As a tattooist of 25 yrs and one of the people who helped on the fact finding for the regulations I feel I must STRONGLY object to the idea of turning tattooing and piercing apprenticeships over to a “school”.  Learning the crafts of tattooing and body piercing is not a time set event, the amount of knowledge and information gained in the one on one experience of apprentice and master is not replaceable by a classroom setting.   What you are, to all appearances trying to do is create a climate of low standards for licensure that you already fail to enforce.   I see ads everyday on Craigslist and even a guy driving around in a pickup offering tattoos out of a house, unlicensed, and you do nothing.   You have also changed the testing center for tattooing and made it almost impossible for people to get in touch with anyone regarding the test.   Essentially what you are trying to do is remove yourselves from responsibility for this.  You have never wanted to deal with tatttoing and piercing and know nothing about it, you wish to encourage these “schools” in part so someone can make money and in part so you no longer have to deal with it.   This will cause an increased risk in health and safety to the public.  It simply will because without the one on one educational process of tattooing and piercing how can you possible say that a person is trained?  Hair grows back, so a botched haircut is easily repaired, you also have a very minimal risk of infection and disease with most other trades represented by the board who operate in a “school”  both tattooing and piercing to have that risk and no matter what you have seen on TV there is no way for the sterile practices required to tattoo or pierce safety to be drilled into a individual to the point of muscle memory without that one on one experience.  How you ask?  Ask an apprentice how often they set up our work stations before they are ever allowed to touch a person.  This one on one critique of their set up is How they learn that process, it is how it becomes memory.  You can NOT get this in a classroom.   You are also going to create a means for people with no experience other then “school” to suddenly open a shop legally, this would also create ANOTHER influx of shops.  Shops owned and operated by individuals with no real world experience in tattoing or piercing, and again I point out the overal cost to the public between a bad tattoo and a bad haircut.  If you do this, it will directly effect not only the legally operating shops, but also the health and safety of the public, all because you would prefer a simple answer and let someone make money by owning a school, so you didn’t have to deal with it.

Tattoo artists have trained their own apprentices for hundreds of years, turning tattooing, which is an art, into a school would destroy the art.

Please do not do this to our artists and future artists. I am not a tattoist, but am tattooed.  I want my artists trained in the traditional manner.

1. I completely agree with Robert Knox. This industry is NOT made to be taught in school. Some of my apprentices I have kept for two years to ensure they are taught every single detail so as not to harm someone. the teaching process is crucial to this industry and we are trying to move forward not backwards. A school would completely destroy what we have worked for to improve the image of the industry. A teacher with multiple students wont be able to catch cross- contamination every time, where as a sponsor only has one or two people to watch will catch everything almost everytime. 

2. The Test for tattooing and body piercing needs to be updated.

3. As for the DOLI takeover: Getting a license is a lengthy process as it is now and communication is horrible. It takes nearly three months to get a license after the apprenticeship is complete... thats rediculous, so is the excuse "we have lost your paperwork"... everytime. With this being said, the switch to have DOLI as the department to oversee may not be a bad thing... if results are faster that would be nice. Dpor is understaffed, if this speeds up the process through which apprentices and sponsors only answer to I think the rest of the community would appreciate a more effecient system. 

The Tattooing and Body Piericing community is HUGE in culture. Apprenticeships are given to those who DESERVE to be a part of our industry NOT just anyone who wants in.Changing the policy to allow for ANYONE to become a Tattooer or Piercer is going to hurt our industry NOT make it better. Apprenticeships are not and never have been "cookie cut"  each one is special.. and unique in its own way, trying to force regulate for "standardized" is not goingto help ... We all pride ourselves on our ways of doing things, always different from the next with the same Beautiful outcome . Tattoo schools.. BodY piercing Schools...or whatever they will be called do not need to exist..  NO ONE in this industry is in a hurry to add more fish to the pond TRUST ME.. Which is why it is so selective . and personal.. Tattooing can not be taught in a classroom, andcan not be taught by anyone who isnt a tattooer . APPRENTICSHIPS ARE SACRED ....  please do not impead on them 

