Laser Hair Removal: America's Most Dangerous Unproven Technology© & Risks, Dangers, and Side Effects of Laser Hair Removal & Understanding Laser Hair Removal Danger
15 November, 2004 by Kimberly in Five Star Electrologist©
Five Star Electrologist©

A Scientific Thesis on temporary laser hair removal, as compared to Electrolysis, the only proven medical technology that can legally claim PERMANENT HAIR REMOVAL and which is approved by the Five Star Electrologist's Guild™

©1998 by Kimberly Williams, R.E., Dean
President and Founder of the Five Star Electrologist's Guild™


Dear Governor Napolitano,

My name is Kimberly Williams, R.E. I have been a Massachusetts licensed and registered electrologist since 1979. I have twenty-four years of professional experience, and have dedicated my life to my chosen profession. I would like to make you aware of the dangers of temporary laser hair removal, a business experiencing explosive growth here, largely through a complete lack of regulation or oversight. It is also important, however, to provide full information regarding the Electrolysis profession - the safe alternative. This educational report is quite extensive but I believe the public should be well informed; every consumer or patient has the right to complete information, especially regarding procedures that have a lasting effect on their personal appearance and consequently, their self esteem. Everybody wants a healthy complexion, but there are many discrepancies in the quality of the treatments available from Electrologists and Laser Parlors in Arizona. The state where I was educated and began my practice, Massachusetts, has the most stringent requirements in the United States for licensing Electrologists, so I have a unique perspective on this situation.

This report is based on hard science, and much of the information is, to my knowledge, being published for the layman for the first time. It is written in a way that any intelligent person can understand, because it is vital that they do. Each scientific term is cross-referenced and defined. I am providing this report to not only to consumers but to every cabinet post in the Government - State and Federal - as well as the Arizona Better Business Bureau and the FDA.


History of my profession

The history of Electrology would surprise most people. My profession was founded in 1886 for the purpose of relieving "Trichiasis" (inflamed infected ingrown hairs of the eyelid). This condition left untreated can result in blindness. In 1952 the profession was among the first to use sophisticated solid-state equipment. The Commonwealth of Massachusetts formed a state board and began requiring licensing and registration for Electrologists in 1959, and in time there were similar state boards in 32 states (although Arizona still lacks one). In 1985 Computerized Programmable Epilators became available, and in 1996 the FDA upgraded electrolysis equipment to the status of a class one medical device. Electrologists alone have been granted the right by the FDA to legally claim Permanent Hair Removal. Our field is fully professional, a medical discipline in fact, and the reason for the virulent opposition to a state board here is the fact that many in the business would be out of work after failing the sort of examinations real electrologists must pass to be licensed. These hold-outs would prefer training they can breeze through, usually in weeks instead of years, ultimately at the expense of their patients. The Electrolysis-Electrology profession has, since its inception, undergone extremely close scrutiny by FDA, AMA, Underwriters Laboratories and every State Board of Electrologists. Our equipment is F.D.A. approved, tested by Underwriters Laboratories and U.P.E.M.A. (United Professional Epilators Manufacturers Association). That's why Electrologists have the sole right to advertise "Permanent Hair Removal".

I work closely with physicians regarding endocrinology, electrolysis, and micro eye-surgery for Trichiasis. I also work with epileptic patients who use medications such Dilantin, a drug which causes extreme hair problems in women and men. I try to see if it is possible to work with the Neurologist, possibly changing the medications to an alternate drug that does not create the hair problem, making the treatments shorter for the patient.

Why does Arizona need a State Board of Electrologists?

I am not your typical Electrologist in Arizona, a state with no requirements to become one, no professional training, license or registration requirements. Arizona is so lax you can take a weekend course and become a "Certified Electrologist", "Certified Expert Electrologist", "Certified Technical Electrologist"; you can make up any title you want. Arizona desperately needs a State Board to protect the consumer from charlatans, quacks and laser operators with dangerously insufficient training. Here are some reports that demonstrate why.

