The Room Has Standards. The Heater Has Standards. The Operator Doesn’t.

Three standards tracks are converging on the U.S. sauna industry at once. Europe published its first room-construction standard in February. The U.S. published its first modern heater-safety standard last June. And in April, a solo trade attorney published a 6,000-word white paper arguing that none of it will matter much unless operators build their own certification infrastructure.

MacKenzie Boling, the founder of Longevity Law PLLC, wrote “Building Defensible Standards for Sauna, Thermal Bathing and Contrast Therapy” and posted it on Substack in early April. Five weeks later, on May 12, Sauna from Finland republished it through the trade body’s member news channel. That is the news peg here: not the white paper itself, but the industry’s largest trade body choosing to amplify a solo practitioner’s argument that the operator side of the business has no structural floor.

The timing is useful. It lets us map the operator-standards question against two hardware-standards milestones that SaunaNews has already covered. The picture that emerges is a category where the physical product is getting real institutional infrastructure while the people running the rooms are still figuring it out on their own.

The Hardware Side Is Getting Real Infrastructure

Within the past year, the sauna industry’s physical products picked up two major institutional standards, each the result of years of committee work.

UL 60335-2-53, published in June 2025, replaced UL 875 as the U.S. safety standard for sauna heating appliances and infrared cabins. It carries ANSI approval and harmonizes the U.S. with the international IEC 60335-2-53 framework for the first time. Manufacturers now face a single modern standard instead of an aging domestic one. The transition has implications for every heater sold in the country, from residential wood-burning units to commercial electric models.

EN 18164, published in February 2026, gave Europe its first pan-continental standard for public wellness climate rooms. Developed by CEN Technical Committee 136, Working Group 16, it covers design, ventilation, materials, and safety for saunas, steam rooms, and infrared cabins in commercial settings. It took years of negotiation and significant Nordic pushback to get to publication.

Both standards share a trait worth noting: institutional backing. UL has a standards committee, a certification infrastructure, and a commercial testing model. CEN has national standards bodies, a formal objection process, and enforcement mechanisms across EU member states. Both standards have budgets, timelines, and organizations behind them.

The operator side of the industry has none of that. No U.S. body certifies sauna operators. No voluntary standard defines what a well-run sauna facility looks like. No professional association maintains a code of conduct with enforcement authority. Boling’s white paper is an attempt to name that gap.

One Attorney, One Substack, One PLLC

The white paper is a detailed argument, not a standard. It spans roughly 6,000 words and makes the case that the U.S. sauna and thermal-bathing industry needs its own operator-certification infrastructure before regulators or litigators build one from the outside.

The core claim: as the category grows, the absence of voluntary operator standards creates legal, operational, and reputational risk. If operators do not define what “good” looks like, someone else will, probably through litigation or local ordinance, and probably without industry input.

Boling proposes a framework organized around three layers. First, third-party certification for individual operators, modeled on credentials in adjacent industries like personal training and food safety. Second, voluntary practice standards developed by industry working groups covering areas like temperature protocols, sanitation, staff training, and emergency procedures. Third, a professional-association model to house and enforce both.

The author’s background is relevant to reading the argument. Boling is an attorney and the founder of Longevity Law PLLC, a firm focused on regulatory and risk work for wellness and longevity operators. She is a former public defender and former licensed massage therapist. Her consultancy offers operator risk reviews and a subscription legal-education product.

That does not invalidate the argument. But it means the person proposing an operator-certification framework also runs a business positioned to benefit from one. We treat that as context, not disqualification. The structural question she raises exists whether or not her firm is the one to answer it.

Why the Channel Matters More Than the Document

Position papers on Substack are common. What made this one worth covering is what happened five weeks after publication.

Sauna from Finland, the trade body representing Finland’s sauna industry, published Boling’s paper on its member news channel. The organization represents over 100 Finnish sauna companies and functions as the industry’s primary international marketing and standards-adjacent body. It is, by membership count and global reach, the largest sauna trade organization in the world.

The republication is not an endorsement. Sauna from Finland regularly publishes member contributions, and the member news channel carries less editorial weight than the organization’s own research or policy reports. But the decision to host a U.S. attorney’s argument for operator certification on that platform is a signal worth reading. The institutional side of the industry sees the gap too.

The signal gets more interesting when you look at what Sauna from Finland does not do. It is a marketing and trade promotion body, not a standards organization. It does not write standards, accredit operators, or run certification programs. CEN writes EN 18164. UL writes UL 60335-2-53. Nobody writes the operator equivalent. Boling’s paper is naming a vacancy that the industry’s own institutions have not moved to fill.

What the Regulatory Vacuum Looks Like in Practice

The white paper makes its case at an abstract level, so it helps to see what the absence of operator standards looks like on the ground.

There is no federal framework for sauna operator licensing in the United States. No state requires certification to operate a commercial sauna facility. Health departments in most jurisdictions treat saunas as an afterthought in pool and spa codes, if they address them at all. Cold plunge adds a new layer of complexity, with facilities navigating a patchwork of local pool codes never designed for deliberate cold-water immersion.

The consequences show up in municipal zoning. In Minneapolis, 1980s-era city code classified saunas and bathhouses alongside adult entertainment venues. The categories were never separated. When operators tried to open legitimate Nordic-style sauna facilities, they ran into a regulatory structure that could not tell the difference between a löyly ritual and a strip club. At least one sauna business closed. The city eventually revisited its approach, but the episode illustrates a pattern: without operator-level standards, cities default to whatever regulatory category they already have, and that category is often wrong.

Boling’s paper argues that voluntary, industry-written standards would give operators something to point to when a code official, insurer, or judge asks what “standard practice” looks like. Right now, the answer is that there is no standard practice. Every operator invents their own.

What Remains Uncertain

A white paper is not a standard, and a Substack post republished by a trade body is not a standards project. Several large questions remain open.

There is no committee. EN 18164 took years of multi-country negotiation through a formal CEN technical committee. UL 60335-2-53 went through ANSI’s consensus process. Boling’s proposal has no committee, no institutional sponsor, no funding, and no announced timeline.

The industry may not want operator standards. Compliance costs money. Defining a standard of care creates a litigation benchmark that does not currently exist. Some operators will see voluntary certification as a competitive credential; others will see it as a barrier to entry that favors larger, better-capitalized players. The trust question in this industry cuts in more than one direction.

Self-regulation carries its own risks. If the people writing the standards are also the people selling compliance services, the framework can drift from consumer protection toward gatekeeping. That concern is not unique to sauna, but it is worth naming in a category where the certification market does not exist yet and the first movers will define its shape.

And there is no announced next step. The white paper does not name a pilot program, a working group, a founding committee, or a timeline. It is, for now, a well-argued brief that identifies a real structural problem without a concrete mechanism to solve it.