Is Tattooing an Injection? Evaluating the Mechanics of Ink Placement.
Guidance recently released by the Food and Drug Administration (FDA) regarding tattoo inks describes tattooing as an injection process, but is injection the correct terminology to use when describing tattooing? This perspective aims to provide a brief overview of the core mechanics and science behind injection and tattoo processes, as well as emphasize the importance of using the correct terminology when referencing tattoos and the act of tattooing moving forward. STATEMENT OF SIGNIFICANCE: Due to a change in the FDA regulatory framework around cosmetics in December 2022, for the first time the FDA is in the process of actively regulating tattoo inks. Central to how tattoos will be regulated is whether tattoos and tattooing should be considered an injectable process. If tattoos are injectables, then tattoo inks would be considered within a medical device framework leading to a radical alteration tattoo industry in the US and globally. This perspective surveys the literature to understand what it means for something to be "injected" and then compares that to the state-of-the-art understanding about how tattoos are deposited in the skin. Based on this analysis, it is clear that tattooing should not be described as an injection process.
- Research Article
- 10.3389/fpubh.2023.1279884
- Nov 10, 2023
- Frontiers in Public Health
In this study, we collected voluntary recall records of tattoo and permanent makeup ink from the U.S. Food and Drug Administration (US FDA) Enforcement Report Database. The recall records contain information, such as recall date, manufacturer, ink color, reason for recall, and the microorganisms detected from the ink samples. Between 2003 and 2021, a total of 15 voluntary tattoo ink recalls occurred in the U.S. market, involving over 200 tattoo inks marketed by 13 manufacturers and one distributor. Fourteen recalls were due to microbial contamination, and one recall was due to allergic reaction. As follow-up, a microbiological survey of 28 tattoo inks of new batches from seven manufacturers having products that were previously recalled was conducted. Aerobic plate count (APC) and enrichment culture methods based on the FDA’s Bacteriological Analytical Manual (BAM) were used to detect microbial contamination. The results revealed that six out of 28 tattoo inks were contaminated with bacteria and were produced by two manufacturers. The level of microbial contamination was less than 250 CFU/g in three of the tattoo inks and between 1 × 103 and 1 × 105 CFU/g in the other three inks. Eleven bacterial isolates were identified, including spore-forming Bacillus-related species and potentially pathogenic species. Overall, this study shows that some tattoo ink products produced by manufacturers with a recall history continue to be contaminated with microorganisms. This highlights the need for ongoing monitoring and quality control of such products.
- Research Article
38
- 10.1161/circoutcomes.114.001460
- Jan 1, 2015
- Circulation: Cardiovascular Quality and Outcomes
A recent Food and Drug Administration (FDA) proposal aims to speed the evaluation process for new high-risk medical devices that are intended to address unmet medical needs,1 much like existing expedited approval processes, such as the humanitarian device exemption rule for devices intended to treat rare diseases. Such programs are strongly supported by the medical device industry and some patient advocacy groups, which have criticized the FDA for being too stringent in its evidentiary requirements for investigational devices, leading to delays in the approval of potentially helpful products.2–4 For example, in 2011, the FDA approved a transcatheter aortic valve replacement system that demonstrated significant improvements over conventional treatment options for selected patients with severe aortic stenosis.5,6 However, the United States was the 43rd country to approve the device, roughly 4 years after the European Union.7 Yet expedited approval for high-risk medical devices raises the possibility that these devices will not be as effective as predicted in their limited premarket testing or that they could cause unanticipated harms after approval.8 Of course, well-studied devices may present unexpected safety concerns years after approval,9,10 and even the most rigorous conventional premarket approval process will result in some devices later found to be unsafe or ineffective.11–13 Safety of approved medical devices and the proper scope of premarket testing remain contentious issues after recalls of several widely used devices, including popular models of implantable cardioverter defibrillator leads14,15 and metal-on-metal hip implants.16 Inherent limitations in premarket testing, along with the prospect of lowered evidentiary standards for expedited device reviews, place greater pressures on postapproval monitoring of devices to follow clinical performance and to identify emerging public health problems. Medical device manufacturers routinely perform this sort of vigilance, …
- Front Matter
1
- 10.1038/jid.2011.38
- May 1, 2011
- Journal of Investigative Dermatology
Successful Investigational New Drug Preparation without Reinventing the Wheel
- Research Article
88
- 10.1016/j.jaci.2005.10.031
- Dec 29, 2005
- Journal of Allergy and Clinical Immunology
“Black box” 101: How the Food and Drug Administration evaluates, communicates, and manages drug benefit/risk
- Research Article
- 10.1016/j.annemergmed.2006.12.009
- Feb 1, 2007
- Annals of Emergency Medicine
The future of drug safety: What the IOM report may mean to the emergency department
- Research Article
- 10.23785/tu.2025.04.009
- Sep 1, 2025
- Therapeutische Umschau. Revue therapeutique
The growing popularity of tattoos highlights the importance of careful regulation of tattoo inks to minimise health risks. In Switzerland, tattoo inks are subject to strict legal requirements based on food legislation, which are designed to ensure that they are sterile and harmless. The European Union has significantly tightened restrictions on substances in tattoo inks through Regulation (EU) 2020/2081 in order to increase safety. In contrast, the USA regulate tattoo inks under the supervision of the Food and Drug Administration (FDA), but do not have specific pre-market controls for tattoo ink products. This comparison highlights different regulatory approaches in Switzerland, the EU and the USA and underlines the need for more harmonised global regulation to protect consumer health.
