Reviewed by Evan Lewis, PhD. Last updated August 2026.
A nail tech can look at a nail, describe what she sees, decline the service and refer the client out. She cannot diagnose toenail fungus, work on it, or promise results. What she can do is hand the client a cosmetic take-home routine that sits inside a cosmetology licence and earns her money.
Why does this keep happening to you?
Because discoloured toenails are common, and your licence has a line you are not allowed to cross. You take the polish off, and there it is. Thick at the free edge, yellow through the plate, maybe lifting away from the bed. She has been coming to you for three years and she is looking at your face for a reaction.
This is not a rare event. It is a recurring one, and for most techs it has no good ending. You either work around it and feel uneasy, or you say no and lose the appointment, the rebook and sometimes the client.
What do the state boards actually say?
They do not all say the same thing, and that is the first thing worth knowing. Three of the largest states word the same moment three different ways.
| State | How the rule is written | What it means in the chair |
|---|---|---|
| Georgia | A flat positive requirement: “All cosmetology services shall only be performed on intact, healthy scalp, skin, and nails.” | The nail has to be healthy before you touch it. There is no judgement call built into the sentence. |
| Texas | A prohibition triggered by your own belief. A practitioner may not perform services if she has reason to believe the client has a contagious condition, or “inflamed, infected, broken, raised or swollen skin or nail tissue”, or an open wound in the area to be serviced (16 TAC §83.102(b)). | It turns on what you reasonably think, not on a diagnosis. You are never asked to be right about the cause. |
| California | Written around risk to you. Under 16 CCR §984, no establishment may require or permit a licensee to work on a client with an infection capable of being transmitted to the licensee, and services on inflamed or broken skin need appropriate precautions or gloves. | The framing is occupational safety rather than client suitability, so the conversation you have is a different one. |
Federal guidance points the same way without naming a state. OSHA tells salon workers to “wear gloves, and avoid clients with cuts, open wounds/sores, blisters, or visibly infected skin on their hands, feet, or nails”, and to clean and disinfect tools after each client “per the policies put forward by your state’s cosmetology board”.
Which is the honest headline here. There is no single US rule. Anyone who tells you there is has not read three of them. Look up your own board before you build a policy on any of the above.
And if you work in Canada?
Same moment in the chair, different machinery behind it. A Canadian tech reading a US state board rule is reading someone else’s law, so it is worth setting out how the two systems actually differ.
There is no national licence, and licensing is provincial. The Government of Canada’s own Job Bank says it plainly: “The steps to get a license or certification are different in each province or territory. You will need to contact the regulatory authority where you want to work to learn what to do.” It lists Esthetician (Nail Technician) as a regulated trade in Manitoba (Apprenticeship Manitoba) and Saskatchewan (Saskatchewan Apprenticeship and Trade Certification Commission), Cosmetologist as regulated in New Brunswick (Cosmetology Association of New Brunswick), and the occupation as non-regulated in Nova Scotia, where the Cosmetology Association of Nova Scotia is still the body to ask.
If your province is not in that list, that is not the same as “no rules”. It means the answer sits with your own provincial or territorial authority rather than with a list on a website. The same page also notes that a business licence is required for owner-operators, and that practitioners offering these personal services “are required to adhere to infection control procedures”.
The thing that actually governs your chair day to day is public health, not a beauty board. That is the real structural difference, and it catches people out. In Ontario a salon is a “personal service setting” under the Health Protection and Promotion Act, and it is inspected by the local public health unit. Public Health Ontario’s guide for those settings is the closest Canadian relative of the Georgia sentence, and it is more explicit than any of the American rules above, because it names the nail:
Read the last clause again, because it is this whole article in one sentence: defer, and advise her to seek treatment. The referral is not a courtesy you are adding on top of the rule. In Ontario the guidance builds it in.
Two honest caveats, and they matter. That document is Ontario, and it says of itself that it is a reference document that does not supersede the regulation. Every province and territory runs its own public health rules and its own inspections. So take it as the shape of the thing, then check your own province and your own local public health unit before you write a salon policy on the back of it.
What belongs on a nail salon sanitation checklist?
Your own board writes it, and the checklist that matters is the one your inspector reads. Nail salon sanitation requirements are set state by state in the United States and by public health units in Canada, so a generic list copied off social media is not a defence. The four items below are the ones that come straight from the sources already cited above.
- Clean and disinfect every tool after every client. OSHA says exactly that, then hands the detail back to your state board.