I am a 3 year apprentice..1 .5 year tattooer. I   think that apprenticeships are sacred, we are the first line of defence against who gets into our industry. Its generations of knowlege that is being passed down and it is importatnt fo new apprentices to understand and appreciate the culture that goes into what we do.NOT everyone can do what we do. Not everone learns at the same pace.. Not every situation is the same.. apprenticeships should be spent side by side with your mentor, in the shop AND OUT. its a relationship you build with the people that are giving you their knowledge.Learning in a shop enviorment is imperitive to this job. there are millionsof situatons you need to be prepared for and that preperation can only come from learning someone elses experiances .. we push eachother to grow,. help eachother learn and keep our industry thriving . it seems youre tryin to take away what makes this industry so special  and  THAT IS NOT COOL  

tattooing has to be learned in the shop. By changing anything with the apprenticeship process it takes away something that is special about tattooing. You should have to be chosen to be part of this industry. Plus any other way does not prepare you for the reality of working in a shop. Its also going to open the flood gates for many who do not belong and take money away from those who dedicated there life to this craft. Just sounds like some people trying to cash in any way they can being an outsider. 

Tattoo schools is a scam, people that "graduate"will never become good tattooers because they will  be not get taught the proper way to speak with customers, learn the correct way to tattoo, shop etiquette, etc. They will spoil time, money, as well as produce many bad tattoos and possible scarring, infection, etc. It is an all around bad idea to have tattoo schools

Re: 18 VAC 41-50-110 Tattooing Instructor Certificate and 18 VAC 41-50-120 Permanent Cosmetic Tattooing Instructor Certificate                To align instructor requirement with other professions regulated by the Board to include general requirements noted in 18 VAC 41-20-100, for Cosmetologist, Barber and Nail Instructors.

Hours of instruction and performance.  Reduce hours (750) - VAC 41-50-280 requirements to align tattoo with hours (90) of permanent cosmetic tattooing (18 VAC 41-50-370).

       I am currently about a year in to my body piercing apprenticeship. I absolutely feel like I could not learn the amount that I am learning if I was limited to being in a classroom. Being in the shop under my mentor gives me the opportunity to have one on one teaching. If I was in a classroom with approximately 20 other students I would be limited on what I could learn. Being out of a shop enviorment is going to prolong my apprenticeship because I will not be getting in shop experience. Tattoo schools are a terrible idea, the industry is old and its traditions are sacred. It should all be left the way that it is.

NO TO TATTOO AND PIERCING SCHOOLS

All the laws that have been imposed on us as tattooers have not made tattooing any safer or better for the general public.  They have put a monetary burden on us, and forced us to spend lots of time complying to these seemingly arbitrary regulations. There is absolutely no enforcement of the laws we currently have- which means that only the tattooers who are trying to abide by the laws are affected in any way.  Tattooers know their craft better than anybody on some board could ever know.  The more the apprenticeship process is taken away from tattooers, the worse the outcome will be.

Why woud any self-respecting, or competent tattooer take the time to teach their craft to anybody who can cough up some cash?  Those who can- do, and those who cant try to legislate their way into getting a slice of our pie.

I imagine a future where every Piercing  Kiosk in every mall(not subject to the same piercing standards as tattoo shops) will have a state trained non-capable tattooer sitting there handing out hepatitis to the unsuspecting public who falsely assume that because there is a state issued license that the person tattooing knows what they are doing. They will buy their way in. There will be bloody bandages piling up in the food courts of malls everywhere.  

No to tattoo/piercing  schools. 

Good morning, I am a licensed professional tattooer of 23 years and shop owner in Virginia Beach for 7 years...I am writing to get some clarity on the proposed changes to tattooing codes, as regulated by the board or barbers and cosmetology, through the DPOR...

What is the specific nature of the proposed changes to the tattooer codes?

What does it mean to potentially have tattoo apprenticeships going through the DOLI, and how will that change the standards that currently exist?

