business covid-19 public-health
Interpreting the meaning of &quot;additonal considerations&quot; in Covid-19 reopening guidelines for cosmetology business
<p>My wife and I are trying to interpret the document</p>
<blockquote>
<p>Reopening Protocol for Personal Care Establishments:
Appendix R Effective as of June 19, 2020t the document from LA County
Department of Public Health,</p>
</blockquote>
<p>The confusion is in a section titled:  &quot;ADDITIONAL CONSIDERATIONS FOR NAIL SALONS&quot;
The confusion is wether the word considerations implies &quot;optional&quot;.</p>
<p>Also, the first line in &quot;Addtional Considerations&quot; list:</p>
<blockquote>
<ul>
<li>A plastic partition between worker and client with ample space cut out where hands or feet can be slid
underneath to conduct the manicure or pedicure has been provided, when feasible.</li>
</ul>
</blockquote>
<p>Does that mean we determine what is feasible, or does the Dept. or Health?</p>
<p>This is a bit confusiong for someone with limited English.</p>

<blockquote>
<p>in a section titled: &quot;ADDITIONAL CONSIDERATIONS FOR NAIL SALONS&quot; The confusion is wether the word considerations implies &quot;optional&quot;.</p>
</blockquote>
<p>No. <em>Additional</em> does not mean <em>optional</em>. In fact, page 1 of <a href="http://publichealth.lacounty.gov/media/Coronavirus/docs/protocols/Reopening_PersonalCare.pdf" rel="nofollow noreferrer">Appendix R</a> states in bold: &quot;<em>All businesses covered by this protocol must implement <strong>all applicable</strong> measures listed below</em>&quot; (emphasis added).</p>
<p>Listing measures specific for nail salons in a separate section is a straight-forward way to indicate that businesses which are not --or do not involve-- nail salons don't need to be concerned about implementing those measures.</p>
<blockquote>
<p>Does that mean we determine what is feasible, or does the Dept. or Health?</p>
</blockquote>
<p>You determine what is feasible, but at all times you need to &quot;<em>be prepared to explain why any measure that is not implemented is not applicable to the business</em>&quot;. See continuation of the aforementioned statement.</p>
<p>Thus, if you determine that providing the &quot;plastic partition [etc.]&quot; is impractical or not functional, your assessment needs to be persuasive for an inspector to rule out a finding of non-compliance.</p>