These practitioners advertise right along with the very few State Licensed and Registered Electrologists and mimic our advertising. The consumer has no way to know if they are qualified. These unlicensed operators have harassed and bad mouthed the few Registered Electrologists who have made the effort to become licensed. They make unqualified, unsubstantiated claims. Their equipment, much of the time, is not FDA approved or up to date; they think that the purchase of their first epilator is lifetime investment. Their use of bloated titles and manufactured credentials give the consumer a false sense of trust in them. (Without a state board to regulate certification and maintain standards, the word "certification" doesn't mean much.) Many patients have already had tragic experiences with laser hair removal, for example. They've been badly scarred,, and this is not the most severe injury caused by this laser technique as practiced by our "Certified" Electrologists. Much worse are disfiguring burns.. One has to wonder how many we won't see - those having signed non-disclosure agreements as part of an insurance settlement. Many such claims have been paid; it happens quite often. The payments soothe the victim's pain only to a certain point. Many will have their disfigurations for years, or even the rest of their lives. Is this worth it? This irrevocably harms the patient's appearance, well being and self-esteem. This gives the few of us who are truly dedicated and competent State Licensed and Registered Electrologists a bad image that is difficult at times to overcome.

A State Board of Electrologists, with licensing and registration, is needed to assure professional standards and safety. I've always felt that Arizona is a progressive state, but not in this. We have absolutely no Legislation or standards enforcement of the Electrolysis-Electrology profession, or the as yet unproven Laser Industry. There are licensing and registration requirements for every other profession in Arizona, so I must ask: Who Forgot The Electrologists? Electrolysis is a professional medical occupation in which no mistakes can be made with out leaving a scar or pit or physical deformity. Most of the "Certified" Electrologists are using the Laser supposedly under the guidance of physicians, but by law, the doctor does not have to be present, just "on call". They advertise membership in Electrologists Associations that have no real requirements to join and who grant them their exagerated titles and certifications, which look impressive in their frames, but are worth very little. Their training lasts a month or less. Certification courses for Electrolysis should be banned outright for the simple reason that they don't teach the skill level necessary to become a competent Electrologist.

Laser treatments are painful not only because of the inherent nature of the process, but also the operator's lack of training. Many of them are not trained at all. A State Licensed and Registered Electrologist, on the other hand, can provide a very comfortable treatment. There is nothing inherently painful in genuine electrology. Before looking for a qualified Electrologist, read my Five Star Rating System(c), and ask yourself if you would go to a Physician who did not finish or even attend medical school, or pass the Medical State Boards.

Laser parlors should not be allowed to imply that they can remove hair permanently; the FDA has denied them permission to do so. They make unsubstantiated claims of permanent hair removal to the uninformed public. Professional schooling for Electrologists that results in licensing and registration is available on states near Arizona such as California, Utah, New Mexico and Oregon. Why does Arizona not have a State Board of Electrologists to protect its citizens?

How it would work

Upon the formation of a state board, "grandfathering" in of certified or non-registered Electrologists would be most unwise, resulting in a confused mess of differing standards, and in no change to the lack of professional competency for the most part. Now, I am really going to be forward! I would like to offer my professional services to set up an Arizona State Board of Registration of Electrologists that would require already certified individuals to take a "State Sponsored requisite course in Electrolysis", to achieve basic professional standards, competency, and most important, ethics.

This could done without causing undue hardship to the lay electrologist who could attend a one-day a week seminar for three hundred hours of professional training. Certified electrologists ought to have the opportunity to be true professionals and become licensed and registered electrologists. Newcomers would be required to attend a private professionally accredited school with more training. Without a doubt I could train all the lay electrologists myself. Our profession in Arizona needs help and professional guidance.

The Arizona Electrology Association, to the best my knowledge, does not have a single licensed and registered member and has not sought State Licensing and Registration since its inception. In fact, there was a referendum 1989 to have a State Board but the members voted it down.

Because I am licensed and registered I have not been asked to join this organization. In fact it is to my advantage if Arizona requires no license or registration; it gives me a distinct advantage over everyone else. But I am truly dedicated to my chosen profession- it is my dream for this profession to be established in Arizona; it would be my way of saying I am proud of what I do and to make a contribution to the profession. By licensing and registering Electrologists we can increase the quality of work, safety for the patient, and establish a standard of professionalism. It would require a small sacrifice of time and money but in the long run it would it good investment for the future. It would provide the citizen a safe and better choice of professional services, and if correctly managed A State Board of Electrologists could even become self-sufficient.

This is why the Electrolysis and Electrology professions and its practitioners should be licensed and registered as medical specialists; there is no room for error in our profession without serious consequences for the consumer. I rest my case on that issue.