...if you’re talking about and thinking of changing the regulations so that tattoo apprenticeships will be taken out of the tattoo studios, and put them inside a classroom, within the legislation of the DOLI AND DPOR, taught by instructors that do not have real qualifications and substantial experience, as a professional tattooers, then I completely disagree...and think that it’s not only an insult to tattooing, and degrading to professional tattooers, and even potential apprentices...tattooing is a tradition, a lifestyle, and a skill that has been handed down generation by generation, from mentors to deserving apprentices...the only way to properly learn the sacred craft of tattoo, is to earn it in a tattoo shop environment.

When will this meeting be, where, and how can I attend, so I can hear and be heard?

Thank you for your time and help in understanding what is going on here.

Gabriel Cece

I would like to suggest that the Board consider changing the amount of years to be a sponsor to an apprentice change from five years to a more reasonable number, like 3. The current inkmasters on Spike TV had only 5 years of experience, and she’s one of the best in the world. Five years is way over what it should be, as there are a lot of people ready to sponsor another person after being licensed for fewer years. Also, I know many old timer tattoo artists that don’t come to Virginia because we have overly strict licensing policies. There are some states that don’t even require a license, and to come to Virginia, those old school artists would have to “complete an apprenticeship” under a Virginia artist, which many find to be demeaning since they have been tattooing for so long professionally. 

I strongly object to the idea of a school for tattooing for a number of reasons. Tattooing is more than just another profession. Because of the immense amount of knowledge that’s required to make a capable tattooer, there’s no realistic way an instructor will be able to provide what’s necessary for an apprentice to graduate and be ready for a shop environment. A real apprenticeship requires a high degree of commitment from the mentor and apprentice. There is no substitute for the one-on-one experience of mentor/apprentice. Seasoned tattooers would still have to dedicate time for teaching a tattoo school graduate. Furthermore, tattooing is not for everyone, and much of the deeper knowledge should not be given to anyone just because he/she has the money. I guarantee any instructor won’t come close to possessing the knowledge a seasoned, respected tattooer has to give to an apprentice. Because of this, schools will only flood tattooing with more hacks, and will increase the risk to the public.

 Im a tattoo Artist with 19+ years Experience. Our business was started by my grandfather in the 1920s, He tattooed for 60 years, Aprenticing and Passing it on to my father who tattooed for 35 years, who in turn apprenticed and passed it on to me and my sisters. Tattooing has been our family tradition and business for a VERY LONG TIME, we hope to teach our own children when they reach working age. Changing the way apprenticeships are done is extremely upsetting, and  DESTRUCTIVE  to our Family Traditions and also to this entire INDUSTRY.  You will flood a stable market with Sub-Par Artists which there isnt enough room for.  Youll create more PROBLEMS than solutions for yourselves and established artists.  Instead of making things harder on those of us who follow the rules, your agency needs to Focus on Indentifying and PENALIZING the BOOTLEGGERS who are tattooing dangerously, messing people up, not paying fees and not being taxed.  I suggest you enact some laws to deal with them and some sort of TIPLINE to help catch and punish the ones that you cant find blatantly and obviously posting on social media.  Please Take these words into deep consideration. Thank you for your time.

From what I gather, this ammendment is an attempt to make it so that future apprenticeships are to be conducted soley through DOLI. If this is correct then I am AGAINST this proposal. The skills necessary to be a good tattooer are not learned in a classroom with anyone other than a professional tattooist. No one is even cracking down on the thousands of people blatantly advertising "cheap tatz" on Facebook, who are not only doing horrible tattoos, but giving people infections and diseases. I feel this regulation would encourage said kitchen wizards the freedom to get a nice little certificate that states they went to a class for tattooing trying to add to their credibility and thus continuing the filth they were already spreading.

Tattooing is something we, as artists, take very seriously so getting an apprenticeship should be a process left to the professionals. Apprentices need to be guided and that one-on-one attention is the only right way to get it done, in my opinion.

We appreciate the opportunity to discuss the current regulations and speak with you about how we can be beneficial to your efforts to better the tattoo industry. We would like to work together with you in these matters so that our voice can be heard.

