Yes, very. First, the “laying on of hands” is reserved to ordination. Second, the laity cannot actually bless except in very limited circumstances. Just because someone says something that sounds like a blessing, or makes a motion that resembles a blessing, doesn’t mean that any blessing was actually given.
I understand what you are saying here, however, I think you are carrying this a little too far. Laying on of hands has many uses and reasons why it is acceptable by laity and clergy; it is not exclusive to ordination.
If I am understanding the post in which this comment is about, a retreat master who is a lay person is in charge of this retreat, and therefore the people in which are on the retreat team, so they are in the charge of the retreat master and in that person’s authority, so yes the retreat master can confer, with language appropriate for the laity, a commissioning or blessing for that event. There is nothing wrong with that. On the other hand, if the retreat master does things as a cleric would, then there may be an issue; i.e. “I bless you in the name of the…” It would be appropriate to use words such as to call upon the Holy Spirit, or give whatever a person may need for this particular event. It is okay to say, “…may God bless you…” Yes, even with hands extended or laying on the person. Any person can wish that type of blessing on any one they care to. That is not a priestly blessing; it is a prayer of intersession for this particular person. This is the context that this should be kept in.
My main point is this, we encourage laying on of hands often in prayer for healing, or intersession, or you name it. We teach our confirmation kids to lay hands and pray for healing. Our bishop at the end of Mass does something that I think is incredible, he invites anyone who wants healing prayer to come out of the pews and stand in the isles. Then he invites the newly confirmed to lay hands and he leads them in a healing prayer.
Please don’t try to clericalise everything a person does that could be seen as “what the priest should be doing.” After Mass often people come to me to bless items like rosaries or medals, I will always do the same thing, look for the priest. I tell the people who ask, I can bless this item, however, since the priest is here I must defer to him; and the people give me the same reaction, “oh, ok.” It gives them a sense of what is right; the priest should be the main focus. But if the priest is not available, then I will confer the blessing.