Tanning Lamp Care

Understanding tanning lamp mechanics is of utmost importance for proper maintenance and care. And although lamps may seem simple to order and replace, they are complex components that figure heavily into the overall tanning process.

Each lamp manufacturer has its own definition of useful life for its product, and each tanning salon has its own set of operating conditions. Although both these points are not very helpful in answering the question of when you should replace your lamps, there are some guidelines that can help determine the right point in time.

It seems that the best and most reliable means of determining when lamps should be replaced is through the correct use of a UV meter. The basic rule is when the output level has dropped to 70 percent to 75 percent of what it was when the lamps were new, the lamps should be replaced.

It is generally during the first 100 hours of operation that sunlamps show the highest decline in their output performance. For this reason, some manufacturers define their lamps nominal output performance after 100 hours of operating.

The drop in power between zero and 100 hours can amount to about 10 percent to 20 percent, depending on the properties of the phosphor used inside the lamp. Most of the published maintenance curves were obtained with "free burning" lamps under optimal operating conditions. Therefore, the actual decline in the output of lamps in tanning beds often differs significantly when taken from the salon environment.

The measurement of UVA (or total UV) irradiance is often part of a daily routine for indoor tanning salon operators. For reasons of practicality and cost, the UVA measuring instrument preferred for this purpose is generally the pocket-sized type.

We all understand that the UVA reading plays an important part in deciding when to replace tanning lamps. For financial reasons and customer satisfaction, there should be the best possible assurance that the salon owner can depend on the readout from his or her UV meter.

A UVA meter can be a great tool when used properly; however, all too often salon owners think it is an exact measurement for output, but instead it is relative. If salon owners choose to rely on the UV meter then they should be sure to follow the same format for measuring output including:

• Take an initial reading upon the installation of new lamps.

• Make sure the measuring conditions always are kept the same. Measure at the same location of your tanning unit, at the same distance, observe the same electrical conditions for each single measurement.

• Make sure that the acrylics and reflectors are clean. It is imperative that acrylics are changed according to the manufacturer’s specifications.

• Wait with your measurement until your tanning unit is in a state of thermal equilibrium, which takes about five to 10 minutes after turning it on.

If these steps are carried out, measurement readings for comparative purposes will be obtained. Pocket-sized meters are used to measure a variety of UV bandwidths. Even if your meter only registers UVA levels, it can be assumed that the UVB values will diminish by approximately the same relative amount.

You can check individual lamps at the acrylic, or take an average body reading in the middle of the bed. Body position is generally considered to be 25 cm above the bench, with meter pointed up at the closed canopy.

Accuracy Of Measurements

In general, the accuracy of UV readings on digital displays is sometimes overestimated. Renowned universities consider an absolute accuracy of between 5 percent and 10 percent as very good. Therefore, for some low-cost UV meters that operate under much less controlled conditions, considerably greater measuring errors could be expected.

For example, it is known that with some low-cost UV meters, the readings for one and the same radiation source differ by up to 20 percent to 30 percent between identical products from the same manufacturer.

Some manufacturers of UV meters do provide calibration accuracy of plus or minus 5 percent to 10 percent reference NIST traceability, so it’s important to look for that specification to minimize error potential.

UVB Measurement

It is more difficult for a hand-held meter to isolate the UVB bandwidth (280-320 nm) from the total UV bandwidth (280-400 nm). Hence UVB measurement can be more problematic. And since the primary purpose of using a UV meter is to tell the salon owner when to replace his or her lamps, the measurement of UVB values is not necessary for that purpose because UVA and UVB irradiance drop by about the same relative amount.

However, a very important usage of a UVB meter is to check acrylic transmission. Solarized and aged acrylic blocks a significant amount of UVB, while allowing most UVA to transmit through it. Only a UVB meter that has a selective 280-320 nm filter can display this problem. Another usage for a UVB meter is to divide the reading by UVA value and obtain an estimation of percent UVB.

Lamp Output

When examining the output performance of a lamp, as a rule, about 20 percent to 25 percent of the electrical input will be emitted as ultraviolet radiation. Yet, this only is true for new lamps that are in optimal operating conditions—meaning that the electrical conditions such as supplied voltage, lamp current and wattage meet the specifications of the lamp manufacturer.

Ballasts and starters—if used—also play an important role. The two major factors responsible for the actual performance of a tanning unit are the aging of the lamps over time and equipment characteristics of the tanning unit.

