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Needles used in tattoo and piercing are classed as "Sharps." 

Contaminated Sharps refers to any SHARP item that has contacted blood or potentially hazardous substances that can penetrate the skin and therefore includes used tattoo and piercing needles. Un-used needles would not be considered "contaminated."

Blood, in infection control refers to liquid human blood unless modified (it does not refer to particles). 
Carefully examining how definitions are defined  in legislation-derived political regulations sometimes reveals a common Fallacy of Argument: switching meanings.

For tattoo and piercing, if liquid blood could be squeezed  from a wipe it would be considered hazardous waste.  Universal precautions refer to blood (fluid) and other bodily fluids, not mere wipes.  If a bandage were squeezed and blood or semi-liquid blood was released, that would make the item Contaminated Waste requiring hazard waste disposal.

Exposed means a specific eye, mouth, mucous membrane, non-intact skin or parenteral (piercing the skin barrier) contact with blood. Exposures are serious requiring specific remedial action.

Contaminated refers to the presence or reasonably anticipated presence of blood or body fluids on an item or surface. "Cross-Contaminated" is usually used to refer to anything that has come into contact with something contaminated.   

Leaning on a tattoo with unprotected forearm not only increases your risk of blood contact but can possibly cause your skin flora to infect the client.

Antiseptic creams and ointments are used to fight (existing or suspected) infections. They are not considered nor used as protectants.  Modern infection healing is done systemically, not by the application of
antiseptics.  Many applied antiseptics actually prolong the healing process and interfere with the wound healing process.

Regulated waste refers to blood in a liquid or semi-liquid form, dried blood or caked instruments.   
If you can squeeze or ring blood droplet from wiping tissues or gauze it is considered regulated waste. Properly performed tattoo does not generate any regulated waste.  Liquid waste (e.g., from ultrasonics) can be flushed down the toilet with care to avoid splashing.  Non-regulated contaminated materials can be placed in a plastic bag that is sealed and discarded in the routine trash disposal system.

Soap and Water Cleaning as compared to Cleaning with Disinfectant Cleaners produces no statistical difference in bio-burden levels on cleaned surfaces. The effectiveness of ingredients can be measured, but their effectiveness on a surface compared to simple cleaning is not demonstrated to be greater. There is cause to suspect the use of disinfectants as harmful to people and the environment. Disinfectants should be used judiciously and routinely changed.

Liquid sterilants, such as Cidex etc., have no place in tattoo nor piercing . Labels, which must be followed, usually state that it is a violation of Federal Law to use the products other than for their intended purpose.  Often fumes must be ventilated for safety as well.

Air spray disinfectant rates have not been demonstrated.

Single Use or "disposable" labeling on any package means that it is not intended for re-use nor for use on more than one client.

Health Departments are responsible to protect the health of the population-based community.  All Tattooists must protect the health of the community and the local health department is the primary source for community priorities  relating to tattoo. Discussion with DOHs to influence appropriate regulations should be done in appreciation of their task and respect for their efforts. 

Keep in mind
Health Departments have done more to extend
life & happiness than the field of medicine.

It has been my experience that DOHs are

  • too busy with "real" concerns and don't think time spent on tattoo is of particular value 
  • rely on only a few sources for their information;
  • do not normally proactively reach out to the tattoo community;
  • only ask for comments at the last moment after the regulations have already been effectively finalized.

All tattooists and piercers are required to follow DOH  regulations.

AIR in in hospitals is a source of microorganisms. Air disinfection reduces wound infection rates as measured in hospital settings. Effective air disinfection equipment requires professional engineering and room air flow pattern studies plus close monitoring. Filtering units placed other than at the source of new air mixes the disinfected air with untreated air and significantly diminishes effectiveness. Treatment must occur where the air actually enters the room. Air change rates listed as so many times per hour for modular filtration units is not an indication of any amount of room disinfection. Filtration is not as effective as Ultra Violet treatment. UV however requires equipment that can be dangerous and ineffective if not professionally installed and diligently maintained by a knowledgeable staff.  There is no reason to suspect a dangerous concentration of pathogenic air-borne microorganisms in non-medical settings.
Air-borne sources are problematic. Fungus and mold are the only microorganisms that can be detected to a degree, and everything depends on where the test is done, how it is done because it leads to no wider conclusions about air generally. Even spores settle out of the air at a rate of 3 feet per hour. There are no reasons to suspect normal air as being a source of infection.

