First Presentation

A1334-2015 Outline of Issues, September 1, 2015
Submitted and written by Westley Wood

The logic for this bill is as follows:
Only sterile ink is fit to use.
“Which is What has to be Proven” but not proven. (WisWhtbP:But Not)
Ink exposed to air more than once (using reservoir bottles) is unfit for use.
Not proven. (WiW)
Single use ink “packages” will only be exposed to air once.

THEREFORE (Conclusion):
Only single use packages of sterile ink are fit to use.
(These reasons do not support the conclusion.)

Using the same faulty logic, as soon as you open the single use ink package it becomes exposed to air and is now unfit for use. It is even worse because it is not closed or sealed but left open in the air.

Rebuttal Objections
1.  Peeling the seal off an ink cup exposing the ink to air does not cause it to be unfit for use. Is a needle unfit for use when opened?  Is the open cup of wash water unfit?
2.  Only tap water used to make ink or mixed into ink has been linked to infection.
NYC DOHMH went to the root of that problem and ruled that sterile water is to be used when mixing inks with water. NYC separated Fact from Fiction.
3.  Safe and effective usage over time is the universal principle to determine if something is safe to use or not. The current reservoir method is proved by usage over time as safe and effective. Usage trumps technical specs. Both non-sterile and sterile ink from reservoir bottles poured into single use ink cups is already the voluntary standard affirmed by Health Departments everywhere effectively protecting the health of the community from cross contamination. It works. There is no merit or advantage changing the method.

Non-sterile CUPS AND GLOVES are proven safe by usage.
Are not implicated as a source of infection. Their hot manufacture conditions produce a virtually sterile, accepted level of protection proven by safe usage over time (including in hospitals and medical settings) except in open-infection-prone procedures performed in special Operating Rooms.

COMPOUNDING INK and WASHES is proven safe by usage.
Tap water has been a source of infection when mixing or compounding ink from ingredients or making washes. This was acted upon by NYV DOHMH. Artist’s mixing pigments on the spot has never been implicated in causing infection. However, clients should be made aware when inks are not sterile. There is no evidence to support a prohibition of the long history of custom mixing ink, nor for the matter, making one's own needles.

COST IS A LEGITIMATE IMPORTANT FACTOR impacting the livelihoods of thousands.
The ink for a tattoo that now costs $0.35 to $0.50 per tattoo will now cost $5.00, $10.00 even $25.00 and more, using single use ink packages. This will directly harm tattooists. It will decrease business.

INVESTMENT LOSS
Tattooists have investments of thousands of dollars in ink and decades in working with many inks to find the mix that works best from them. These years of experience will be lost.
Industry suppliers have millions invested in ink made years in advance.

SINGLE USE IS A FAILED IDEA TRIED MANY TIMES
Single-use packages have been introduced many times, in twist opens, k-cup style, blister pack, vials, and all were rejected as unsuitable for professional tattooing. Those who are ready to supply single-use packages by December 2015 will distort the selection away from the inks used successfully to the detriment of the tattooist and the client. The optimum size package and method of dispensing will also take time to develop and implement.

Respectfully submitted:
Westley Wood, Lic. #40596680, Owner, Sacred Tattoo NYC and Unimax Supply Co.
 

"New New York Stat Law" BILL A1334-2015
REQUIRING
INDIVIDUAL-USE STERILE TATTOO INK PACKAGING

Of course this is upsetting because it will cost
ten to twenty times as much if single use "packages"
are required per tattoo and will do nothing
to reduce "infection rates",
the justification for the law.

The Tattoo Argument

The industry standard method:
using a main bottle and dispensing ink
into single-use cups is
PROVEN BY USAGE
Safe and Effective
PROVEN in millions and millions of tattoos
by tens of thousands of tattooists
for decades.

We encourage using Validated Sterile Ink.
The cost is not that much: $0.10 - $0.25 per bottle.
But it takes time and we expect the industry
itself will go that way, buy into it, without being compelled.