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12-17-2025 Council Packet
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12-17-2025 Council Packet
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<br />Little Canada’s licensing provisions, found in Chapters 2202 and 2203, were written to regulate <br />traditional massage therapy businesses and narrowly define massage activity, resulting in ambiguity <br />surrounding other CAHC and practices involving physical touch. <br /> <br />The City’s existing ordinance includes performance standards for massage establishments, such as <br />hours of operation, practitioner qualifications, rules around security, and general decorum in the <br />practice. The ordinance establishes a cap of three (3) such establishments citywide. <br />Staff believe it is prudent to clarify how the city regulates touch-based CAHC practices and other <br />similar touch-based services that are not traditional massage therapy, but pose similar questions and <br />concerns of public safety and wellbeing. The City Council discussed this issue at their November <br />12, 2025, Workshop meeting and provided staff with direction for updating the City’s standards. <br /> <br />Why Cities Regulate Touch-Based Wellness and Therapeutic Practices: <br />Cities regulate massage establishments and similar touch-based services for several reasons directly <br />tied to public health, safety, and welfare. <br /> <br />First, these practices create inherent client and practitioner vulnerabilities. Services often occur in <br />private rooms, may involve partial disrobing, or may involve individuals who are emotionally, <br />mentally, or physically vulnerable. These conditions elevate risks of misconduct, exploitation, <br />boundary violations, or unsafe interactions. Operational standards such as restricted hours, no locks <br />on interior doors, inspection access, required coverings, and prohibitions on beds or sleeping <br />equipment are widely used to mitigate these risks and maintain a safe, professional environment. <br /> <br />Second, massage-related businesses have historically been used as fronts for unlawful activity <br />nationwide. Establishing parallel performance standards for all touch-based practices ensures that <br />operators prone to the same concerns and risks are equitably regulated and subject to the same level <br />of oversight. This approach provides regulatory clarity by applying consistent oversight to all touch- <br />based services that present comparable operational and enforcement considerations. <br /> <br />Third, touch-based services can involve prolonged physical contact in enclosed settings, which <br />creates health and sanitation concerns. Requirements related to compliance with building and health <br />codes, sanitation expectations, prohibition of drugs and alcohol, and the City’s and County’s <br />authority to inspect premises support the maintenance of public health standards. <br /> <br />While some conduct standards appear in §146A or in other laws, local licensing provides the City <br />with a direct and effective oversight and enforcement mechanisms. Without a local license, the City <br />must wait for State, County, or Sheriff intervention and would have a limited set of tools to respond <br />even after misconduct is identified. Local licensing allows the City to act independently and <br />decisively against establishments engaging in unsafe, illicit, or non-therapeutic behavior, including <br />suspending or revoking their ability to operate. This gives the City a proactive means of <br />safeguarding public health, safety, and welfare rather than relying solely on external agencies to <br />address problems after they occur. <br /> <br />Proposed Ordinance: <br />Ordinance 921 makes minor amendments to the existing standards outlined in Chapters 2202 and <br />2203 to clarify regulatory treatment of non-massage touch-based practices. <br /> <br />1. New Definitions <br />Instead of broadening “massage,” the ordinance creates a distinct category for CAHC <br />practices that involve purposeful, non-incidental touch for therapeutic, relaxation, comfort,
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