An International Organization Incorporated 1958

Chairman: Infection Control Standards Committee

Barbara Kieffer, CPE, 3601 SW 29th, Suite 205-B, Topeka KS 66614

To: Blood Products Advisory Committee

Eduardo Nunes, Director of Standards and International Affairs of the American Association of Blood Banks, has informed the American Electrology Association (AEA) of the FDA's Blood Products Advisory Committee meeting to discuss the acceptability of prospective donors who have recently undergone acupuncture, electrolysis, body piercings or tattoos.

In 1958, the AEA was formed to help provide permanent hair removal practitioners with the highest standards of education and ethics. As the largest membership organization for the profession and as a result of our continued interest in promoting safe electrolysis, the AEA developed "Infection Control Standards for the Practice of Electrology" with the assistance of the Centers for Disease Control and Prevention (CDC), Cathy Backinger, MPH, FDA, the medical community and other experts in the field of infection control. These Standards were updated in 2000 with the same stringent review and are included for your reference.

The procedure of electrolysis for hair removal has been available to the public since the 1870's and throughout its history there have been no documented cases of disease spread by electrology. In electrology a fine, solid needle is inserted into the hair follicle and a current is applied, which destroys the hair follicles ability to produce hair. The depth of penetration of electrology instrumentation is limited mostly to the skin tissue layer and never below the subcutaneous tissue layer, so electrology is considered a superficially invasive procedure as compared to hospital surgical procedures. The resulting non-intact skin does require that the electrologist practice Standard Precautions. The AEA's Infection Control Standards state that critical items used during treatment are sterilized prior to use. To decrease the Electrologists risk in handling sharps, the Standards further state that the needle be pre-sterilized and disposable. These Standards are printed annually in the AEA Membership Roster and every member is kept abreast of appropriate infection control procedures and changes in the Standards. Members are also bound by our Code of Ethics to adhere to these Standards. These Standards are available to all training facilities, all licensing boards and are written in such a way as to be understood at all levels of competency. When these Standards are followed, there is no risk of contracting disease during the electrology treatment.

There are millions of electrology consumers in the U.S.A. who should not be deferred from donating blood. Please consider the above information when reviewing the reasons for deferring blood donors.

Thank you for your consideration.

Barbara Kieffer, CPE,

Infection Control Standards Committee

Attachment: Infection Control Standards for the Practice of Electrology