Single Use Packages of Ink    UPDATE of Meeting  FRIDAY SEPT  4, 2015

Another open independently-called meeting with another NY State Senator, Senator Phil Boyle of Long Island
at Cliff's Tattoo, Wednesday, Sept. 23, 2015 at 10:30AM  1445 Middle Country Road, Centereach, NY  631-732-1957
A meeting with NY State Senator David Carlucci,
Sponsor of A1334-2015 on Wed. Sept 3, 2015
held in Pearl River NY organized by Mick Metal, Revolution Tattoo Shop.
NY State Senator David Carlucci met with an ad-hoc group of tattooers, suppliers and ink manufacturers Wednesday September 3, 2015 and listened to their views of how Bill A1334-2015 did not meet the needs of professional tattooing. Senator Carlucci explained that the new law was developed with the Red Cross. Because he was not aware of the other issues brought up, as he goes forward input will be solicited proactively from those affected by the bill. He further explained that he will work on amending or correcting the wording in hopes of changes before the December 2015 effective date. by Wes Wood and Irving, Unimax Supply.

Unimax Unequivocally Supports SALES TO THE PROFESSION ONLY

You are free to use these arguments provided either Unimax or Wes Wood is attributed as the source for these ground breaking arguments.

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.
 

A Second Coloquial Presentation

"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.

 

Albany Bill A1334-2015 concerns infection.

It is
not true
that a previously opened bottle of sterile-or-not ink
is suddenly unfit for use by dint of opening and
dispensing ink because it is exposed to air.

If that were true... (which it is not)
 

... then, as you pour the ink into a cup
it becomes unfit for use, being exposed to air,
(worse, it is mixed with air).
Common air does not cause ink to be unfit for use.
Ink may no longer be "technically"
operating-room sterile for an infection-prone open wound,
but that is not tattoo. They share some similar concerns
but do not require the same response.
If the needles are opened, are they
then no longer fit for use?
Safe and effective usage over time proves our procedures are safe.
Nothing can trump safe and effective usage over time.
If single use packages are required, then tattoo requires a
HOSPITAL OPERATING ROOM.

Tattoo is not
OPEN-INFECTION-PRONE SURGERY.
Clients do not walk away with infections,
and we NEVER see yellow eyes.
The extreme standards for Operating Rooms
cannot be reasonably required for tattoo.

Cups and gloves must be discussed
to lay that argument to rest.
While technically not sterile they are manufactured
as virtually sterile from hot forming machines
and have never, never been implicated as a source
of infection, for the same reasons as air
has not been implicated
as a source of infection in tattoo.

The last issue concerns compounding ink from ingredients.

Validated-as-Sterile Sterile Ink, would be the ultimate for safety
(Ink that is consistently lot tested negative for growth).
Because there are isolated cases of non-sterile ink as a source of infection
it is not unreasonable to be transparent with the client
and ask for client approval before using formulated and non-sterile ink.
That is fair.
It is also reasonable to limit the storage life after opening
similar to other cosmetics, perhaps 12 months.

SENATOR CARLUCCI
finished his presentationby saying he would
notify health departments to delay implementation until legislative action can be implemented to change or amend the bill.
Simply re-interpreting the law as I suggested but not changing it might lead to problems of interpretation at a later date by different health departments. Good point.

There is one last point,
What happens to tattooist investment in ink?
Tattooists have thousands invested.
Suppliers have millions invested.
We are not simply going to throw this away
without proof of a clear and present danger to public health.

"Why the law?" was asked.
Senator Carlucci said Red Cross asked for the law and the sponsors  relied on Red Cross interpretations and understandings.
 


"Oh Great Omi, Patron Saint of Tattooists, Pray for us." 
Wes Wood

Comments can be sent to Wes Wood at unimaxsupply@gmail.com

Unimax Unequivocally Supports
SALES TO THE PROFESSION ONLY