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Regulatory Activity Report for Nov. 2025 – Jan. 2026
By Denise Logsdon
After being caught by surprise by the Louisville Metro Council with the proposal of an
ordinance to replace the 2007 Massage Establishment Ordinance that exempted LMTs,
the local LMTs and their clients were unable to prevent the passage of this burdensome
ordinance.
While 3 weird amendments were made by the council, there are still multiple problems
with this ordinance for legitimate massage therapy providers. Prohibition against
locking the front door and having a lock on inside doors raise major safety issues for
groups not employing enough people to always have someone at the entrance. It is
interesting to note that (E)(1) does say that this section on locking access “shall not
apply to a massage facility if the massage facility is a business entity owned or operated
by one individual with no employees or independent contractors present at the time of
the massage services.” Also that in subsection 115.193, the final clause says that a
business with 1 individual and no employees/independent contractors does not have to
post the “Required Slavery and Human Trafficking Notices.”
At this point the problems of vagueness (how many licenses required if several
independent practitioners rent a suite together? 1, or 1 for each?), inspections, the
registry of clients fully identified with their services and prices paid, the annual license
fee of $200 plus fingerprinting and the cost of the inspections, the title implying that
LMT’s are the problem in human trafficking, and several vague sections.
On January 16, myself, James Specker (AMTA National GR Director), and Sarah Wood
(Babbage Cofounder lobbyist) met with Connie Mendal, Chief Health Strategist for
Louisville Metro Dept of Health and Wellness to get some clarifications. Ms. Mendal
noted that the health department will be doing the inspections. By Jan 30, she expects
the Health Dept website to have a page with information on this ordinance and the
application for massage business licenses. There will be a 60-day window to apply,
after which the business will be subject to late fees, penalties and closure if operating
without the license. https://louisvilleky.gov/government/health-wellness
Ms. Mendal did clarify that if all the therapists at a location are working under one
business name, only the business is required to have a facility license, not each
therapist. But if they are operating separately (each individual LMT is paid by the client,
not the business and the LMT’s simply rent the space together) then each LMT needs to
have their own facility license. If an LMT is not incorporated or holding any registered
LLC designation, and are working individually, not presenting themselves as a
“business” then they do not need the license (ie those of us who work with no signage
or advertisement).
Health inspections are unscheduled. If there are multiple licensed businesses at one
location, they will likely inspect them during the same visit. They will wait if a session is
in progress until the client is dressed and off the table. They will initially target
inspections at businesses which have had a complaint, and those without an LMT will
be closed and reported to KBLMT. Our state licenses must be posted “in a conspicuous
place within the facility.”
She insists that Patron Registries (or logs) are a huge deterrent in illicit massage
businesses. The Health Dept inspector will simply ask if the business has and maintains
a patient registry, and will not ask to see it unless something is amiss. The registry must
list the client 1 st and last name, therapist 1 st and last name, date of service and type o
service provided. In states with massage establishments regulated by the state, the
businesses can generate this from their online massage booking service. Natalie
Johnson, city attorney for the metro council said that the registry must include clients
back to the “inception” of the business. I pointed out that our state law only requires us
to keep client records for 5 years, so many of us have purged records of clients who
have not had a service in the past 5 years. She did not have a reply. Those of us not
using a computer booking/bookkeeping system are will need to put the registry together
prior to being inspected.
There were enough organized protests to have 3 changes made to the original proposal
when it was passed in November:
--p. 3, Definitions: Struck “buttocks” and “breasts” from the definition of Sexual and
Genital Parts. This now reads: “Includes the genitals, pubic area, anus, perineum, or
vulva of any person.”
--p. 11, Section 115.183: struck the restriction on the number of security cameras to
only 2 and requiring 1 to face the main entrance. Added after Each massage facility is
“required to have video surveillance at all exterior entrances/exits, and are prohibited
from having interior cameras.”
--p. 13, Section 115.184 (E): Added the underlined phrase: Any contact with a patron’s
sexual or genital areas is strictly prohibited unless under direct orders of a licensed
medical professional. **Please note that it is strictly forbidden by our state licensing
law and regulations, with or without a medical referral or instruction, to massage the
genitals and other parts defined as sexual in the definition of this ordinance. Our
regulations also require specific training and written permission from the client to do
breast massage (as in post-surgical situations). Both the assistant city attorney and Ms.
Mendal agreed that this underlined amendment should be removed immediately.
Otherwise, the council and taskforce that worked on this misguided ordinance plan to
not accept any amendments until the ordinance has been operating “6-12 months.”
AMTA-KY chapter’s lobbyist and is firm did work hard in November to talk to all council
members and try to delay this bill until it was more fully vetted by the local massage
community. This was unsuccessful, and Mr. Babbage communicated with me in Dec.
that he was stunned by the “tangents” all council members were capable of taking when
discussing the ordinance. He is continuing to work with me, at this point working on
arranging a meeting with city administration outside of the council. Hopefully soon we
will have a general meeting with representatives of the mayor’s office, ABC officials, the
state Human Trafficking Task Force, and the 3 “organizers” of the Alliance of Licensed
Massage Therapists of Greater Louisville (now 71 members). I am one of the
organizers, and do not purport to represent AMTA in these meetings but do make it
clear that I will relay info to AMTA and ask for resources as so many AMTA members
are in the Metro area.
The other thing to note: The KY Legislature is now in session. Bob Babbage sent Ann
Boone and I a bill to read that intends to amend our licensing law on the state level, and
this bill is supported by the state league of cities. It gives cities and local governments
authority to regulate the businesses of licensed massage therapists. It also raises the
level of violation for working without a license to a Class A misdemeanor, adding that
“Each session shall constitute a separate offense.” Our members need to be vigilant
about their renewals. This would be much more problematic if a local inspector notes
an expired license.
Bob has noted that cities in northern KY have problems with illicit “massage”
establishments, and we have already seen this pop up in Bowling Green as well as
Louisville. It’s clear that we are probably not going to successfully get “massage” taken
out of local anti-trafficking and prostitution ordinances without some kind of major pro-
active long-term campaigning.
In the meantime, the Alliance (including AMTA members) and Bob will continue to chip
away at this ordinance for clarity and the protection of our practitioners and clients.
Denise Logsdon, MS, LMT
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