TDLR advisory board recommends package of curriculum, distance-learning and licensure edits under HB 1560

The Texas Department of Licensing and Regulation's (TDLR) Barbering and Cosmetology Advisory Board recommended adoption of a set of changes to draft rules implementing House Bill 1560 after a daylong virtual session and public comment from schools and trade groups.

Assistant general counsel Derek Burkhalter walked the board through the draft text and 70 written public comments that focused on three main subjects: how the proposed 1,000‑hour curriculum divides theory and practice, limits on distance education, and whether the merged standards should add a high‑school‑diploma or equivalent requirement for some licenses.

Public commenters representing schools and national associations urged flexibility. Brandon Martin, owner of Avenue 5 Institute, said the draft "remove[d] that discretion" for schools to allocate extra theory or practice hours when students need additional preparation. Karina Santoro, vice president of product at Milady, warned the draft could "impose unnecessary restrictions on schools by defining the full scope of the thousand hours while leaving out some critical topics."

Board action focused on staff proposals and several member motions. The advisory board voted not to add a new education prerequisite requiring a high‑school diploma or equivalent; the board's motion on that item instructed staff to retain the published approach that sets age and hour requirements but does not create a new diploma mandate. Derek Burkhalter told members the statute requires harmonization between barbering and cosmetology standards but does not itself force an added diploma requirement.

On curriculum structure, the board approved edits allowing "related theory" and "related practice" within the defined hour buckets so schools can blend instruction rather than being strictly limited to discrete theory or practice topics. The board also approved language authorizing the department to approve a single, combined curriculum that covers paragraphs 1'4 of the draft (the full package), enabling a school to offer an integrated program that would allow students to meet requirements for both cosmetology operator and class A barber licenses in one course.

Distance education drew strong public comment from students and school owners who said pandemic-era temporary allowances had allowed some students (including single parents and those living far from campuses) to complete training. The board voted to revise the draft so a school "may not designate more than 50% of the total hours in each course as theory hours delivered via distance education," and staff reiterated that practice hours must continue to be in‑person per statute.

A further edit increased the curriculum for the newly created hair‑weaving‑specialist/esthetician combination from a 700‑hour proposal to 900 hours after board members and industry representatives pointed out that the esthetician curriculum alone had previously been 750 hours; the board adjusted the internal hour buckets proportionally.

Derek Burkhalter said staff will analyze the advisory board's recommendations for statutory compliance, present the package to the commission on Dec. 6, and -- if approved by the commission and within statutory authority -- publish final dates. Staff outlined a staggered timeline the board discussed: schools can seek curriculum approval beginning Aug. 1 to prepare for fall semester, new license requirements would apply Sept. 1, and some implementation items (like continuing‑education requirements for barbers) have later phased dates.

Votes at a glance:
- Do not add a high‑school‑diploma/GED requirement to the harmonized license standard — outcome: approved by board vote (recommendation to retain draft without added diploma language).
- Allow related theory/practice blending in curriculum buckets — outcome: approved.
- Cap distance‑education theory hours at 50% (applies to hours delivered via distance education) — outcome: approved.
- Allow department approval of a combined curriculum covering paragraphs 1'4 so students can complete both licenses in one program — outcome: approved.
- Increase hair‑weaving‑specialist/esthetician combined curriculum from 700 to 900 hours (redistribute internal hours proportionally) — outcome: approved.

Next steps: the department will submit the advisory board's recommendation, along with public comments, to the commission in December. Staff said they will flag any recommended edits the department believes exceed statutory authority and will conduct any necessary cleanup rulemaking later. If the commission adopts the package and statutory authority permits, curriculum approvals can begin Aug. 1 and the new license requirements would apply Sept. 1.

Speakers quoted are members of the advisory board and public commenters; quoted text comes from public comment and staff presentations at the Oct. 31 advisory meeting. The board did not adopt any change that the transcript shows staff would treat as inconsistent with statute; staff will report to the commission on statutory constraints.