- Bin anything porous that touched an unhealthy nail. Texas requires a buffer block or porous nail file exposed to broken or unhealthy skin or nails to be discarded immediately after use.
- Gloves on, and skip broken skin. OSHA tells salon workers to wear gloves and avoid clients with cuts, open wounds, blisters or visibly infected skin on hands, feet or nails.
- Defer the service, then refer. That is the Ontario wording, and it is the most explicit written instruction for this moment anywhere in the sources here.
Salon sanitation rules also cover the parts nobody photographs. Foot spa jets, drain screens, implement storage and whatever cleaning record your state or your public health unit asks you to keep. Those are state and province specific, and they are usually the first thing an inspector asks for, so build your checklist off your own board’s sheet rather than off anyone else’s.
Can a nail tech diagnose nail fungus?
No, and it is worth being precise about why that is good news rather than a limitation.
Discoloured, thickened toenails have a long list of possible causes. Trauma from a running shoe, psoriasis, a bruise under the plate, staining from dark polish, and yes, a fungal infection. They can look nearly identical across a pedicure bowl.
A cosmetology licence is a licence to beautify. Naming a cause is a clinical act, and it belongs to someone with a clinical licence. The moment you say “that’s fungus”, you have made a diagnosis on someone else’s authority and you own whatever follows.
What can you legally say to the client?
Describe. Do not name.
- “This nail has changed since I last saw it.” True, observed, yours to say.
- “My licence only lets me work on healthy nails.” The rule takes the decision off you personally.
- “Someone who works on feet should look at it.” A profession, not a condition.
Notice what is missing. No cause, no name, no promise, no reassurance you cannot back. Three sentences and the whole thing is inside your scope. If she pushes back on being turned away, what a tech is allowed to refuse and how to word it works through the same thirty seconds from the refusal side.
Why the no-claims rule is the thing we have in common
Here is the part that surprises most techs. Your regulatory position and ours are the same shape.
You cannot make health claims. Neither can we. IodinePure is a cosmetic, listed with Health Canada as a cosmetic, and it carries no drug claims of any kind. It is two ingredients in water and it is sold for the look of the nail.
That means a tech recommending it is not stepping outside her licence, because there is no claim attached to step outside of. Almost every other thing she could mention in that moment is a registered drug, and repeating a drug’s claims is exactly the sentence a board notices.
The model that works: refer, and support
Refer-and-support is two moves, not one, and the second is the one everybody drops.
Refer. Send her to a podiatrist, a chiropodist or a foot care nurse. That is where a cause gets established and where debridement, thinning and any prescription decision belongs. None of that is your work and none of it should be.
Support. Give her something to do at home in the meantime, which is a cosmetic routine and nothing more. She leaves with a plan instead of an apology, and she has a reason to come back to you.
Around 200 foot care clinics across North America already run this way, with the professional handling the nail and the client running a routine between visits. The salon version is the same shape with a different professional at the front of it.
What does the routine look like between appointments?
It is a soak and a spray she runs at home, on the timeline of nail growth rather than weeks. The reason this pairs with your work rather than competing with it is that timeline. Toenails grow slowly. A 2010 study measured toenail growth at 1.62mm per month, which puts a full big-toenail replacement somewhere around nine to twelve months.
Nothing changes the appearance of nail that has already grown. What changes is what comes in behind it, and that is measured in appointments, not weeks.
Our EZ Clear Nails kit is built around a soak tray rather than a brush, because submerging the toe carries the solution under the free edge and around the nail folds, which is where a paint-on film sits on top of. It is designed to run alongside professional care, not instead of it.
It also gives you a natural checkpoint. Photograph the nail at the visit she starts, then again at four to six weeks and at twelve. The base of the nail is the only place where progress is visible, so that is where you both look.
What is this not?
It is not a way to keep working on a nail you should not be working on. If your board or your public health unit says intact and healthy, the routine does not change that answer, and starting it does not make the nail workable today.
It is not a substitute for the referral. The reason to refer is that you do not know what you are looking at, and a bottle does not solve that.
And it is not fast. If a client wants her toes to look different for a wedding in three weeks, the honest answer is polish and a different conversation. Anyone selling you speed in this category is selling you something.
Common questions
Can a nail tech work on a client with toenail fungus?
It depends where you work, and the wording differs meaningfully. Georgia requires services to be performed only on intact, healthy nails. Texas prohibits service where the practitioner has reason to believe there is inflamed, infected, broken, raised or swollen skin or nail tissue. California frames the same situation around transmission risk to the licensee. In Ontario, Public Health Ontario guidance says service is to be deferred where there are visible skin infections including nail fungus, and the client is to be advised to seek medical treatment. Check your own board, or your own province and local public health unit, rather than assuming somewhere else’s rule applies.
