complainant and the issue or issues reported in the initial complaint or in a subsequent board follow-up. It shows that almost three-quarters of complaints against licensed braiders (77 of 103) came directly from cosmetology boards, with the next largest share by a wide margin coming from the boards’ licensees. 3 Figure 3 shows the proportion of complaint files for licensed or registered braiders received from each complainant type. Ninety-nine of the complaints were from Florida, with 80% of those originating with the Florida Board of Cosmetology. 4 The four remaining complaints were split between Ohio (2), Mississippi (1) and New York (1). The other five states and D.C. reported zero complaints.
Table 3: Issues in Complaint Files of Licensed/Registered Braiders,
Nine States and D.C., 2006-2012
| Issues | Total Complaint Files* | ||||
|---|---|---|---|---|---|
| Health and Safety | Unlicensed Braiding** | Unlicensed Cosmetology | Other | ||
| Complainant | |||||
| Consumer | 1 | 1 | 0 | 0 | 1 |
| Other | 0 | 0 | 1 | 0 | 1 |
| Licensee | 0 | 23 | 1 | 0 | 24 |
| Board | 3 | 37 | 41 | 0 | 77 |
| State (training hours required) | |||||
| District of Columbia (100) | 0 | 0 | 0 | 0 | 0 |
| Florida (16) | 3 | 59 | 40 | 0 | 99 |
| Louisiana (500) | 0 | 0 | 0 | 0 | 0 |
| Mississippi (0) | 0 | 0 | 1 | 0 | 1 |
| Nevada (250)*** | 0 | 0 | 0 | 0 | 0 |
| New York (300) | 0 | 0 | 1 | 0 | 1 |
| Ohio (450) | 1 | 2 | 1 | 0 | 2 |
| Oklahoma (600) | 0 | 0 | 0 | 0 | 0 |
| Tennessee (300) | 0 | 0 | 0 | 0 | 0 |
| Texas (35)**** | 0 | 0 | 0 | 0 | 0 |
| Total | 4 | 61 | 43 | 0 | 103 |
* A complaint file may have multiple issues.
** Licensed braiders may have complaints calling them unlicensed. These are most often for braiders who have lapsed licenses or who falsely obtained licenses.
*** Nevada did not have a specialty braiding license until 2011.
**** Texas stopped licensing hair braiders in 2015.
Not only were most complaints against licensed braiders filed by cosmetology insiders, but, as Figure 4 shows, the vast majority of complaints were about the unlicensed practice of braiding or cosmetology. Health and safety issues were implicated in only four of the 103 complaints. Three of these complaints were from the Florida Board of Cosmetology and concerned issues found during routine inspections. One of the Florida complaints was dismissed and one involved two unspecified violations that led to a $100 fine. The third cited a salon for poor lighting and ventilation and dirty fixtures, in addition to the unlicensed practice of cosmetology, and fined the owner $500. The fourth and final complaint related to health and safety came from an Ohio consumer who reported a braiding salon for having a hole in the ceiling, water leaks and poor lighting. The state cosmetology board has no records indicating any follow-up actions it may have taken in regard to this complaint.
The existence of so few complaints with health and safety issues suggests that there is little threat to consumers from braiding, whether states require zero training hours for licensure or 600. However, with so few complaints, it is impossible to run a statistical analysis to verify the lack of statistically significant differences between the states.
Unlicensed Braiders
Boards received only 27 complaints against unlicensed braiders during the study period. Unfortunately, because the number of braiders operating without a license is unknown, it is impossible to determine the probability of an unlicensed braider receiving a complaint—or, put differently, how common complaints against unlicensed braiders are. It is likewise impossible to analyze probabilities by type of complaint.
Table 4 disaggregates complaints against unlicensed individuals by state, complainant and the issue or issues reported in the complaint or in a subsequent board follow-up. It shows 27 complaint files between 2006 and 2012, split among five of the states: Ohio (12), New York (7), Florida (5), Oklahoma (2) and Texas (1). The remaining four states and D.C. received no complaints against unlicensed braiders.
