MoCRA 2022 - The End of Tattoo (maybe)...unless...we
go about our usual and normal business using what we have always used: safe
and effective pigment inks.
Source material tells a different story about pigments.
See on Page 2.
Our Synthetic Organic Color Pigments are to be removed from the market so
that Lasers can more easily remove all tattoo$.
The Legislature passed the Act which gives the FDA deniability.
Laser removal is the problem, not the
Blue 15 is the most produced color because the pigment crystal is virtually
impervious to destruction. Why do you think blue jeans are blue? Blue 15
pigment does not disintegrate in almost any medium, including the body.
Words to the contrary have no evidence, Medical school teach that we
use toxic chemicals as ink, like mercury and make would-be dermatologists
memorize the names to dissuade patients from being tattooed, and surprise
even now the CDC suddenly goes 180 degrees warning about infections from tattoos even though there is
no greater infections of tattoos than anything else (they used to give tattoo
a pretty clean slate - - a sudden change without evidence).
the legislature got it in their heads to pass an Act, MoCRA 2022 enabling
the FDA to make rules specifically for products that meet the description
below, trying to hide the sole purpose of MoCRA 2022. Other effects are
The Act will creep to seize every aspect of tattoo from needles as medical
devices, to tools, training and licensing, even for purchasing ink. MoCRA
2022 is Pandora's Box ending Tattooing.
This is the
QUOTE: Convoluted language that fools no one.
"Products that are intended to alter appearance for more than 24 hours under customary or usual conditions of use and removal by the consumer
and is not part of such conditions of use."
removal interests describe tattooists as "people with little or no medical
training injecting unknown substances into people."
taught to regard a tattoo as a self-inflicted wound.
The EU has
already eliminated the "problem" inks.
The end of
Independent Tattoo Ink Producers.
will monopolize the tattoo ink market by large scale producers (now
going on). It is
accepted that more stringent oversight is necessary for large commercial ink
producers because of the order of
magnitude of the tattooed who can be affected by their products. There are
many independent small batch (400 to 800 oz. per lot)
tattoo ink producers who cannot afford the costs to meet new "medical prduct" regulations and
would not even be able to obtain the pigments only available by licensing by
the FDA. As an aside, how much will it cost to enforce compliance, and then
use violence against dissenters?
All this over tattoos.z
The rational to regulate tattoo used to be based on the
horrors of "infection" with HBV, Hepatitis C, and other strange sounding
diseases. Today, this
argument is all
but abandoned because infections are rare and most easily treated. But, it is being used, as step one in a 2-step
Step one in propaganda presents " a truth " that you already know
as a truth, such as tattoos can become infected. Add disturbing pictures and it sets your emotions
tattoos cause horrors.
Propaganda Step 2 introduces the lie: tattoo inks
possibly contain infectious materials, or the needles, or the artist
can give it and the ink may have toxic substances that are a threat to health, carcinogenic,
toxic, mutagenic. With the pictures you accept the lie.
Listen to an interview of very well
respected EU Dermatologist, Christa de Cupyer (deC) (30 years of Permanent
Cosmetics) Board Member of ESTP who is singled out and credited with
inspiring the makeover of tattoo inks by her book Dermatologic Complications
with Body Art talking about "the dangers of Tattoos and
Piercings". My comments indicated by [ww.]
European Academy of Dermatology and Venereology (EADV)
January 13, 2016.
Watch video here
but before you do be aware that this is a well constructed hatch-job to
frighten the beJesus out of patients, and all of it gross overstatement.
Before you watch consider
if the Questioner asked
"How can a person be at risk living in New York?
A similar answer to the interview might be:
There are many sources of getting harmed even killed in NY.
- cars and trucks kill pedestrians,
- delivery motor bikes whizz between cars knocking pedestrians down;
- things fall off buildings even killing passersby;
- subway riders get pushed on subway tracks,
- foods are known to cause disease,
- homeless attack at random,
- kids grab cell phones, pick pockets, grab carry bags,
- innocent people are killed by stay bullets,
- random people are punched, knifed even from behind
- inappropriate touching in crowds
Now watch the video below
to see the manipulation to scare you.
The bad things in the video do not regularly happen, are not expected to
happen but are presented as if of concern during normal activities. They are
extraordinary happenings that need not influence constant attention. They
are anecdotal presented as common occurrences.