Any radiation source loses a certain degree of power the longer it is in operation. For example, the reduction in power hardly is noticed in the general lighting of private households. In general, incandescent or fluorescent lamps are not replaced until they stop functioning.

Unfortunately, this is not as simple with the UV lamps used for indoor tanning. Tanning units are expected to meet certain requirements with respect to their tanning effectiveness over a given period of time. With increased use, they are no longer able to meet such expectations because of a marked performance decline, even though they are still in full working order from an electrical point of view. With tanning lamps, the recommended useful life is considerably shorter than the electrical life.

Normally, manufacturers give recommendations on the useful life of their lamps, but these recommendations only can be used as a guide because there is no clear and official definition of the term useful life. Each manufacturer can make its own definition. Additionally, different operating conditions, as well as equipment-related factors, have in certain cases a considerable effect on the actual useful life of a tanning lamp.

Although both of these points are not very helpful in answering the question, "When should lamps be replaced?", there are some guidelines which help determine the right point in time.

Measuring Different Types Of Lamps

Experience has proven that measuring different types of sunlamps with a UVA or total UV meter usually proves problematic in practice. The deviation of the UV meter from the actual measured value varies from spectrum to spectrum. As a rule, UVA readings obtained on different types of lamps are not comparable for effectiveness.

If lamp (A) shows a reading of 20 mW/cm, and lamp (B) shows 15 mW/cm, this does not generally mean that lamp (B) has a 25 percent lower effectiveness. If there is a clear distinction between the spectral characteristics of both lamps, it is perfectly possible that lamp (B) has higher UVB with lower UVA and tans in a lower session time.

That is because the irradiance readings from UVA and UVB meters are unweighted and do not correlate to the erythemal action spectrum (EAS). The EAS weights 297 nm and below very high, and 298 out to 400 nm progressively lower.

For measuring different types of lamps’ erythemal effectiveness, an MED/hr meter must be used. If its sensor response curve accurately follows EAS weighting, it will yield EAS in much the same manner as spectroradiometers do for FDA determination of Te maximum timer interval of (4) MEDs (minimum erythemal doseage).

This information is intended to emphasize the fact that low-cost, pocket-size UV meters are suitable for a variety of distinct purposes, depending on their specific response.

• UVA (or total UV): Relative measurements for lamp aging.

• UVB: Acrylic transmission and percentage of UVB.

• MED: Erythemally weighted effectiveness.

Salon owners should not rely solely on customer response regarding the output of the lamps, due to the many and varied skin types and base tan levels. They should follow a typical lamp maintenance and replacement routine in order to provide their customers with consistent tans year-round.

Compatibility

The subject of lamp compatibility, substantial equivalency and recommended relamping procedures poses several concerns for responsible salon owners and operators who are tying to conduct business within the guidelines established by the FDA, local authorities and the original equipment manufacturers. The following is a brief overview that should be reviewed by all your employees.

It generally is agreed that tanning lamps should be replaced when their output drops below 65 percent to 70 percent of the level when they were new. In operating time, this is generally between 700 and 1,000 hours, although some longer maintenance models may last as long as 1,500 hours with
proper care.

When approaching this procedure, the obvious first question is, what can be used for replacement? The physical dimensions of a lamp obviously could preclude its use in certain units. A 72-inch lamp obviously will not fit into a unit designed to use 59-inch lamps. And the voltage requirements of a lamp must match the tanning unit’s output. However, there are other factors that might make a lamp good for one tanning bed and incorrect for another.

One basic factor is the connector type. Tanning lamps are available in either Recessed Double Contact (RDC) or Bi-pin configurations. The bi-pin lamp has two pins protruding in a side-by-side arrangement on each end; the RDC type of lamp has two contacts on each end housed in a plastic post. The two types are not interchangeable.

Also, distinctly different types of lamps, including standard low-pressure, RUVA and VHO lamps are not interchangeable. Different lamp types have individual operating requirements determined by their particular design. For example, RUVA lamps have a reflecting panel built into the lamp itself, eliminating the need for external reflectors in the tanning unit. This means there is a distinct front and back to the lamp, as the reflective panel must face toward the tanner. Tanning units that use this type of lamp generally place them closer together than do those using traditional lamps.

Both RUVA and VHO lamps also generate more heat than normal low-pressure lamps, making a more powerful cooling system within the tanning unit necessary. To summarize, lamps of any design should be used only in equipment that is designed
for them.