Just some of the dangers

I have a reputation for being blunt, so I will go straight to the point. From the perspective of almost a quarter century of professional experience I can tell you that the lasers that are presently used, and touted as a superior technique, are a danger to the public.

Let's deal strictly with the facts: Most lasers on the market today are built inexpensively and sold at a high profit with no set amount of training or credentials required to operate them. Lasers are dangerous. You can purchase a laser pointer for under $40 with a warning on the label clearly stating not to point it in someone's eye at the risk of causing blindness. The much more powerful Medical Lasers used for temporary hair removal are being used by people with minimal training! These "Certified Electrologists" tell you that Electrolysis is painful to convince you to submit to laser treatments, which they say are not. But when I do a consultation and case history on each new patient it seems that a majority have suffered some painful skin damage from laser treatments, from moderate to severe. They tell me they were intentionally deceived, told that it was painless and removed hair permanently, when the FDA has ruled that it is illegal to advertise the Laser as painless and permanent. Additionally, they advertise in the Yellow Pages under Electrolysis, yet they are not electrologists. Electrolysis is a specific technique, which they do not in fact practice. Isn't this deceptive advertising?

Laser hair removal is, unfortunately, common enough that if laser parlors advertised under that heading, their customers would find them. Instead, they plant their ads right next to those of real electrologists. I doubt the State would remain uninvolved if accupuncturists or faith healers buried their ads among those of surgeons, or for that matter, pet sitters advertised under "day care centers". This situation is precisely the same.
Many ads are sensationalistic, with perfect air-brushed models. I realize that sex sells. But I realize too that this has little connection with professionalism, skill and credentials.

The medical profession has been trying to make incursions into our field for years, with new, easier techniques, none of which has been successful. From the thirties to the fifties they used X-Rays for hair removal. It worked; radiation therapy makes your hair fall out, but the AMA banned it after the cancer rate jumped. There were pills with nasty side effects. Every ten to fifteen years the Electrolysis-Electrology profession is besieged by some new wonder treatment. Now we have the latest interloper in our profession, the laser.

The tide is turning, for thirty-eight states now require Licensing and Registration to practice Electrolysis-Electrology. We have always accepted and welcomed those who are willing to make the grade and the effort to seek a professional education and proper State Licensing and Registration. Most "certified" laser practitioners would fail the requirements. If there was one single unbiased, independent, scientific double-blind study with corroborating data that laser did not harm the tissue, did not permanently discolor or prematurely age the skin in the treated area, and permanently removed hair, I would use it. I would have purchased the first Laser for hair removal based on proven scientific data without hesitation. There is none. So I will not sacrifice my ethics for money.

There are no secondary independent studies (such as Underwriters Laboratories) as to the true effectiveness of laser equipment that I am aware of. Here is how they work: They use a broad beam laser, where the smallest beam is the diameter of a dime. The orifice or entrance to the hair follicle, in contrast, is maybe two to five thousands of an inch in diameter. The depth of follicle is anywhere from 1/8 or 1/16 inch to an inch deep. An evaluation to see if the follicle is distorted or curved, ingrown, inflamed or infected is mandatory. I would like to know how this evaluation is done by laser practioners. With out proper medical protocol the consumer/patient is being put at risk physically and emotionally. The patient could run the risk of severe infection and irreparable skin damage. These people are not informed that there are some ill-trained physicians who make wild, unsubstantiated claims about the laser, or about the FDA rules and regulations. Why are there no standardized requisites for the training of laser operators that result in a license and registration? I have personally searched the web and put inquiries out for independent agencies such as Underwriters Laboratories and others. To date I have not been able to find one independent double blind study!

One strict law of physics that laser operators have not so far disproved is that laser light travels in a straight line. How can laser operators make the claim that the laser beam travels down the curved follicle hair shafts? Would they please provide the proof that they can bend light?

