Unimax Supply Co - MoCRA

MoCRA - She Says Mill Certificates Not Valid

Tue, 25 Mar 2025 13:10:49 GMT

MoCRA - She Says Mill Certificates Not Valid
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Part 1 by Westley Wood, Pres.,
Unimax Supply Co Inc., 269 Canal St., New York, NY 10013

It is important that Professional Piercers know that
“Mill Certificates” are not valid for piercing jewelry:
it is fraud.

1) Unimax defends the Rights of Piercers Not to deceive the public. So says Unimax, The leading Body Piercing Supply Expert for 30 Years.

2) 316L is by definition “Surgical” Stainless Steel (according to ASTM) 316L continues to be used SAFELY, for MORE THAN 30 YEARS by HUNDRED OF THOUSANDS of PIERCERS in HUNDREDS OF MILLIONS OF PIERCINGS.This proves safety.

3) No case can be shown that harm would have been averted
if F138 material had been used instead of factory grade 316L.

4) Support for Unimax Position can be seen in
Recognized Standard Setting Organizations, such as
ASTM, ANSI, WTO, WHO all declare the Principle:
“safe and effective use over time is considered proof”.
This is an operational principle that is counted on world-wide.
According to the World Trade Organization’s (WTO)
Code of Good Practice (CGP), as well as
the Technical Barriers to Trade (TBT)
accepted by the U.S. Government, by ANSI and ASTM
they ALL endorse and publish openly

STANDARD-SETTING PRINCIPLES are as follows

(a) Standards must establish a level of protection
appropriate for the application based on the risks in that application;
(b) do not result in arbitrary or unjustifiable discrimination;
(c) do not constitute a disguised restriction of trade;
(d) do not discriminate between similar goods that provide similar benefits;
(e) that a standard be relevant to the risks associated with the application and
(f) the factors that influenced the rule must be revealed to show:why this rule, why now?

5) Rules must not result in prohibition of what is proven safe and effective over time; (by safe usage over time).

6) “Qualities of materials are changed upon any work done to the original ingot. The Mill creates the ingot and certifies upon testing that it meets a specified range of material qualities. When the ingot is altered The Mill Certificate becomes invalid.

Ingots are sold to fabricators and made into different shapes, worked on more and finally a finished product is produced, usually through a few fabricators. It then must be tested if it is to claim it meets an ASTM standard.

Qualities of a material are not passed down as if by “inheritance” from the metal. When a material is fabricated into something, even polishing, even bending, even threading, the original material is changed and voids the Mill Certification.

Reason alone is enough for anyone to understand this.

“How can the Mill vouch that something meets the specifications when it has been altered: even by sterilizing the surfaces that are changed and void the Mill certification? Mill Certificates do NOT certify “products-made-from” a Mill’s material. The Mill Certificate is made for the purchaser not the ultimate consumer.

Disreputable sales pitches intend to mislead consumers to draw the conclusion that if it is made “from” F138 (they don’t reveal the above Mill Certificate is voided) therefore it meets the original specifications.

Knowing the truth we should not deceive customers. After all, we don’t know if even shards become embedded during threading or whether micro particles become embedded in polishing.

Respectfully submitted,
Westley Wood, President,
Unimax Supply Co Inc (registered NYC in 1989) NY NY 10013
Read the complete argument at
https://wreyeting.org/materials/body_piercing_material.htm

"...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

03/25/2025 Westley W Wood, Pres.
Unimax Supply Co Inc.
NY NY 10013

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She Says We Must Resist

Tue, 9 Jul 2024 07:19:58 GMT

She Says We Must Resist
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Update May 18, 2025
The tattooed can never accept as legitimate the destruction of tattoo by prohibiting the essence of tattoo: its raison d'être: its indelibleness, its non-removableness without which it cannot exist as a permanent mark on the skin. Tattoo is permanent by definition.

The wording of the Congressional justification is "gobbledygook". Here is the quote that is used to justify the FDA take-over.
"Products that are intended to alter appearance for more than 24 hours and removal by the consumer is not part of such conditions of use."
This Orwellian quote redefines tattoo but does not change or reveal the nature of tattoo nor descriptive of a new relationship that had previously been overlooked.
Judge for yourself if this justifies the FDA takeover of Tattoo creating a new concept that determines if a product is a Cosmetic for FDA purposes. This defining element REQUIRES REMOVE-ABILITY FOR TATTOOS.

Secondly, The British influence on the FDA is plain to see in the "MoCRA Draft Guidance for Industry 2023". This travesty should remain in the UK, not involuntarily imposed on Americans by a misled Congress: that which has always belonged to the people: tattooing.

Many States, cities and towns prohibited markings to peoples' bodies in the 20th Century. We took them to court and won our right to tattoo. New York City's Mayor signed the NYC Council's resolution in 1998 declaring Tattoo could not be prohibited.

MoCRA surely looks like federal interference by a work-around by prohibiting our safe and effective pigments that we tatooists have used in hundreds of millions of tattoos by tens of thousands of tattooists (in any living memory). As 1860 Orestes A. Brownson wrote, in essence, if cattle want to brand themselves they should not be prohibited. We would be fools ourselves to try to prevent them. Let them be cattle.
Which leaves only falsely-applied "Buyer's Regret" as if tattoos were sold as short-lived, temporary, knowing full well tattoos get old or even look poor one day. Today, that poor-looking tattoo can be fashioned into something with "dignity" so there is an answer that would not infringe on everyone else's individual rights: get a cover-up, that's the answer.