Revisions to the FDA regulations bearing on tanning products fortunately take much of the guesswork out of choosing replacement lamps. To be compliant, a replacement lamp must be plus or minus 10 percent the erythemegenic and melanogenic output of the original lamp. It does not attend to the maintenance value or type of tan given by the original lamp. Since the procedures and testing necessary to satisfy the regulations are beyond the capabilities of almost any salon, primary determination of whether a replacement lamp is compatible is the responsibility of the lamp manufacturer.

Once the compatibility is established, the FDA requires the lamp manufacturer to print somewhere on the lamp or its packaging the specific lamp models that the new lamp is designed to replace. If the labeling doesn’t say that the lamp is a direct replacement for a specific lamp, odds are it is not. It is important to remember that just because a lamp physically may fit into a tanning unit, it is not necessarily designed for use in that unit.

Salon owners should be aware than an FDA inspector or state regulator may visit their salon without notice. If the original lamp or an FDA compatible lamp is not being used in the tanning unit, they may prevent the salon owner from using the equipment unit it is in compliance.

Additionally, lamp manufacturers are required to file appropriate paperwork with the FDA for its replacement lamp products. Salon owners should have all the necessary paperwork on hand to show that the lamps are compatible.

The following has been excerpted from an FDA-published document, Sunlamp Products Performance Standard, and is presented as general information for the suntanning device owner or operator:

Possible Amendments

On Feb. 10, 1999 the FDA announced its intent to propose amendments to the performance standard for sunlamp products.

The FDA is taking this action to address concerns about the adequacy of the warnings on sunlamp products, current recommended exposure schedule to minimize risks to customers who choose to produce and maintain a tan, current labeling for replacement lamps and current health warnings that do not reflect recent advances in photobiological research.

The Safe Medical Devices Act of 1990, enacted Nov. 28, 1990, transferred the provisions of the Radiation Control for Health Service Act to Chapter V, subchapter C of the Federal Food, Drug and Cosmetic Act. This authority provides for developing, amending and administering radiation safety performance standards for electronic products.

Sunlamp products are Class I medical devices exempt from pre-market modification requirements. These products are intended to provide ultraviolet radiation to tan the skin. As class I devices, sunlamp products are subject to general controls such as registration, listing and current good manufacturing practices. In addition, sunlamp products also are subject to the regulations for electronic product radiation control.

The sunlamp performance standard originally was published in the Federal Register on Nov. 9, 1979. On Sept. 6, 1985, the FDA amended Sec. 1040.20 and made it applicable to all sunlamp products manufactured on or after Sept. 8, 1986. On Aug. 21, 1986, the FDA issued a guidance titled, "Policy on Maximum Timer Interval and Exposure Schedule for Sunlamp Products." The guidance explained the criteria the FDA uses to evaluate the adequacy of the exposure schedule and the recommended maximum exposure time for sunlamp products. On Sept. 2, 1986, the FDA issued another guidance entitled, "Policy on Lamp Compatibility." The guidance listed the criteria the FDA uses to evaluate lamp compatibility for sunlamp products.

Before proposing any electronic product performance standards, the FDA is required to consult a statutory advisory committee, the Technical Electronic Product Radiation Safety Standards Committee (TEPRSSC). At the Sept. 23-24, 1998 meeting of TEPRSSC, the FDA presented general concepts for amendments to the performance standard for sunlamp products. The committee recommended the FDA pursue development of the amendments and the FDA intends to present more specific proposals to amend the performance standard to TEPRSSC prior to the publication of the proposed rule in the Federal Register.

The FDA is concerned that inadequate attention is being paid to the recommended exposure schedule that was designed to minimize risks for those who choose to produce and maintain a tan. In addition, the FDA is further concerned that the warnings for sunlamp products are not reaching many users of sunlamp products and that the existing exposure schedule does not take into account the variations in individual human UV sensitivity. In order to update the current sunlamp products standards, the FDA is considering revising Sec. 1040.20.

Additionally, sunlamp technology continues to change. These changes can affect both the intensity and the spectral characteristics of UV from sunlamps. Because there is no uniform grading/rating system, choosing a replacement lamp can be confusing for tanning bed owners. Owners choosing replacement lamps must consider lamp compatibility as well as compliance with the FDA’s performance standard in order to protect users from excessive exposure to UV.