Patients with white or blonde hair are told the laser is an ineffective treatment. Patients with dark complexions are told they could suffer a permanent loss of pigmentation. A broad beam laser is painful. The heat generated by the laser beam will have to travel 1/16 to 1/8 of an inch to destroy the root of the follicle. In order to reach the depths needed for true (as claimed) permanent hair removal, a laser would have to burn off the first two layers of skin: the stratum corneum (granular layer) and the malphigian layer which protect the body from infection. This is why laser operators be should be required to inform the patient that they could end up with permanent skin discoloration and scarring, especially people of darker skin. In the Corium layer of the skin we also have free nerve endings, pain receptors, touch receptors and sebaceous glands (hormonally controlled glands that keep the skin soft and supple with the excretion of sebaceous oil, without which our skin would be dry and flaky). The Sebaceous gland's oil protects the skin from the elements such as sunlight and the cold. For the Laser to achieve total destruction of the root of the hair (the Papilla is the germanative part of the hair) it must sacrifice the microorganisms of the skin. This is disastrous to the functionality of your skin. It destroys the collagen fibers which control the elasticity of the skin, critical for skin tone, Mechanoreceptors (Pachianian Corpuscle) Pressure and Vibration Receptors. The Appocrine and Eccrine Sebaceous glands are deystroyed. The Suderiferous Gland, otherwise know as the sweat gland, is lost in the area treated by the Laser. Sensory and Autonomic Nerve fibers along with veins and arteries which nourish the skin, let alone provide skin sensations such as being burned or frozen, are lost in the treated area. These skin functions are lost when they are burned. Look at skin that has been burned and you will see the proof.

The germinative papilla or root of the hair usually lies at the top of the subcutaneous tissue where the couplers (blood supply) that nourish each individual hair are located. Not all follicles produce hair and they are damaged or permanently destroyed too. The smallest laser beam used for hair removal is dime sized in diameter; most are the diameter of a quarter or nickel. What happens to the skin and all its microorganisms where there is no hair? It's easy to see that to get a few hairs that are not concentrated, you must destroy a lot of surrounding tissue. This is a lack of medical common sense. Who established this unprofessional medical protocol?

I know that if properly informed, patients would be most unwilling to sacrifice their skin to rid themselves of their unwanted hair.

In one square inch of skin there are four yards of nerve fibers, 1300 nerve cells, 100 sweat glands, three million cells and three yards of blood vessels. Yet there is not one nerve fiber inside the follicle. A professionally trained Electrologist can avoid nerve fibers.

Doctors are always telling patients, "Stay out of the sun because it damages the skin." What could happen if the intense heat and ultraviolet radiation produced by a laser triggered a dormant basal or squamous skin cancer cell? Have you ever thought of how hot a laser is? Of course every one wants to have healthy beautiful skin but the safety of the laser is not proven. Should we play "Russian Roulette" with our health with a quick fix that has not proven to be permanent? Until the Laser can be proven safe and effective in a double blind study with honest test results, laser hair removal should be banned for the safety of the public. Only a physician should be allowed to use a laser for scientific research. Quite a few states have pending legislation, limiting laser use to physicians. I am in total agreement with that.

One must realize that all the body's defensive micro-organs that protect us could be compromised or be lost permanently in areas burned by a laser. Infection is the biggest risk to a severe burn victim (See my Info-Laser-Links). Certain large areas such as legs could be rendered completely dysfunctional and be permanently scarred.

I have recently been the target of a particular laser company who used the foulest obscene language in a response to this report! Then he said, "I'm just trying to show you how to make more f-----g money". All for the fact that I made an honest complaint about their illegal advertising and strong-arm tactics. These people make phony appointments and threatening phone calls to me. They're real brave, aren't they? This was a representative of Medical Doctor's office. There is nothing wrong with free enterprise except when its laws are violated and its ethics, which I cherish, are flushed down the toilet. Certified Electrologists slander me for printing the truth. If they keep it up I will just work harder. I'll publish their education and qualifications and compare them to mine, most notably the ones who took the correspondence courses in electrolysis that total no more than 100 hours.

A broad beamed, dime size diameter laser is missing its intended microscopic target, the papilla. The microscopic opening of the hair shaft and all its essential microorganisms are permanently damaged and lost. The only laser operators that do not damage your skin are the ones who turn the laser down so low that it only burns the hair off at the surface of the skin. Of course then the patient still has the hair problem; they now suffer from PLOM (permanent loss of money). That's why patients who come to me who have had this form of laser treatment still have their hair problem. Gee, I wonder why? The ones who had the intense laser treatment have some hair-free treated areas where the skin has obviously been burned. We were taught in Electrolysis school that hair will not grown on scar tissue. These patients' skin has been permanently discolored and burned and they still have most or all of their unwanted hair problems. The interior structure of the follicle has no nerve fibers inside it, so if you're having this performed by a competent, licensed and registered Electrologist who has the proper skill, you will find your treatments surprisingly comfortable.