The apprenticeship is a time honored tradition which connects our future with our past. We seek to preserve those traditions, while incorporating modern techniques and aseptic practices. Why not offer an enhanced apprenticeship training program which offers opportunities for hands-on-in-studio-learning as well providing classroom support, online learning and multimedia resource libraries?

Perhaps we could form a council or committee to ensure the members of our industry have an equal opportunity to be heard, This council could be comprised of professional tattooers and piercers from licensed studios across the Commonwealth as well as members of our regulatory bodies. This council's goal would be to create practical and efficient apprenticeship regulations while respecting the traditions of our tattoo industry.

To allow ample time for discussion, implementation and review could we request a 90 day moratorium on any new regulatory changes with regards to tattooing in the state of Virginia until adequate representation can be established.

It is our hope that with patience and communication we can provide quality training to the future of our industry while preserving the traditions of our past.

 We look forward to speaking with you further in regards to these matters and appreciate the opportunity to offer our experience as a resource in shaping the future of our industry.

Best Regards,

David Zobel,

Cary Street Tattoo

It seems like this amendment is intended to create the infamous "tattoo school" and I'd like to add to my fellow tattoo artists that this is not in the best interest of the public. It may feel to the average person as if tattooing is something like barbering or working in a salon, but it is indeed so much more intricate than that. Tattooing cannot be taught from a book. And part of the reason as to why that is, is because each client is so vastly different. Let's just for a moment ignore the actual art and talent required to perform a tattoo properly and just take into consideration the various skins that exist in this world, and no, I'm not talking about black vs. white you racist (jk) I'm talking about skin type. Something, that I don't have enough characters to explain to you, what you really need, in order to understand what I'm talking about, is time. You need time in a tattoo shop, something that a tattoo school can't provide. You can pull up manequins and dead pigs, but you can't simulate a tattoo shop, because you couldnt possibly simulate the diversity of clientelle. As an apprentice at a tattoo shop, you are offered that opportunity to observe and learn from every client that walks through the door, not just willing donors. Which brings up another significant downfall to tattoo schools: your teacher to student ratio. In a shop, there's one student, per, however many tattoo artists work in that shop, whereas, in a school, you have one teacher per however many students paid for the class. A tattoo apprenticeship needs to be tailored to the individual, much like a suit I'll never be able to afford, you can't teach from the lesson plan if someone is a year ahead of the program, much like you can't jump ahead to tattooing when someone can't draw a straight line perfectly. Much like public education, it would only hinder the students who are ripe to succeed, and push ahead students who need more time to thrive. So let's say, you make a "tattoo artist", then what? You just let them out into the world? With their blood born pathorgens and their CPR certification and their "Lisence to tattoo"? And who hires them? or do they work out of their house? I mean, don't get me wrong, I make good money off of coverups, but guess what? COVERUPS ARE HARD! And it's not fun to do. Do it right the first time right? Which is why, you need to stop DPOL from being able to make and run tattoo schools. Don't ruin these poor kids future by stealing their money and not giving them a proper education. DPOL cannot provide the proper environment required to learn tattooing. As far as piercing goes though, who cares, they just stab people, do whatever you want with them. 

I am an "apprentice" of 1.5 years and an artist of 5 years and I must say I am nervous about just what all this means for those of us who aren't licensed yet, and are in the middle of our apprencticeships. Will the time we put into getting our licenses not mean anything, all of the sudden? Will the amount of hours we put in, go towards a damn 'tattoo school'? Would we have to go to the school just to get a license or could we continue with our apprenticeships? I couldn't find these answers so I'm hoping this will get cleared up. And as for tattoo schools, I completely agree with all the other artists against them. It's a waste of time and students' money and should be learned through hard work. You CANNOT learn to tattoo from a book, nor someone who isn't a tattoo artist. And not even all tattoo artists know what they are doing. So that's even slimmer odds of finding a good tattooer to give up their job just to attempt to teach a bunch of kids this craft that takes years to get decent at. The only thing a tattoo school would mean is more money for the pockets of those in charge of everything.