- News Article
11
- 10.1289/ehp.121-a126
- Apr 1, 2013
- Environmental Health Perspectives
British chef and food activist Jamie Oliver ignited a firestorm in January 2011 when he mentioned on the Late Show with David Letterman that castoreum, a substance used to augment some strawberry and vanilla flavorings, comes from what he described as “rendered beaver anal gland.”1 The next year, vegans were outraged to learn that Starbucks used cochineal extract, a color additive derived from insect shells, to dye their strawberry Frappuccino® drinks2 (eventually, the company decided to transition to lycopene, a pigment found in tomatoes3). Although substances like castoreum and cochineal extract may be long on the “yuck factor,”4 research has shown them to be perfectly safe for most people; strident opposition arose not from safety issues but from the ingredients’ origins. But these examples demonstrate that the public often lacks significant knowledge about the ingredients in foods and where they come from. This is not a new development; the public relationship to food additives has a long history of trust lost, regained, and in some cases lost again. The Federal Food, Drug, and Cosmetic (FD&C) Act of 19385 was passed shortly after the deaths of 100 people who took an untested new form of a popular drug, which contained what turned out to be a deadly additive.6 The new law was consumer oriented and intended to ensure that people knew what was in the products they bought, and that those products were safe. The law has been amended over the years in attempts to streamline and bring order to the sprawling task of assessing and categorizing the thousands of substances used in foods, drugs, and cosmetics. One result of this streamlining is that under current U.S. law, companies can add certain types of ingredients to foods without premarket approval from the thin-stretched Food and Drug Administration (FDA). In other words, there are substances in the food supply that are unknown to the FDA. In 2010 the Government Accountability Office (GAO) concluded that a “growing number of substances … may effectively be excluded from federal oversight.”7 Is this a problem? The answer depends on whom you ask.
- Research Article
2
- 10.1161/circulationaha.116.022137
- Aug 15, 2016
- Circulation
The US Food and Drug Administration (FDA) is a remarkable hybrid. Part regulatory agency, part public health agency, it sits at the intersection of science, law, and public policy. The FDA’s mission can be considered in the context of 2 broad dimensions: the products it regulates and its core functions. Both fall under the rubric of protecting and promoting the public health. The FDA’s remit is both broad and diverse: altogether, the agency has regulatory responsibility for >20% of the US economy. The products it is charged with overseeing through its various centers1 encompass food and cosmetics (regulated by the Center for Food Safety and Applied Nutrition); food and drugs for animals, including companion animals and animals used for food (regulated by the Center for Veterinary Medicine); and medical devices, drugs, and biologics (regulated by the Centers for Devices and Radiological Health, Drug Evaluation and Research, and Biologics Evaluation and Research, respectively). Tobacco products were added to the FDA’s portfolio by the Tobacco Control Act of 2009, and are overseen by the Center for Tobacco Products. Regardless of the specific product regulated, the FDA’s core mission remains the same: to protect the US population by helping to ensure the fundamental safety of the food Americans consume and the medical products prescribed by their clinicians. At the same time, this primary mission is complemented by a mandate to promote the public health by reviewing research and taking appropriate action on the marketing of regulated products in a timely manner. Not only do people need access to advances in nutrition and medical therapies, but also the American spirit is itself characterized by a strong current of scientific and technological innovation. At first glance, differences in these 2 priorities, protecting the public safety and promoting the public health through encouraging innovation, might …
- Research Article
77
- 10.1111/j.1524-4725.2011.02202.x
- Nov 2, 2011
- Dermatologic Surgery
A rise in popularity of cosmetic tattoos has led to an increase in adverse reactions. Due to more pressing concerns, the Food and Drug Administration (FDA) has not traditionally enforced its authority over tattoo inks. To raise awareness of the dangers of cosmetic tattoos. We reviewed FDA policies regarding tattoo ink, different ink components, adverse reactions, and various treatment options for cosmetic tattoo removal. An increase in consumer complaints has prompted FDA investigation into tattoo inks and their safety. It is important that further complications be reported to the FDA to promote regulation of cosmetic tattoo inks.
- Research Article
34
- 10.1016/j.jvs.2013.06.059
- Aug 22, 2013
- Journal of Vascular Surgery
Reporting standards for adverse events after medical device use in the peripheral vascular system
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24
- 10.1016/j.jvs.2012.11.043
- Mar 1, 2013
- Journal of Vascular Surgery
A surgeon’s perspective regarding the regulatory, compliance, and legal issues involved with physician-modified devices
- Front Matter
4
- 10.1016/s0140-6736(05)17994-x
- Feb 1, 2005
- The Lancet
Safety concerns at the FDA
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1
- 10.1016/j.jand.2016.03.023
- May 25, 2016
- Journal of the Academy of Nutrition and Dietetics
What’s the Latest on Acrylamide?
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2
- 10.1002/cpdd.374
- Jul 24, 2017
- Clinical pharmacology in drug development
Theranos Experience Exposes Weaknesses in FDA Regulatory Discretion.
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6
- 10.1097/00000542-199903000-00032
- Mar 1, 1999
- Anesthesiology
FDA's role in anesthetic drug development.
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