KANBrief 4/20
EN 17169, Tattooing – Safe and hygienic practice, was published in spring 2020. Its content includes guidelines for tattooists, and also hygiene requirements. In its comments on the draft standard, the occupational safety and health lobby had stated that the standard’s focus must lie on the quality of the service and the safety of the customer, and not on the safety of the tattooist.
Since 2014, professional tattooists’ associations (notably the German association DOT e.V. and United European Tattoo Artists (UETA)) have been calling for the national codes in different countries to be merged into a European standard. A particular aspect of tattoo services is that at present, the profession may be conducted in Germany without any qualification or training having to be demonstrated. Tattooists need merely notify the authorities that they are conducting the trade. This was presumably also the reason for the need for essential requirements to be laid down, at least in a standard.
The EN 17169 draft standard, Tattooing – Safe and hygienic practice, was published in 2017. It not only contained specifications regarding the safety and health of customers, but at many points also regulated the safety and health of the tattooists. Drawing a clear distinction between the measures for the two target groups is often difficult: measures for customer safety may also provide protection for the tattooists. Examples are vaccination of the tattooists, and the use of gloves.
The focus of a service standard should lie upon the quality of the service and protection of the customer, and not upon requirements for the protection of employees, which may be governed differently from country to country. Accordingly, CEN Guide 15 also states that requirements relating to the safety and health of workers should not form part of service standards. KAN has commented on the draft standard in order to work towards deletion or rewording of the clauses concerned and addition of a national foreword referring to the OSH provisions and regulations applicable in Germany.
The standard was published in spring 2020 after much discussion. The scope still explicitly states that the standard sets out requirements and recommendations for hygienic and safe tattooing practices, in the interests of protecting both clients and tattooists against infection. A recently published national supplement to the standard makes explicit reference to the occupational safety and health arrangements in force in Germany for tattooing. It is anticipated that the next revision of the standard will incorporate this addition directly into the national foreword. Tattooists and employers will thus also be informed that compliance with the standard alone is not sufficient and that further OSH provisions must be observed in Germany (e.g. the ordinances on biological substances (BioStoffV), hazardous substances (GefStoffV), workplaces (ArbStättV) and preventive occupational medical care (ArbMedVV), the Infection Protection Act (IfSG), and hygiene ordinances of the regional authorities).
There is no doubt that the new standard can make tattooing safer for customers. It stipulates for example that customers must be given detailed verbal and written information before and after tattooing on the procedure, risks, possible complications and aftercare, and lays down requirements for the premises and for the cleaning and disinfection of equipment. The requirement for the consent form to contain information on the tattoo inks used is also a good measure. At the same time, it remains to be seen whether – as announced in the DIN press release accompanying publication of the standard – EN 17169 is suitable for use as a reference by the health authorities with respect to the inspection of tattoo studios.
The standard also has one or two curiosities: “smoking, e-cigarettes and other electronic nicotine delivery systems” and the “consumption of non-prescribed and illegal drugs or alcohol” are explicitly prohibited in the tattooing area.
Dr Anja Vomberg
vomberg@kan.de