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MoCRA 2022 - Below are some "as-is, unadulterated" references to support the contention that, as a whole, pigments are not of concern toxicologically nor a danger to the public in the application of tattooing. There is no evidence - zero evidence to support eliminating from the market our pigments. Pigments normally used are not dangerous as tattoo ink.

100s of millions of tattoos are living proof. Where are the bodies? Where? Our hospitals are not full of tattooed people. It is likely the revere is true.

First quote From:
The Color Pigments Manufacturers Association Comments on EPA's HPV NPRM: A CRE Review
Quoted from the published Letter to EPA OPPT Document Control Office
Docket Number OPPTS-42213A

"The CPMA has defined pigments as "Colored, black, white, or fluorescent particulate organic or inorganic solids which usually are insoluble in, and essentially physically and chemically unaffected by, the vehicle or substrate in which they are incorporated. They alter appearance by selective absorption and/or by scattering of light. Pigments are usually dispersed in vehicles or substrates for application, as for instance in the manufacture of inks, paints, plastics, or other polymeric materials. Pigments retain a crystal or particulate structure throughout the coloration process."

"A critical characteristic of color pigments, therefore, is stability and insolubility in the substrate which makes up the final use of the color pigment. Indeed, this characteristic defines in large part the quality and value of a color pigment in the marketplace. The more stable a color pigment remains in harsh environments, including outdoor applications, the more valuable that pigment will be in the marketplace. Such stability has environmental benefit since stable coloring does not require re-coloring or replacement of the colored product."

"With only a few recognized exceptions, color pigments, both organic and inorganic, are extremely insoluble in water. As an example, copper phthalocyanine organic pigments have a maximum solubility of less than a part per trillion. A solubility in water could not be calculated for chrome antimony titanate, an inorganic pigment, since the pigment cannot be dissolved sufficiently in boiling sulfuric acid to create a calibration curve. Color pigments are not, therefore, a threat to the environment when disposed of with solid waste in appropriate lined landfills. Color pigments are further protected from leaching into groundwater by the plastics, paints and inks that make up the final products incorporating color pigments."


From IOP
The single most important factor in evaluating the toxicological and ecological properties of an organic pigment is its extreme insolubility in water and in the application media.
“Pigments are therefore processed largely as solid, crystalline, and therefore physiologically inert materials.
Since organic pigments are commonly combined with other materials, a pigmented system typically contains only a small percentage of actual pigment. It is, therefore likely that other components, such as binders, solvents, and various agents may more severely affect the ecological and toxicological properties of the applied product.”
p589, Industrial Organic Pigments, Production, Properties, Applications, Third Completely Revised Edition, 2004, Willy Herbst, Krause Hunger ISBN 3-527-30576-9


A comprehensive study, performed in the USA by DCMA* has show, that the metal impurity in organic pigments is markedly below legal standards[8]Dry Color Manufacturers Association, now CPMA (Color Pigments Manufacturer’s Association.


Toxicity of Organic Pigments

Organic pigments are extremely insoluble. As a result, these compounds are non-toxic and very low in bioavailability. In the literature, there are three published summaries concerning the acute toxicity of pigments.1 The vast majority of these LD50 values are above 5000 mg/kg and no LD50 values for pigments are known to be below 2000 mg/kg. As such, when compared to other compounds, organic pigments are not, and should not, be assigned a high regulatory priority based on toxicity. Since these compounds have been found to be safe in extremely high doses, priorities and resources should be directed toward compounds which raise concerns.

Therefore, due to their extremely low solubility, in both lipids and water, organic pigments are not bioaccumulative nor do they bioconcentrate in the food chain. This has been shown by extensive tests which have indicated that, even though log P values for organic pigments may be calculated at levels that would signal concern, in actual tests, organic pigments do not exhibit any potential to bioaccumulate.


Synthetic colorants represent a relatively large group of chemicals met practically everywhere in our daily life. Such potential hazardous chemicals may have undesirable effects not only on the environment, but also on humankind. To minimize the possible damage arising from
production and applications [ww.emphasis] of such colorants, an international association called ETAD (Ecological and Toxicological Association of Dystuff Manufacturing Industry) was founded in 1974, which coordinates the ecological and toxicological efforts of organic-colorant manufacturers. …
… The following examples, are in part, based on investigations made by ETAD groups some time ago.  A survey of acute oral [ww]  toxicities, as measured by the so-called LD50 value demonstrated that of the 4,461 colorants tested, only 44 (ca. 1%) had a LD50 <250 mg/kg, but 3,669 exhibited practically no toxicity (LD50>5g/kg). The evaluation of these colorants by chemical and coloristic classification showed that the most-toxic compounds are found among bisazo and cationic dyes. Pigments and vat dyes generally display very low actual toxicities, presumably attributable to their generally poor solubility in both hydro- and lipophilic media. Today, the LD50 test is hardly performed anymore because of the large number of animals to be killed.
Much more difficult to assess are chronic risks such as carcinogenicity and, to a lesser extent, sensitization and allergies evoked by colorants. Since long term tests with animals are difficult and ethically hard to justify, carcinogenic risks are assessed by short-term bacteria/mammalian microsome assays and by long-term observations of people working in dystuff production. [ww]
…Bisazo dyes based on benzidine are also known to be carcinogenic  … epidemiologic studies revealed an increased incidence of bladder cancer in workmen exposed [ww] to benzidine.
benzidine-type colorants are no longer produced [ww] by the large dyestuff manufacturers. This policy also includes pigments. [ww] Benzidine pigments are not really toxic, because it is very unlikely that these insoluble materials are reduced in the intestinal tract. [ww] [Tattooed pigments do not go into the intestinal tract where pigments can be broken down. [added by ww] pp 583-6 Color Chemistry, Heinrich Zollinger 2003

The above is very important to show how false the claims are of the dangers of pigments.

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

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

Westley W Wood, Pres.
Unimax Supply Co Inc.
NY NY 10013


If we are prohibited (meaning threatened with force against dissenters) from using our customary and effective inks, proven safe over time, I am suggesting we could reject using or purchasing the new "temporary" inks.  Wes Wood  9/12/23