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MoCRA She Says Controlling

Wed, 1 May 2024 07:55:33 GMT

MoCRA She Says Controlling
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Mocra She Says Tennessee

Wed, 3 Apr 2024 07:00:53 GMT

Mocra She Says Tennessee
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She Says Tattooing is Permanent

Tue, 19 Mar 2024 08:37:51 GMT

She Says Tattooing is Permanent
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MoCRA - Statement 2

Fri, 26 Jan 2024 12:50:11 GMT

MoCRA - Statement 2
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YES: YIKES:MoCRA 2022 (USA) Yes, it's YIKES!

MoCRA WILL lead to TOTAL CONTROL!
Plain and Simple.
Private Rights / Public Interests.

Does a small portion of citizens
have a Right to prevent everyone
from being tattooed with indelible ink?

If the answer is "Yes" that is totalitarian.

--AND ANOTHER REASON--

It is impossible to have 2 rights contradictory.
If MoCRA is allowed then we have no RIGHT
to be tattooed with INDELIBLE ink.

What happens to dissenters?

MoCRACANNOT NULLIFY OUR RIGHT.
Especially since there is
NO HEALTH THREAT.
WHERE ARE THE BODIES?
What hospitals are inundated with tattoo problems.
Hospitals are now doing PM - being taught by tattooists
and prisons are now teaching how to tattoo.

100s of Millions of Tattoos are proof of safety
so health is not a legitimate argument.
Editorial: Wes Wood

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MoCRA FDA Reply to Unimax Letter

Fri, 22 Dec 2023 07:05:07 GMT

MoCRA FDA Reply to Unimax Letter
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MoCRA - Statement

Wed, 20 Sep 2023 08:44:34 GMT

MoCRA - Statement
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Statement

All Friends, There is another

Unanticipated Side of MoCRA of 2022.

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 towes@unimaxsupply.com

Sept 20.2023

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MoCRA Cosmetic?

Sat, 16 Sep 2023 14:18:51 GMT

MoCRA Cosmetic?
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Cosmetic?

Tattoo is not a MoCRA-02022 Cosmetic Product, never was considered as such and not now.
Quotes support that Tattoo (1) was never considered “Cosmetic” nor “Medical” by anyone, that (2)Tattoo was always something “other” a special something definitely not a ��cosmetic” anything. (3) Cosmetic and Medical users “used” tattoo techniques, were "borrowed" from tattooing inventing the term “Permanent Cosmetics” to separate the cosmetic-medical application from the rougher sort of people who get tattoos. (4) UK tattooist George Burchett , d.1953 after tattooing 60 years, writes about having two store locations, one an upscale dignified setting, wearing a white jacket to do eyebrows, lips, rosy cheeks and other “Cosmetic” enhancements being sure to never mention the word “Tattoo”. (5) The Page 66 quote is clear that tattoo was never considered a “cosmetic” And finally (6) the FDA has 80 years recognizing that Tattoo is not to be treated as a cosmetic product, it does not fit. It is metaphysical as well as existential.

-----------------------------------------------------------------------------------------------------------------
“While accounts from the tattoo artists were important in evaluating pigment use over time, these reports were subject to secrecy (and possibly deception), constant modification and loss of integrity, time passed and memories faded as stories and recipes were passed to newer generations, and artists came and went. In addition, formulations could change based on availability of supplies, experimentation by the tattoo artists and of course, the manufacturer of the materials being used by the artists. As such, without any reliable scientific data, accounts of pigment composition as reported by tattoo artists, historians, and even the researchers and information seekers such as those conducted by physicians, were limited in their ability to reliably ascertain pigment compositions available during any given time. A review of the scientific literature, in which studies of tattoo ink compositions was conducted based on experimentation using chemical and instrumental methods

provides a much more solid account of pigments used in tattoo inks for select time periods.”

Page 96, -6

p. 66 Miranda Forensic
“The technique of using flesh-colored tattoo inks is currently considered cosmetic or medical and often used to treat birthmarks, skin grafts or skin pigmentation abnormalities and diseases.”

“A variety of “folk” remedies were reported, [for tattoo removal]…As such, Parry compiled a list of “methods of tattoo removal scientifically tested and approved by chemists, physicians, and surgeons” (Parry, 1933B), p.145… Miranda p.. 72
Parry adds, ”These methods are not to be used by the tattooed themselves or by tattoo masters but by physicians or surgeons only. The list is compiled on the basis of chemical and medical literature dealing with tattooing and its removal” (Parry, 21933b, p. 146) Miranda p. 73 Miranda Forensic

Miranda Forensic
Forensic Analysis of Tattoos and Tattoo Inks, Michelle D. Miranda, State University of New
York at Farmingdale USA, CRC Press, Taylor & Francis Group, Boca Raton, Florida 2016
ISBN 978-1-4822-2146
George Burchett, Memoirs of a Tattooist, First Published 1958

"...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

You may say What's to do?

If we are prohibited from using our customary and normally used color pigment inks, proven safe and effective over time, in hundreds of millions of tattoos, by tens of thousands of tattooists for the last 30 years then we will do without colors altogether. We can do Black only.

I am suggesting that we reject using or purchasing their "easily removed" inks.
Hit them in their pocket. They incorrectly think we will pay them while they destroy the permanence of tattoo.

Wes Wood 9/12/23

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MoCRA - Pigments

Sun, 10 Sep 2023 06:48:19 GMT

MoCRA - Pigments
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Pigments

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 tattoo 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 reverse is true.

First quoteFrom: 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

__________________________________________________________

From CPMA
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.

__________________________________________________________

From
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.

____________________________________________________

From ETAD
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)
wes@unimaxsupply.com

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

05/27/2023

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

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