The FDA states, "The Laser can not be advertised as painless". We know this is true because burning skin hurts. A professionally trained Electrologist does not allow this damage to happen. Yet, when I read the Yellow Pages all I can see are claims that lasers are a painless, permanent, gentle treatment and superior over electrolysis and all other forms of hair removal. Look in any Yellow Pages telephone book under Electrolysis to see what I mean. These Certified "Wonder" Electrologists advertise reasonably priced laser treatments- on one Laser Web Site one advertises how excruciatingly painful electrolysis is and never mentions how painful the laser is. Of course some people are not aware of the FDA ruling that laser operators cannot advertise laser treatments as painless. Is the laser operator unaware? She also has an electrolysis web site, in which she proclaims how comfortable electrolysis treatments are. It sounds like someone is playing on both sides of the fence to get both hands into your pockets. Gee, I wonder where all those phony phone calls come from.

The electrolysis profession has always used all FDA approved equipment, and our profession is one hundred and seventeen years old. All our equipment is scrutinized and approved by the FDA. The AMA also approves electrolysis. Have they approved the laser? The FDA is besieged by unimaginable numbers of lobbyists and aggressive marketers, or should I say racketeers, trying to get approval for it. The electrolysis machine has been classified as a class one medical device that has stood the test of time, and now we have state of the art computerized equipment. The best electrologists use computerized epilators that are not more than six years old unless they have had factory upgrades.
The gray area in which laser operators advertise warrants a full-scale investigation. They have not proven the safety of their equipment, established professional guidelines, or real schools where the course results in a License and Registration. There is no uniformity of standards in their business. I think it is most unfair that they have gotten away with operating in such a manner for so long.

I'm from Massachusetts, though I like to use the expression "I'm from Missouri". Let's see them prove their claims with valid scientific data. All their equipment should be tested by honest and reliable independent organizations such as Underwriters Laboratories. To this day not one laser manufacturer has presented their laser hair removal equipment for a double blind study. I wonder why?

I truly believe that the laser should banned until it is proven (or made) safe and effective. Right now, physicians should be the only ones to use this equipment, which ought to be considered experimental at this stage. I wonder though, after this thesis is published, if they would have volunteers? And laser operators should advertise among themselves, in their own category, not under electrolysis. They should not be allowed to damage the reputation of an established profession by passing themselves off as members of it.

My Credentials

My professional schooling in electrolysis and electrology consisted of the following; 500 hours in Theoretical Sciences, Endocrinology, Histology, Biology, Microbiology, Anatomy, Physiology, Pharmacology, Hygiene, Sanitation and Sterilization, plus Electricity and Professional Ethics, while simultaneously taking 600 hours of practical application, for a total of 1100 hours of profession education. The Massachusetts State Board of Registration of Electrologists monitored my grades during my training. Upon completion of the requisites you are required to complete a patient thesis, Mid-term and final examinations plus a two-hour written State Board Examination and one hour practical examination. I successfully completed these examinations and was awarded a Massachusetts License and was designated a Registered Electrologist. I was awarded a diploma and issued a pocket license still current today. I graduated from Miss Kelly's School of Electrology in 1979, one of the oldest and the best schools in the country for my chosen profession. Massachusetts began licensing and registering electrologists in 1959, the first state in the nation to do so. Even though I live and work in Arizona I run my practice as if I were in Massachusetts and keep my license and registration current. In essence that means that a state board inspector could walk in any time with no warning, and inspect my office, equipment, hygiene and sanitation and sterilization equipment and cleanliness.

After completing the above mentioned, I authored, edited and published the Scientific Electrologist© editions 1, 2, 3 & 4, The Electrologist's Diagnostic Case History© and booklet with instructions, The Electrologist's Insertion Guide©, and the Electrologist Encyclopedia© and last but not least, this Scientific Thesis, LASER HAIR REMOVAL: AMERICA'S MOST DANGEROUS UNPROVEN TECHNOLOGY©

Also, I was a distributor and factory representative for a leading medical grade electronics corporation, which allowed me unlimited access to the modern computerized epilators (electrolysis equipment). All my equipment that I use is FDA approved and has earned the approval seal of Underwriters Laboratories "Seal of Quality." In addition I was the first Massachusetts Licensed and Registered Electrologist to use computerized epilators in 1985. The equipment I use has the highest U.P.E.M.A rating (United Professional Epilators Manufacturers Association).