Is this a US-only issue, or does it apply in Canada too?
It applies in both, but through different systems. In the United States it is a state cosmetology board rule. In Canada there is no national licence, licensing is provincial or territorial, and the day-to-day rule about whose nail you may work on comes from public health rather than a beauty board. The practical answer in the chair ends up the same: describe, decline, refer, and hand her a routine.
Can a nail technician diagnose nail fungus?
No. A cosmetology licence does not include diagnosis, and thickened or discoloured nails have several possible causes that look alike, including trauma, psoriasis, bruising and staining. Describing what you see is inside your scope. Naming the cause is not.
What should I say to a client instead of naming it?
Three sentences cover it. That this nail has changed since you last saw it, that your licence only lets you work on healthy nails, and that someone who works on feet should take a look. You have described, explained and referred without making a single claim.
Can I recommend a product to a client?
You can recommend a cosmetic product, because a cosmetic carries no health claims for you to repeat. What creates the problem is repeating a drug’s claims or promising an outcome. Keep the language to a routine your clients use at home and you have stayed inside your scope.
Is the partner side open to Canadian nail techs?
Yes. It runs the same way in Canada and the United States, with the same commission split on the same products and the same free kit so you have used it yourself before you ever mention it to a client. There is no stock to buy in either country.
Are salon tools really a transmission route?
Shared nail equipment is documented as one. A 2022 scoping review of household transmission found evidence of spread in 44% to 47% of households with an affected member and identified shared nail equipment among the routes. Texas rules also require a buffer block or porous nail file exposed to broken or unhealthy skin or nails to be discarded immediately after use.
Should I use a credo blade on a callus?
In Texas, razor-type callus shavers designed to cut growths of skin such as corns and calluses are on the list of substances and products a practitioner may not use. Several other states restrict them too. Check your board, because this one carries real enforcement risk.
Does nail tech continuing education cover toenail fungus?
Continuing education is set by your own state board rather than by any national body, so both the hours and the subjects differ from state to state, and in Canada the requirement sits with your provincial or territorial authority. No course changes what a cosmetology licence covers, so none of it adds diagnosis. The learning that pays off in this moment is sanitation and infection control plus a script you can say out loud: describe, decline, refer.
How long before the client sees anything?
Longer than she expects, and telling her that up front is what keeps her going. Toenails grow at about 1.62mm a month, so new growth at the base is the first thing to appear and a big toenail takes roughly nine to twelve months to replace itself entirely.
The bottom line
The nail you have to turn away is currently worth nothing to you. It is a lost appointment, an awkward thirty seconds and often a client who quietly stops booking.
Describe, refer, and hand her something. That version of the same moment ends with her holding a plan, a referral in her phone and a rebook in your diary.
If you want the display card and the partner side of this, the professional partner page covers how it works. It is open to techs in Canada and the United States on the same terms, the same commission split and the same free kit to start with. There is no stock to buy and nothing to keep on a shelf, which is the whole point of earning retail commission without holding inventory.
Two related reads: how a changed nail gets told apart from injury, psoriasis and bruising, and what actually cleans a nail tool and what only looks like it does.
Evan Lewis, PhD, specializes in natural and nutritional therapies for the prevention and management of chronic diseases and their complications. His research spans chronic disease, diabetes complications, clinical nutrition, and nerve health, including the development of topical iodine therapy for foot care and wound health. IodinePure products are listed with Health Canada as cosmetics. This article is general information for licensed professionals, not legal advice, and requirements change and differ by state, province and territory.
Sources: Ga. Comp. R. & Regs. R. 240-4-.02. Texas Administrative Code Title 16, Part 4, Chapter 83, §§83.102, 83.106 and 83.112. Cal. Code Regs. Tit. 16, §984. OSHA, Health Hazards in Nail Salons: Biological Hazards. Government of Canada, Job Bank, job requirements for Nail Care Technician, NOC 63211. Public Health Ontario, Guide to Infection Prevention and Control in Personal Service Settings, 3rd edition, first revision July 2019. Yaemsiri S, Hou N, Slining MM, He K. Growth rate of human fingernails and toenails in healthy American young adults. J Eur Acad Dermatol Venereol. 2010. Jazdarehee A, et al. Transmission of Onychomycosis and Dermatophytosis between Household Members: A Scoping Review. J Fungi (Basel). 2022;8(1):60.
