NEHA Annex to the Body Art Model Code, 3rd Edition

Analysis Regulation of microblading varies widely across the country. While the Food and Drug Administration (FDA) can investigate and act to prevent consumer injury after a public health issue is identified, there is no federal oversight for cosmetic or traditional tattooing. Instead, states and other local jurisdictions are largely responsible for regulating tattooing and permanent makeup industries (FDA, 2017). Health regulators in various states have taken dissimilar views on microblading with some considering severe restrictions to the practice and others believing microblading should be exempt from existing tattoo regulations. Lawmakers in Missouri, with support of permanent makeup technicians, recently put forth a bill that would redefine tattooing in the state to include microblading and other types of permanent makeup procedures (“Lack of Regulations,” 2017). Additionally, the Georgia Department of Public Health recently issued a press release stating that under Georgia law, microblading is considered tattooing and can only be performed in a licensed tattoo studio (Hokanson, 2017). Similarly, the Oklahoma State Department of Health specifies that any procedure that affects more than the dead layer of skin cannot be performed by a cosmetology licensed individual (Oklahoma Secretary of State, 2017). Many other states including Idaho, Maryland, and Wyoming, however, do not reference microblading in their regulations (Mercer, 2017). Microblading is often referred to as semipermanent, a term that has created confusion and has cast doubt on whether the practice should be regulated more like traditional tattoos. The shifting use of technologies has also made it difficult for regulators to keep up with the specifics of the practice (Darby & Darby, 2016b). Due to widely varying regulations and underreporting, well‐documented data on microblading procedure complications are lacking. Nonetheless, adverse reactions that vary from mild to severe have been documented after undergoing microblading procedures. In 2003 and 2004, FDA reported more than 150 adverse reactions from certain permanent makeup ink pigment. Additionally, FDA received numerous reports in 2012 of contaminated inks resulting in widespread infection, leading FDA to issue a warning for cosmetic tattooing nationwide (FDA, 2017). Powdered inks sometimes used in microblading can be mixed with contaminated water or alcohol solutions. Some inks, often advertised as organic or natural, are known to turn from black to blue or green. The spreading out of pigment has also been reported in select cases of eyebrow and cosmetic tattooing, causing unsatisfactory and often permanent physical scarring (Lee, Ahn, Choi, Whang, & Lee, 2001). Other complications that can occur from eyebrow tattooing include reactions resulting in noninfectious or infectious granulomas (raised and reddened tissue) that can spread beyond the tattooed area (Greywal & Cohen, 2016; Ro & Lee, 1991). Granuloma reactions can occur regularly and without warning. Previous skin tattoos in other areas have not been shown to predict or influence the likelihood of a reaction following cosmetic eyebrow tattoos (Cunningham & Feighery, 2015). Additionally, a previous history of drug allergies or medication offers no insight into whether granulomas will develop. Granuloma reactions can take months to resolve and often require extensive treatment with steroids or varying antibiotics (Martín et al., 2007; Sim et al., 2010). Cases can also take months or even years to present themselves, and can appear after repeat procedures (Guerra, Chavez, Welsh, & Welsh, 2016).

Furthermore, eyebrow tattooing has resulted in multiple cases of sarcoidosis, a granulomatous disease that can involve multiple organs including the lungs, eyes, nerves, and skin (Mirzaei,

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