SNEEZING and COUGHING are dangers for airborne spread of infectious microorganisms in a normal environment that we would like to keep as free of microorganisms as possible. The aerodynamics, just like a spray gun, produces great numbers of droplet nuclei which will be suspended in air and for long periods of time. It is these suspended particles that carry infectious microorganisms that spreads disease. A sneeze or cough into a tissue prevents aerosol projection and transmission of airborne infectious microorganisms.. Once on the tissue surface the tissue can be safely discarded and the spread of possible air borne contamination eliminated. Sneezing and coughing must always be done into a tissue. Have an easily accessible supply of tissues for customers and visitors.

PETS: Because dogs and cats may transmit more than 30 illnesses to humans their presence raises concern although their is little information available to determine if the risk is of any significance.

CHILDREN are at greater risk than adults of getting disease. At the least children should only be allowed in a secure separate waiting area that does not contain contaminated items.

CARPETING has been shown to contain higher levels of microbial populations than hard surface flooring. Although studies have failed to link carpeting with any increase in infection rates or the spread of disease the expense and difficulty of maintaining carpeting in a sanitary condition is formidable and probably not achievable in a tattoo or piercing area.

Floor, Walls and Ceilings are sometimes specified as needing to be impervious, easily cleanable, etc. to prevent the spread of disease. Whereas these qualities would be esthetic, studies show the opposite. 
It is not the physical environment that spreads disease but patients in hospitals who contaminate the floor, walls and ceilings.  These requirements for tattoo have no justification and are contrary to published study.  We applaud our advanced NYC DOHMH for opposing these types of regulations as a waste of tax-payer monies having no effect whatsoever on infection rates. (Decreasing infection rates is the justification for regulation.  Everyone subject to regulation should ask for a review of the results of regulations to evaluate their effectiveness.)  It is the responsibility of any health department promulgating regulations to monitor and evaluate the effectiveness of their work to see if they are being successful and if any changes are needed to be made in their practices or principles.  Unfortunately asking this kind of question would be very confrontational because there is nothing to report, no evaluations or assessments are made.  In short, there are no plans to see if the regulations actually work to decrease infection rates.

Sometimes tattoo feels that am attitude is expressed: we should consider ourselves lucky that we are even allowed to practice.  "Who needs tattoo and piercing." is the mesasage we get. Being tolerated means tattoo as folk cultural practice has not right to exist nor be practiced, that we exist by permission only which can be withdrawn.

Isolated Cases  are only isolated cases and are not considered evidence unless it can be demonstrated that contributing conditions are present and the same in every case.   No conclusion can be drawn to substantiate regulation based on isolated cases.  Improper scientific evaluation and thinking crops up in the most unusual places.

GOWNS are needed when soiling is anticipated and are not implicated as a source of cross-contamination.

MASKS and eyewear are used when splashing of blood or body fluid is expected and are not for protection from breathing airborn microorganisms.  Certainly not expected in tattoo.

Filters, and masks, astonishingly, are given a rating at half-clogged capacity.  Which means that if you cleaned your air conditioner filter every day you would have no filtration, or if you changed your auto air filter every month you would ruin your engine.

LAUNDRY should be detergent washed in hot water (70ºC, 160ºF) for 25 minutes

EMPLOYERS should assure workers receive training and education on the prevention of transmission of pathogens and monitor for compliance.

IMMUNIZATION: In addition to standard immunizations all workers who who are occupationally exposed to blood or OPIM should be protected against Hepatitis.

Latex Allergies.  Hands should not be moisturized before donning gloves.  Gloves should not be "snapped" off.   Powder-free gloves may offer some relief.  Employers are required to provide adequate protection to workers.  There is a new sealant for hands that may decrease
latex allergy reactions.

Unimax System for handling used needles and tubes.