For All Friends, There is a

Diabolical Side of MoCRA of 2022:
Unintended Consequences

Because MoCRA is not a preventive policy initiative (regret and dissatisfaction come after, not before, a tattoo) the result of outlawing the current and normal pigments will be the same as having a pill to reverse a drunken stupor. The floodgates will open for outrageous tattooing not less, because tattoos will be easily removed. Nobody would want this. Policy makers wanting to prevent their children from tattoo-fever will see the opposite because tattoos will be easily removed, favoring those who can afford removal, leading to disregard traditional norms leaving others greater dissatisfaction and torment. Policy makers would see this.

Patrick Fafard writes in “Evidence and Healthy Public Policy”, Canadian Policy Research Networks: “Truth does not speak for itself.”
What is selected as evidence, whoever chooses what constitutes evidence seals the result and the policy follows automatically. This is the problem tattoo faces. Science and research are not independent and non-partisan, as Fafard says, not apart from, nor above the policy making but part of the process at its inception.

In the case of tattoo ink – since the FDA was legislatively charged by MoCRA of 2022 to establish “consumer removableness” (e.g. of tattoos, which is of concern to the tattoo industry) there is no wide enough public health policy network, though public health removableness arguments are the basis for the reversal of the 80 year policy of the FDA. The Act stimulates laser use by removing tattoo inks from the market that currently cannot be removed by current lasers. Who's to say this is not the intention? It will make life miserable by removing caution.

The overriding focus after nearly 20 years of lobbying by laser removal interests and a like amount of time by the FDA examining which tattoo inks to eliminate from the market and which to be allowed, is pre-established to require all tattoo inks used to be approved as removable by laser which will not eliminate but increase dissatisfaction and buyers’ regret.

Statement:

The quote below by Michelle Miranda from her book, Forensic Tattoos and Tattoo Pigments, supports the historic and current use, an understanding by "all" tattooists, that Tattoo is not Cosmetic, nor something Medical.  Tattooing technique and equipment is being used for those different applications. It matters what we believe and know what Tattoo is. Outsiders do not determine what Tattoo is. We do!

The FDA's sudden about-face describing Tattoo as a cosmetic product (after 80 years) is  understood for what it is: an attempt to legally justify the elimination of permanent synthetic organic pigments for the benefit of laser removal:  all our modern, safe and effective colors, as well as those not yet invented, excepting more easily laser-removable blacks. It is the pigment crystal structure that makes tattoos permanent. do not solubilize and creates attractive colors. Its essence is permanence without which it is no longer tattoo.

Laser removal interests have been lobbying the FDA for 20 years to get pigments removed from the market:  to enable lasers to easily remove  unwanted tattoos.

if inventors, such as Harvard Professor Dr. R. Rox Anderson, wants to compete in the market with a newer ink (his older 2008 easily-removed-tattoo ink, “Infinitink” was rejected by tattooists: (by not buying it). This ink was made available to Unimax  by "Freedom Ink!" (Really, that was the name.) Competition used to be the way to prove a products worth, but not today.  if MoCRA 2022 is being used to eliminate tattoo pigments, which is what I see, well, we get what we vote for.

The voters in the EU voted into office their leaders too and they have to live with that.

We have done the same, but hopefully we have time to stop the gutting of Tattoo of all meaning by the FDA issuing a "carve-out".

Westley Wood
09/20.2023

“…the most significant expansion of the FDA's authority…since…1938:

Raise your voice.

Westley W Wood, Pres. (Est 1989)
Unimax Supply Co Inc.
NY NY 10013

mail to wes@unimaxsupply.com

Sept 20.2023