The interview is meant to create the impression that any or all are likely
that they all must be considered happening when you sit for a tattoo.
Questioner: How can a
Tattoo get infected?
deC: Oh, there are
different sources for infection.
can just make infection;
[ww. There is no evidence the tattooists
can infect a client directly. Only one case is known of someone with no gloves, sores on his
hands, tattooing in a public park. It is plainly not likely so this is an
anecdotal case only.]
deC: the patient
himself can carry some bacteria on his skin
[ww.Tattoo ink has alcohol which kills bacteria.
The bacteria on the skin has no open skin wound to migrate to and is
constantly being surface wiped. This anyone should be able to see as part of
the procedure. Tattooist believe the skin bacteria of others after they
leave the studio may cause an infection, not the
person causing their own infection.]
and if the skin is not well disinfected he can get infected by procedure;
[ww. There is no evidence that the
tattooing inserts bacteria into the skin. The case cited above is likely
from rubbing the infected artist's hand on the skin directly, repeatedly.
This is anecdotal.]
deC: the devices can be infected
[ww. devices don't become infected. there is no such evidence.]
deC: especially the needles;
[ww.Needles are always sterile.]
and transmission for example of hepatitis by non sterile
(sterile) needle is
[ww. No cases have been documented.]
and also the inks can be infected
[ww. No known case of
hepatitis-containing ink has been shown.]
deC: especially if the
“novist” for example uses running water to dilute the ink.
[ww. No evidence substantiates hepatitis
from tattooing. Even the case in 1959 in NYC was mentioned by City Council
Member as known to be not true.
The only case is from a rural area north of Hong Kong that had no medical
personnel, no hospital no clinic in the 80s. One other source of NON-hep,
infection has been documented by a lone actor (#A) of mixing tattoo ink having used
Tap water to mix the ink, and then selling his ink at conventions and his distributor (#B)
selling to others during 2011 and 2012. This was
a bad lone actor. A separate tattooist diluting his ink with tap water
caused a number of infections in NY. Not actionable.]
The Second Question presented in the interview is:
"So tattoo inks are not safe or not always safe."
deC: There are many concerns in the medical world about safety of tattoo ink
[ww. "Concern" means "NO EVIDENCE" can be found.
The FDA has been lobbied by Laser interests for
20 years to remove inks that are hard to remove and now that the EU has done
so, it looks like the FDA may copy the EU. That would be a shame especially
since the EU improperly banned 316L Stainless Steel requiring the use
of only Titanium for initial piercing. The FDA should not follow the
politicized EU down this rabbit hole of harmonization of codes. It should be
the other way around, the EU should be following the FDA. MoCRA 2022 has nothing to do with
safety of tattoo inks. Hopefully the FDA will stand by safe and effective
use over time as the criteria for continuing their stance.]
because it has been demonstrated that tattoo inks contain contaminants
[ww. What is demonstrated is
that if anyone looks hard enough they can find nano size particles of some
things, sometimes, but there is NO LINK to any harm to the body. There is no
evidence of these claims, even after 20 years of searching to prove inks are toxic.]
carcinogenic mutagenic properties that these tattoo ink’s colorants in
tattoo inks get decomposed in the skin
[ww. Pigments do not decompose in the
They are crystal shape, insoluble and are not dyes.Tattoos are permanent.]
deC: and that this decomposition makes
other dangerous components
[ww. It is the Laser application that causes the crystal to degenerate into
new and different unknown chemicals. Laser interests apparently do not
deC: All these materials are absorbed in the body,
[ww. Colors in
other organs has been reported. But "absorption"? In the tattoo wound, cells
phagocytose foreign bodies when encountered and remain in place. This
isolates pigment crystals from interacting with the body. The claim of being
absorbed is not a
they are drained through the lymph nodes.
[ww. If there were
a problem with pigments in the Lymphatic system we would expect swelling or
inflammation. But there is none. This is a good sign, further proof that
pigments are not a threat to the body because there is no reaction by lymph
deC: But we know little about the bio
kinetics, about the transport in the body and the action of the different
components on different organs.
[ww. WOW here it is: they
know little about the effects of pigments, but want to destroy tattoo
EADV CONGRESS, 28 September – 2 October 2016, Vienna Austria
In my opinion
the Kruger publication quoted above, Industrial Organic Pigments, and
the CPMA are informative.
cannot argue about the existence of unwanted contents citing
"expert" "scientific" arguments. That would be fighting
with their rules. We should not even
consider debating so-called "scientific findings." It would be
insane to hire our own chemists to find what their chemists find.
