Whew! Ran to mail my taxes to the IRS, so now I have a few minutes to catch up on a much more urgent civic duty - the massage regulations in WA State. COMMENTS ARE DUE BY 5PM APRIL 20TH. Please! Make your voice heard.
There are FOUR sections that I am commenting on. Here are links to my (other) website NewSchoolOfBodywork.com where you will find a copy of the full text of WAC Chapter 246-830 so you can download it for yourself.
If you would like to see what comments other citizens are making, please go to the Rules Comments page at https://fortress.wa.gov/doh/policyreview/ . The "Massage Practitioners" link (soon to be "Massage Therapists") is the 7th one down. This is also where you can post your comments (click on "Add Comment").
If you scroll down, you can copy and personalize any of my comments. It is best to make separate posts for each comment. Please read some of the great comments already posted! They are posted confidentially without your name or contact information attached.
I'm so grateful for the technology that allows us to fully participate in this government process and protect our rights to access safe massage therapy.
The only change I am asking for the breast massage section is that they amend "written AND VERBAL consent..." to the procedures. Many clients sign documents without reading them, so this is an important step in the process of professional communication.
I'm asking for significant changes regarding perineal massage being delineated in our scope of practice. Due diligence has not been performed in this arena. It was asked that perineal massage be added with substantively the same requirements as breast massage. However, this is not what has happened. Perineal massage has not been clearly incorporated into WAC 246-830 as it has for breast massage. I am advocating perineal massage have its own section, similar to breast massage so there is no question about its legitimacy. For example, there needs to be a subsection requiring gloves, similar to the intraoral section.
In regard to the draping section, there needs to be acknowledgement that the perineal area may need to be temporarily undraped for treatment with written and verbal consent.
In regard to the record keeping section (once again) there is no reference to perineal massage, as there is to breast massage. This needs to be addressed. And I am completely opposed to section 1 (j) requirements for massage for "treating a health condition". It is WAY overbearing! I am requesting it be change from “IS REQUIRED” to instead be “MAY BE INCLUDED”.
Here is a link to a powerpoint lecture that I gave in Wenatchee on the current updates and my position on them, with some ethical considerations around breast massage thrown into the mix.
Much love and gratitude for all of your support! Aubrey*
- Please go to: https://fortress.wa.gov/doh/policyreview/
- Click on "Add Comment" next to Chapter 246-830 WAC Massage Practitioners
- Please make separate comments for separate issues.
RE: Breast Massage
I am in support of the breast massage section and I am grateful that the Board has seen fit to treat this section with such diligence. However, I feel that adding in section (1)(a) to require written AND VERBAL consent is necessary. Many clients do not read intake forms and policy pages and may not have sufficient reading comprehension to understand these written forms. Written AND VERBAL consent needs to be made standard procedure to keep this valuable treatment safe for clients.
RE: Perineal Massage
I am in support of including perineal massage in the scope of practice for licensed massage therapists. However, this treatment would benefit from being delineated in a separate section, similar to the Breast Massage section, with the same requirements, such as being able to have a witness present, and being able to discontinue treatment at any time, etc.
I propose adding a separate section after the Breast Massage section with most of the same requirements. In addition, in the draping section, there needs to be acknowledgement that the perineal area may need to be temporarily undraped for treatment with written and verbal consent.
I am NOT fully in support of the recordkeeping section in that I do not find it necessary for there to be separate requirements for “massage therapy where the focus is on treating a health condition…” [section 1 (j) ]. I request changing the verbiage in this section from “IS REQUIRED” to instead be “MAY BE INCLUDED”. These additional requirements are onerous and may not apply to every massage every time. In addition, every massage could be considered to be for a “health condition” in that all massage has been defined as being therapeutic by its inclusion in the licensing through the Department of Health. Massage therapists should be allowed to make professional decisions as to what needs to be in a chart note and what does not. This will also allow therapists some latitude in discerning what might be confidential information that clients wish withheld from their charts.