STERILE TATTOO INK

You are free to use these arguments provided either Unimax or Wes Wood is attributed as the source for these ground breaking arguments.

A1334-2015 Outline of Issues, September 1, 2015
Submitted and written by Westley Wood

The faulty-logic for this bill is as follows:
Bill A1334 MAKES A FALSE assumption THAT:

"Only sterile ink is fit to use."

That has to be Proven but it is not, nor is there supporting evidence provided.
Some have suggested this was an attempt to take over the ink business by dropping this bomb on tattooers.
A1334 assumes as true that Ink exposed to air more than once (using reservoir bottles) is unfit for use.
HOWEVER, Biological testing by Unimax proves that ink remains sterile on the shelf after repeated opening and closing when using a source container.
If that were the caswe, which it is not A1334 contradicts itself Single use ink “packages” will be exposed to air.

THEREFORE (A1334 Conclused):
Only single use packages of sterile ink are fit to use.
(These reasons do not support the conclusion.)

Using the same faulty logic, as soon as you open the single use ink package it becomes exposed to air and is now unfit for use.

Rebuttal Objections
1. Is a needle as soon as opened exposed to air and so, unfit for use?
Is the open cup of wash water unfit?
2. Only two sources of tap water when mixed into ink has been linked to infection.
One by an Arizona maker of ink using tap water, and the other to tap water to lighted black to explain a cluster of isolated incidents and hurriedly NYC made a rule that sterile water is to be used when mixing inks with water.
3. Safe and effective usage over time is the universal principle to determine if something is safe to use or not. The current reservoir method is proved by usage over time as safe and effective. Usage trumps technical specs. Both non-sterile and sterile ink from reservoir bottles poured into single use ink cups is already the voluntary standard affirmed by Health Departments everywhere effectively protecting the health of the community from cross contamination. It works. There is no merit or advantage changing the method to only single-use pre-sterilized ink "shots."

Non-sterile CUPS AND GLOVES are proven safe by usage though not sterile. Gloves are not implicated as a source of infection. Their hot manufacture conditions produce a virtually sterile, accepted level of protection proven by safe usage over time (including in hospitals and medical settings) except in open-infection-prone procedures performed in special Operating Rooms.

COMPOUNDING INK and WASHES is proven safe by usage.
Tap water has been a source of infection when mixing or compounding ink from ingredients or making washes. This was acted upon by NYV DOHMH. Artist’s mixing pigments on the spot has never been implicated in causing infection. However, clients should be made aware when inks are not sterile. There is no evidence to support a prohibition of the long history of custom mixing ink, nor for the matter, making one's own needles.

COST IS A LEGITIMATE, IMPORTANT FACTOR impacting the livelihoods of thousands.
The ink for a tattoo that now costs $0.35 to $1.00 per tattoo will now cost $5.00, $10.00 even $25.00 and more, using single use ink packages. This will directly harm tattooists. It will decrease business.

INVESTMENT LOSS
Tattooists have investments of thousands of dollars in ink and decades in working with many inks to find the mix that works best from their tattooing. These years of experience will be lost. It takes 10 years minimum to see if tattoo work even lasts looking decent.
Industry suppliers have millions invested in ink, ink made years in advance and would be irresponsibly harmed without even a hearing. The principle is: those effected by a rule must have an opportunity to comment. In this case there was not comment period. Why do you supposed that was?

SINGLE USE IS A FAILED IDEA TRIED MANY TIMES
Good for closet, illegal, non-licensed tattooers who take their stuff from under their bed to tattoo their friends on the weekend for some quick easy cash. Those fly-by-nighters with no experience will now get ink anywhere they sell tobacco.
Single-use packages are made for that kind of distribution and will encourage unsafe tattooing. They have been introduced many times, in twist opens, k-cup style, blister pack, vials, and all were rejected as unsuitable for professional shop tattooing. Those who are ready to supply single-use packages by December 2015 would distort the selection away from the inks used successfully over time to the detriment of the tattooist and the client and the makers of the most used ink favorites.

Respectfully submitted:
Westley Wood, Lic. #40596680, Owner, Sacred Tattoo NYC and Unimax Supply Co.

A Second Coloquial Presentation

"New New York State Law" BILL A1334-2015
REQUIRING
INDIVIDUAL-USE STERILE TATTOO INK PACKAGING

Of course this is upsetting because it will cost
ten to twenty times as much if single use "packages"
are required per tattoo and will do nothing
to reduce "infection rates",
(the justification for the law.)

The Tattoo Argument

The industry standard method, which is:
using a main bottle and dispensing ink
into single-use cups is
PROVEN BY USAGE
Safe and Effective
PROVEN in millions and millions of tattoos
by tens of thousands of tattooists
for decades.

We do encourage using Validated Sterile Ink.
The cost is not that much: $0.10 - $0.25 per bottle.
But it takes time and we expect the industry
itself will go that way, buy into it, without being compelled.

Albany Bill A1334-2015 concerns infection.

It is not true
that a previously opened bottle of sterile-or-not ink
is suddenly unfit for use by dint of opening and
dispensing ink because it is exposed to air.

If that were true... (which it is not)

... then, as you pour the ink into a cup
it becomes unfit for use, being exposed to air,
(worse, it is mixed with air).
Common air does not cause ink to be unfit for use.
Ink may no longer be "technically"
operating-room sterile for an infection-prone open wound,
but that is not tattoo. They share similar concerns
but do not require the same response.
If the needles are opened, are they
then no longer fit for use?
Safe and effective usage over time
proves current practices are safe.
Nothing can trump safe and effective usage over time.
If single use packages are required, then tattoo requires a
HOSPITAL OPERATING ROOM!

Tattoo is not
OPEN-INFECTION-PRONE SURGERY.
Clients do not walk away with infections,
and we NEVER see yellow eyes.
The extreme standards for Operating Rooms
cannot be reasonably required for tattoo.

Cups and gloves must be brought up
to lay that argument to rest.
While technically not sterile they are manufactured
as virtually sterile from hot forming machines
and have never, never been implicated as a source
of infection, for the same reasons that air
has not been implicated
as a source of infection in tattoo.

The last issue concerns compounding ink from ingredients.

Validated-as-Sterile Sterile Ink, would be the ultimate for safety
(Ink that is consistently lot tested negative for growth).
Because there are isolated cases of non-sterile ink as a source of infection
it is not unreasonable to be transparent with the client
and ask for client approval before using formulated and non-sterile ink.
That is fair.
It is also reasonable to limit the storage life after opening
similar to other cosmetics, perhaps 12 months.

SENATOR CARLUCCI
finished his presentation by saying he would
notify health departments to delay implementation until legislative action can be implemented to change or amend the bill.
Simply re-interpreting the law as I suggested but not changing it might lead to problems of interpretation at a later date by different health departments. Good point.

There is one last point,
What happens to tattooist investment in ink?
Tattooists have thousands invested.
Suppliers have millions invested.
We are not simply going to throw this away
without proof of a clear and present danger to public health.

"Why the law?" was asked.
Senator Carlucci said Red Cross asked for the law and the sponsors relied on Red Cross interpretations and understandings.