Table 4: Issues in Complaint Files of Unlicensed Braiders,
Nine States and D.C., 2006–2012
| Issues | Total Complaint Files* | ||||
|---|---|---|---|---|---|
| Health and Safety | Unlicensed Braiding** | Unlicensed Cosmetology | Other | ||
| Complainant | |||||
| Consumer | 7 | 6 | 5 | 2 | 11 |
| Other | 1 | 3 | 0 | 1 | 3 |
| Licensee | 0 | 4 | 0 | 0 | 4 |
| Board | 1 | 9 | 3 | 0 | 9 |
| State (training hours required) | |||||
| District of Columbia (100) | 0 | 0 | 0 | 0 | 0 |
| Florida (16) | 0 | 5 | 2 | 1 | 5 |
| Louisiana (500) | 0 | 0 | 0 | 0 | 0 |
| Mississippi (0) | 0 | 0 | 0 | 0 | 0 |
| Nevada (250)** | 0 | 0 | 0 | 0 | 0 |
| New York (300) | 4 | 5 | 3 | 0 | 7 |
| Ohio (450) | 5 | 10 | 2 | 1 | 12 |
| Oklahoma (600) | 0 | 2 | 0 | 0 | 2 |
| Tennessee (300) | 0 | 0 | 0 | 0 | 0 |
| Texas (35)*** | 0 | 0 | 1 | 1 | 1 |
| Total | 9 | 22 | 8 | 3 | 27 |
* A complaint file may have multiple issues.
** Nevada did not have a specialty braiding license until 2011.
*** Texas stopped licensing hair braiders in 2015.
As with licensed and registered braiders, most complaints against unlicensed braiders were about their licensure status. Only nine cited health and safety issues, and they came from just two states, Ohio and New York. 5 The other seven states and D.C. received no health and safety complaints. The nine complaints with health and safety issues fell evenly into three categories—sanitation, scalp burns and hair loss. Sanitation issues were implicated in three Ohio complaints: a braider washing hair with a bucket of dirty water (consumer), a salon operating without running water (other), and a salon with a carpeted service area and a blow dryer sitting on the floor (board). In each case, the Ohio board sent a cease-and-desist letter demanding a stop to the unlicensed practice of braiding.
Scalp burns featured in three New York complaints. However, two of these were unsubstantiated, opened by the state’s Division of Licensing Services (DLS) based on newspaper stories. The DLS was unable to track down the women claiming to have been burned by hot water. The third burn complaint came from a New York consumer who reported that an unlicensed braider had burned her scalp with a handheld dryer—legal for licensed braiders to use in the state. She also reported that the salon lacked hot water and tried to use a dirty bucket to wash her hair. The DLS made no follow-up regarding the burned scalp; however, it did file an administrative complaint for the sanitation issues and unlicensed practice. The owner failed to properly respond to the administrative procedures and was ultimately fined $3,500 for not responding or paying the initial fine.
Hair loss was the subject of the final three complaints. A New York consumer complained that after three weeks her braids were falling out along with her hair, leaving her with a bald spot. An investigation of the salon found several sanitation issues, including failure to retain invoices for disinfectants and keep material safety data sheets available. Records do not indicate whether the board took any additional action. Two Ohio consumers complained of hair loss, balding or altered hairline after getting their hair braided. Records only indicate one of these businesses received a cease-and-desist letter demanding that it stop practicing braiding without a license. It is unclear whether the individuals complaining of hair loss were ever formally diagnosed with braiding-related hair loss.
In sum, across seven years and 10 jurisdictions, just nine complaints with health and safety issues were received for unlicensed braiders—just over one per year and just less than one per jurisdiction. Further, none of the complaints alleging consumer harm were verified by licensing boards. And as with licensed and registered braiders, there are too few complaints against unlicensed braiders for a statistical analysis comparing complaints across licensing regimes. Also needed for such an analysis would be the population of unlicensed braiders, which is unknowable. However, only two states, New York and Ohio, reported health and safety complaints against unlicensed braiders, and both have relatively steep licensing burdens. Seven states and D.C. received no complaints against unlicensed braiders involving health or safety.
Licensed Braider Populations
While complaint data fail to show a link between higher licensing burdens and fewer health and safety complaints, the analysis of licensed braider populations does find a link between states that have higher licensing burdens and fewer braiders. For eight states and D.C., it reveals a correlation between the number of braiders per 10,000 black immigrant or African-Americans in the state population and the state. In other words, after taking the black population into account, Florida, Mississippi, South Carolina, Texas and D.C., states that required relatively fewer training hours (100 or less), had more braiders compared to Louisiana, New York, Ohio and Tennessee, states that required 300 hours or more of training. 6 See Appendix C for the regression results of the population analysis.