Where Do We Go From Here?

Where Do We Go From Here?

by Donald L. Smith

Over the next few months, Donald L. Smith will attempt to review and analyze where the indoor tanning industry stands regarding the current or anticipated activities of the various regulatory agencies in Washington.

The Food And Drug Administration

In this issue, Smith will cover two of the responses to the FDA's ANPRM that were filed by organizations not known to be friendly to the indoor tanning industry.

The first is the response filed by The American Academy of Dermatology (AAD). The response was filed by Darrell Rigel, M.D., president of the AAD. "The AAD firmly opposes indoor tanning and continues its longstanding support of a ban on the production and sale of indoor tanning equipment for non-medical purposes," says Rigel. "The AAD also is greatly concerned that some tanning facilities are making health claims about their devices, including posting reports from tanning industry magazines that claim tanning reduces the risk of skin cancer, internal cancers and osteoporosis."

Obviously, the articles that Rigel refers to were first published in medical journals and then summarized by tanning industry magazines. Sadly, the only conclusion one can reach after reading the AAD response is that they don't have any idea what the indoor tanning industry is about and they have no real evidence to show that the risk of tanning outweighs the benefits.

The Skin Cancer Foundation

The report by The Skin Cancer Foundation was made up of 26 companies primarily involved in the sunscreen market and written by James M. Spencer, M.D. and Rex A. Amonett, M.D., who have written several articles in disagreement with indoor tanning. Surprisingly, they rejected out-of-hand the concept that vitamin D might play a role in the prevention of disease notwithstanding the fact that those suggesting otherwise have equal or better medical credentials than do Spencer and Amonett.

The response filed by The Skin Cancer Foundation stated that, "Over the last 50 years there has been a remarkable increase in the incidence of skin cancer and certainly intentional cosmetic tanning is a factor." Unfortunately, the authors do not seem to realize that the indoor tanning industry only has been in existence in the United States for less than 20 years and, therefore could not reasonably be blamed for an increase that started more than 30 years before it existed.

Another indication that the dermatology community doesn't understand tanning is shown by the statement that, "Patrons must be informed that skin phototypes I and II, those who always sunburn and never tan or who sunburn first and later tan following sun exposure, can expect the same outcome from indoor tanning." Those in the indoor tanning industry understand that the whole concept of controlled exposure to UVR is to develop facultative pigmentation (a tan) and not experience the pain of sunburn.

In addition, there were several responses from various state regulatory agencies and almost all of them recommended adopting a 48-hour period between tanning sessions without any consideration given to the phototype or subtype of the individual. This appears to be a "concerted effort" and the tanning industry should expect this issue raised again in regulated states.

Summation

Nothing has happened to change the fact that I believe that the FDA would like the indoor tanning industry to agree to voluntarily self-regulate. In addition, I believe that the FDA would consider it a positive signal if the indoor tanning industry would agree to work with them to develop a comprehensive client education program covering the benefits and risks of tanning. However, if the indoor tanning industry does nothing, regulations will be made and the industry may be adversely affected by them.

Donald L. Smith is the owner of Tucson, Ariz.-based Ultraviolet Medical Systems and has worked with the medical society for more than 20 years. In addition, Smith and his wife, Pat Reykdal, own three indoor tanning salons in Tucson. Anyone in search of more information concerning state or federal regulator activities may e-mail Smith at Reyksmith@aol.com or contact the FDA at (301) 443-7179.