Finally, I was sought out as a guest lecturer at Harvard Medical School from 1983-1987 on the subjects of Human Sexuality, Psychology, endocrinology and electrolysis. Since my basic education I have graduated from numerous schools to enhance my medical education. I am also qualified as professional witness for victims who have been permanently burned or disfigured.

To summarize: There are too many unanswered questions about this most dangerous unproven technology. The law requires that all equipment and personnel who it use to report injuries and damage that has harmed a patient's physical appearance and emotionally damaged that person. Eventually, when more attention is paid and testing becomes required, every malpractice report and incident should be mandated by the FDA to become public through the Federal Freedom of Information Act of 1974. Instead, most claims are paid by insurance companies who then pass off the increased cost to the consumer. Not only does the victim suffer, but the public does too, by increased health care costs. If I were contemplating have laser treatments I would make sure my insurance company offered palliative care, so check your insurance if you are going to take such a risk. When an individual whose only goal was to improve their appearance ends up permanently deformed with second and third degree burns that cannot be repaired by plastic surgery, ask yourself, what is their final outcome? Their final outcome is shame and devastating depression because of their ruined appearance for the rest of their lives. They are left with only one recourse and that is to file a lawsuit which takes years to come to a fair and just settlement. For that is the way the system operates, big insurance companies have big lawyers and their legal strategy is to prevent or prolong the victim's compensation as long as possible.

If the laser had properly been tested by at least two bona fide independent testing agencies that had not one financial interest, in my professional opinion this untested dangerous laser technology would never have been allowed to be used. The Laser was never designed or intended in any manner to facilitate safe, permanent hair removal and it is illegal for the Laser Industry to advertise permanent hair removal in any form. If every case where a patient had been physically and emotionally mutilated was required by law to be reported, these tragedies would not continue. Instead the victims were paid off(out of court settlement). When you settle a malpractice claim out of court the injuring party requires that you sign a waiver never to divulge it publicly or privately. If every one of these inhuman atrocities were made public it would result in FDA investigation. In addition, they should be required by law to properly prove and test their product, their practitioners and last but not least, their non-existent ethics. The lobbyists and big money, big marketers who have rushed this dangerous, untested technology through our government should be investigated for that reason alone! With finical clout and lobbying the Laser Industry keeps on moving its special interests through our government and that undermines our civil rights and the safety checks and laws that were put in place to protect you the public from harm. That these individuals can do such physical and emotional harm to a fellow human being is morally wrong. These people have sold their souls for greed and avarice. How they are able to go home and sleep at night clearly demonstrates their lack of humanity.

The Laser Industry has attacked the Electrolysis-Electrology profession since its conception in 1996. They have slandered us and accused the Electrolysis-Electrology profession of only being interested in maintaining the Status Quo. Well, they are wrong; we Electrologists are good people who care, especially those of us have taken the time, the effort and and have worked hard to become educated, State Licensed and Registered Electrologists. We have worked hard to create State Boards of Electrologists to regulate and insure the safety of the public and to insure the quality of your treatments. We Electrologists have Schools, Guilds, Associations, and we share our knowledge and pass it down to each other and the next generation. To insure your safety ask why the Laser Parlor operators why they have none of the above. As them why they do not have a State Board of Laser Operators to answer to. Ask them why most of their schools are only forty hours long. Ask them, if it is so safe and works so well, then why are people still being maimed and mutilated? Ask them to guarantee you in writing that this will not happen again. Ask them why they have no double-blind study as stated above? However, I ask you the consumer, that after having seen all the photographs and read the reports, is it worth the risk? If you are a victim or have a friend that is a victim, send me your photograph and your story. I will do as much as possible to bring your story and injustice to the to the attention of the public. For when we bring the truth forward only then will we have justice, along with public peer pressure that will bring an end to this unproven, untested, and most dangerous technology that lives off of you, the consumer.

Thank you for your time and attention,

Kimberly Williams, R.E., Dean

Copyright 1999 and revised Copyright 2003, 2004 and authored in its totality by Kimberly Williams, R.E., Dean

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