Looking Fit 02/2004: STATE RADIATION GROUPS MEET TO BUILD TANNING STANDARDS

The Conference of Radiation Control Program Directors (CRCPD)—a national organization comprised of directors of the radiation control programs of each state— met in November to work on a revision of Draft Part BB, Recommended Regulations For Indoor Tanning Facilities. When approved, these recommendations will be a set of model regulations available to any state or local authority to use as a starting point for tanning rules.

The main purpose of the CRCPD, in existence since 1968, is to share knowledge freely among the states while setting national standards for both ionizing and non-ionizing radiation control.

Amy Sawyer, branch manager of the Division of Environmental Health, Radiation Protection Section, for North Carolina, chairs and coordinates the non-ionizing section of the CRCPD. Sawyer has compiled a group of regulatory and industry professionals to help draft a final version of the recommended regulations.

Oregon tanning official Phil Wilson participates as an active member.

The organization also recently added to its ranks two peer reviewers directly from the indoor tanning industry. Brad Kelly of Kelsun Distributors and Paul Germek of the Suntanning Association for Education joined the list of state and federal officials at the November CRCPD board of directors meeting. Other industry members participating in the organization as industry advisors include Joe Schuster of Light Sources and Rick Mattoon of the National Tanning Training Institute.

Having such a strong representation from the indoor tanning industry gives the industry a strong voice in the compilation of the suggested regulations.

The current draft for tanning facilities covers the following topics:

• BB.1 Purpose And Scope—This part provides for the registration of tanning facilities using ultraviolet lamps along with the regulation of the maintenance of tanning facilities.
• BB.2 Definitions—Part BB.2 currently lists 18 terms that are defined to give interested parties a consistent understanding of terminology used in the model of regulations.
• BB.3 Exemptions—This part exemplifies most agencies that use ultravioletemitting devices other than for the cosmetic tanning of human skin.
• BB.4 Application For Registration Of Tanning Facilities—This section gives specific guidelines for the registering of tanning devices prior to their use. It summarizes all pertinent information that must be made available to the interested state agency in the registration process. This section also asks the applicant to provide a copy of operating and safety procedures unique to the tanning facility’s operation.
• BB.5 Issuance Of Certificate Of Registration—This section simply gives the state the authority to issue a certificate of registration.

Other parts of the original draft include:

• BB.6 Expiration Of Certificate Of Registration;
• BB.7 Renewal Of Certificate Of Registration;
• BB.8 Report Of Changes;
• BB.9 Transfer Of Certificate Of Registration;
• BB.10 Approval Not Implied;
• BB.11 Denial, Suspension Or Revocation Of Certificate Registration;
• BB.12 Construction And Operation Of Tanning Facilities;
• BB.13 Enforcement Of Penalties;
• BB.14 Severability; and
• BB.15 Effective Date.

One of the biggest changes to the suggested regulations most likely will be a specific address of training requirements.

“In order for the indoor tanning industry to raise its level of professionalism in the eyes of the country while heading off anti-tanning groups, we must accept the fact that a set of national training guidelines must be drafted,” Mattoon says. “And, because members of the industry were invited to participate, onlookers must agree that the industry is doing its part in initiating this progress.”

As these recommendations move closer to the CRCPD’s Regulations Oversight Committee and Executive Board, the more than two dozen states that currently do not have regulations specific to indoor tanning will have a government- and industry suggested set of reasonable standards.

At this time, it is reported that about a half-dozen states actively are visiting the prospect of establishing and enacting regulations that will govern the indoor tanning industry.

“Because of this, the future of the industry will progress more favorably with reasonably established guidelines that help maintain the integrity of our industry while adhering to policies that ensure the wellbeing of the tanning public,” Mattoon says.

In the past, the U.S. Food and Drug Administration and other federal agencies have looked favorably on industries that work closely with the CRCPD in establishing industry-led guidelines. These guidelines have proved favorable to the industry at hand and the CRCPD’s goal of keeping a watchful eye over the control and standardization of all ionizing and non-ionizing radiation-emitting devices.