It would seem
better to argue that colorants synthetic
organic pigments should continue
as a “carve-out,” as an exception
Tattoo had in the early 1900s, especially the nine years between the two
great wars (George Burchett, Memoirs of a Tattooist) - and continue to have
- a purely cosmetic
application of blush on the cheeks, lip and eyebrow using Tattoo methods, copying tattooist techniques,
the tools and the inks (but wearing a white jacket in a salon and never
using the word tattoo).
I can't be
more enthusiastic for George Burchett's Memoirs which fill the gap from late
189s to WWII. Order today from UnimaxShop.com.
For the past 80 years the FDA side-stepped Tattoo to avoid the dilemma that
Tattoo does not fit into a cosmetic meaning.
one argument that should win the day: Tattoo has the right to use
customary and normally used pigments that are proven safe and effective over
To wit, the
Tattoo argument is:
current customary and normal ink and practices have merit,
proven over a span of the last 80 years, by
consistent safe and effective usage over time,
In hundreds of millions of tattoos
by hundreds of thousands of tattooists.
USA FDA does
not need animal testing to prove the safety of our pigments as recommended
the so-called EU "experts" in the book Dermatologic Complications
with Body Art.
to allow usage is recognized around the world
by all Standards Making Bodies, such as ASTM, WHO and WTO,
accepted as the sine qua non of proof: safe and effective use
be consider cosmetic though some can use it so.
Tattooists have sympathy for those who have
psychological dissatisfaction and buyer’s regret but they "knew what they
were doing" and will have to deal with their problems. Their problem,
should not be made into our problem but it is precisely this that is driving
the effort to ban all pigments that makes Tattoo permanent. If MoCA 2022
paplies to tattooists inks then we are temporary tattooists and reduce our
art to meaningless butterflies, easily removed.
MoCRA 022 is
the result of 20 years lobbying to ban pigments that cannot be removed
easily by lasers, in fact, to ban all synthetic organic pigments because
lasers turn them into unknown substances.
No discussion is possible on these issues.
Tattoo does not enter into debate about these principles.
And in my
should Raise Our Voice.
August 16, 2023
Modernization of Cosmetics Regulation Act of 2022
Quoting from MoCRA
Products that are intended to alter appearance for more than 24 hours under customary or usual conditions of use and removal by the consumer
and is not part of such conditions of use.
Quoting From R. Rox Anderson. MD,
distinguished Harvard Professor and Inventor, who started this idea to
remove from the market those inks that could not be removed by lasers:
"If the FDA did regulate tattoos and they were made of safe materials,
sterile, well tolerated by the skin, and could be removed, it would be a
still love the idea of a safe removable tattoo. What I learned from this
is that when you come up with an idea make sure you understand the
ecosystem that the invention has to fit into.
obscures the obvious: remove tattoo ink pigments from the market that cannot
be successfully removed by Lasers. The words in the Act “removal by the consumer” makes it
clear that Tattoo is the target, an about-face of their historic 80 year
recognition of Tattoo. The FDA looks as if it is being used to ban the
use of color pigments in tattoo in the US
“…the most significant expansion of the FDA's authority…since…1938:
Westley W Wood, Pres.
Unimax Supply Co Inc.
NY NY 10013 (est. 1989)
07/09/2023 See below for 05/27/23
-1 05/27/23 See -2 Below Updated 07-09-23
Write the FDA – This could be trouble … (MoCRA)
The Modernization of
Cosmetics Regulation Act of 2022
The FDA has invited
you to write with questions (Quoted)
though my two inquiries were not responded to.
Inquiries about MoCRA can be directed to
Your Email Subject
line might be something like:
My Question is about MoCRA of 2022 and Tattoo/Piercings.
(Reply must be in the form of a question.)
Will the FDA openly
declare that MoCRA does not and will not
apply MoCRA of 2022 to TATTOO and PIERCING?
Send CC or BC to
if you might be interested
in sharing your take.
...or am I wrong in thinking that
controlling Tattoo Ink
is the major intention of this Act?
The Act does NOTHING to enhance the
already very high safety of
Tattoo and Piercing.
Westley W Wood, Pres.
Unimax Supply Co Inc.
NY NY 10013