Letter to the Board of Massage on WAC 246-830

To: MassageRulesComments@doh.wa.gov and Megan.Brown@doh.wa.gov
Re: WAC 246-830-XXX Breast Massage proposed regulations

I am writing to voice my opposition to the current proposed draft breast massage regulations, and offer suggestions of desperately needed changes.
* It is the Board's job to protect public health and regulate massage therapy. Requiring a prescription for breast massage regulates the public, without increasing health or safety.
As a client, I find it belittling to require me to ask permission of a doctor to allow another licensed medical professional to treat my breasts. Additionally, this prescription requirement will delay treatment and create unnecessary medical visits, as well as increase health care costs.

* The Board is NOT regulating massage therapy, or protecting the public, when it allows therapists with no additional training to perform breast massage, as currently proposed.
1% of primary massage schools in Washington State provide breast massage training. Please require practitioners to keep documentation of their advanced training in this specialty if they choose to provide this service. Please also consider 16 hours the minimum training needed, similar to the intraoral endorsement requirements. This will make it easier to investigate inappropriate touch complaints.

* It is an excellent idea to require that written consent be obtained prior to breast massage.
But instead of requiring massage therapists to provide a a witness during treatment, require that the client be told that they may discontinue the treatment at any time for any reason. This reinforces the client's autonomy in a potentially vulnerable situation. This will also make it easier to investigate inappropriate touch complaints.

* The Breast Massage section should be moved from the "disciplinary" section of the code to the "massage business" section.
Breast massage is a legitimate, therapeutic massage procedure and should not be considered only as a "disciplinary" measure, which suggests it is something wrong or bad.

Please find below a suggested rendition of WAC 246-830 regarding breast massage. You will find it more clear and succinct than the current draft code. Thank you for your attention and your service to protect the public health.

WAC 246-830-XXX Breast Massage
(1) Prior to performing breast massage, a licensed massage practitioner must:

(a) Acquire prior signed written consent before proceeding with the breast massage. The written consent must:
(i) Be maintained with the client’s records,
(ii) Include a statement that the client may discontinue the treatment at any time for any reason,
(iii) If the client is under 18 years of age, prior written consent will be obtained in accordance with the Revised Code of Washington and the Mature Minor Rule;

(b) Use appropriate draping techniques as identified in WAC 246-830-xxx (draping section);
(c) Document in the client’s record a therapeutic rationale for the breast massage.
(2) In addition to the requirements identified in subsection 1, to perform any massage to the breast or nipple, a licensed massage practitioner shall maintain evidence of the completion of at least 16 specialized contact hours as training beyond the minimum competencies, which includes but is not limited to, breast anatomy and physiology, pathology, indications, contraindications, therapeutic treatment techniques, draping, appropriate practitioner-client boundaries, expected outcomes, and client safety related to breast massage.