MoCRA 2022 - Some references to support our 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 - that pigments are dangerous.

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."

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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

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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.

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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.

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"...the most significant expansion of the FDA's authority…since…1938:" Westley W Wood, Pres. Unimax Supply Co Inc. NY NY 10013 (est. 1989) wes@unimaxsupply.com Westley W Wood, Pres. Unimax Supply Co Inc. NY NY 10013 05/27/2023