Regulators choose their words deliberately, and Maryland chose a strong one.
In October 2002 the Maryland Board of Physicians issued Declaratory Ruling 00-1, stating that the use of lasers for hair removal is a surgical act. Only physicians, certified nurse practitioners, registered nurses under the Board of Nursing’s own declaratory ruling, and physician assistants may use lasers for hair removal.
Why the word matters
Calling something a surgical act is not decoration. It sets the ceiling on who may perform it, and it frames every delegation question that follows. A task characterised as surgical does not become delegable to a broader group because the device got easier to operate or the training course got shorter.
It also removes an argument operators make in other states — that laser hair removal is closer to a cosmetic service than a medical procedure. In Maryland that argument was answered more than twenty years ago.
Who may perform it
| Licence | May use lasers for hair removal |
|---|---|
| Physician | Yes |
| Certified nurse practitioner | Yes |
| Registered nurse | Yes, under the Board of Nursing’s declaratory ruling |
| Physician assistant | Yes |
| Unlicensed staff | No |
That list is shorter than the equivalent list in several neighbouring states, and it is the practical constraint on hiring in a Maryland clinic.
Delegation to unlicensed personnel still exists — elsewhere on the menu
COMAR 10.32.09 governs delegation to unlicensed personnel in Maryland, with physician responsibility and documented training. It is a real mechanism. It simply does not extend to acts the Board has characterised as surgical.
So the analysis is per service: establish which items on your menu are surgical acts, which are delegable under COMAR 10.32.09, and staff each accordingly. A single blanket delegation document covering the whole treatment list is the thing to avoid.
Three regulators, kept straight
- The Board of Physicians defines which procedures are medical.
- The Board of Nursing governs the scope of practice for nurses, and its declaratory ruling is what puts RNs on the laser list.
- Facility licensing is handled separately again.
Related reading
Frequently asked questions
Can unlicensed staff perform laser hair removal in Maryland?
No. The Board of Physicians characterised it as a surgical act, and the permitted performers are physicians, certified nurse practitioners, registered nurses under the Board of Nursing’s ruling, and physician assistants.
Can a registered nurse use a laser in Maryland?
Yes, under the Board of Nursing’s declaratory ruling.
What governs delegation to unlicensed staff?
COMAR 10.32.09, with physician responsibility and documented training — for acts that are delegable, which does not include surgical acts.
When was the ruling issued?
Declaratory Ruling 00-1, in October 2002.
General information about Maryland scope of practice, not legal advice. Board rulings and regulations change. Confirm your obligations with healthcare counsel licensed in Maryland.