The FDA also is aware of new research findings that suggest a stronger association between exposures to UV radiation and the increased incidence of skin cancer that has been observed in the U.S. population. Some of this increase has been linked to intense, intermittent exposures to solar radiation; however, other research suggests that chronic, less intense exposures to UV radiation contribute to skin cancer.

Research has identified the fundamental chemical damage that occurs in the genetic material of humans and has linked some skin cancers to changes in specific genes. These scientific findings had led many in the medical community to strongly suggest that consumers avoid intense, intermittent exposures (the type that could produce sunburns) to UV radiation, and also minimize other UV exposures as well.

Some research has linked skin cancer to exposures to sunlamp products, and some research has even suggested an association between the use of sunlamps and malignant melanoma. This association is not definitive. The FDA solicits comments and information as to whether a warning about possible melanoma induction should be part of sunlamp labels. In order to provide users with sufficient information for the safe use of these devices at tanning salons and for home sunlamp products, the FDA is seeking comments and information on suggested changes to the current sunlamp labels.

After considering the risks, some consumers may still choose to tan, either by exposure to the sun or by use of sunlamp products. Those consumers who use sunlamp products should obtain their tan with the least amount of risk from sunburn and eye damage. Therefore, the FDA seeks advice on a recommended exposure schedule that would minimize the risks of adverse effects while still producing and maintaining a tan.

Revisions Under Consideration

The FDA is considering revising and updating the current sunlamp product performance standard (Sec. 1040.20) and harmonizing it with the International Electrotechnical Committee Standard 335-2-27 for UV- and infrared-emitting appliances. After consulting with international standards organizations and evaluation of the current scientific knowledge, the FDA intends to develop a recommended exposure schedule that will become part of the directions for use of sunlamp products.

As part of the development process, the FDA intends to review the material on the effects of UVA and UVB on skin, the effects of UV exposure on melanoma induction and the use of photobiological action spectra as a basis for risk assessment in health protection and product safety discussed at the American Society for Photobiology and European Society for Photobiology Joint Workshop on UV and Melanoma held in Snowbird, Utah, July 11-15, 1998; the International Symposium and Workshop on Measurements of Optical Radiation Hazards, at the National Institute for Standards and Technology held in Gaithersburg, Md., Sept. 1-3, 1998; and, the Research Workshop on Risks and Benefits of Exposure to Ultraviolet Radiation and Tanning, at the National Institutes of Health in Bethesda, Md., Sept. 16-18, 1998. The proceedings of these meetings describe current research findings that show a stronger correlation between UV exposure and skin cancer, photoaging and photoimmunological effects.

The FDA also is considering revising and updating its Aug. 21, 1986, guidance on the determination of the maximum timer interval and recommended exposure schedule for sunlamp products entitled, "Policy on Maximum Timer Interval and Exposure Schedule for Sunlamp Products." The FDA intends to update this guidance after reviewing and evaluating material presented at the meetings listed previously and other available information. In addition, the FDA is further considering incorporating the previous guidance into the sunlamp product performance standard because it believes such incorporation would result in a more comprehensive regulatory standard with all relevant information for compliance in the standard.

Additionally, the FDA is considering adding a provision clarifying that manufacturing includes the modification of a sunlamp product, previously certified under Sec. 1010.2, by any person engaged in the business of manufacturing, assembling or modifying a sunlamp product’s performance, information or intended function for which Sec. 1040.20 has an applicable requirement. This addition would clarify that sunlamp products are being regulated like other products regulated under Sec. 1010.2. The FDA also is considering requiring the manufacturer who performs such modification to recertify and re-identify the product in accordance with the provisions of Secs. 1010.2 and 1010.3. This potential amendment is intended to clarify the responsibilities of firms and individuals who are in the business of installing UV lamps and new timers with different performance characteristics than the original lamps and timers in previously certified products.

The FDA is concerned that the current warning label is not read by many tanning salon patrons because it is too long and detailed. Therefore, the FDA is considering updating the warning statement required by Sec. 1040.20 (d) (1) (i) to simplify the wording and to highlight the risk of skin cancers. In order to update the warning statements, the FDA intends to review and evaluate epidemiological and mechanistic information on UV exposure-related skin cancers, including possibly fatal cutaneous melanoma.

The FDA also is considering requiring the reproduction of the text of the warning statement specified in Sec. 1040.20 (d) (1) (i) in catalogs, specification sheets and brochures pertaining to sunlamp products. The FDA is concerned that consumers who purchase sunlamp products through catalog mail order or through catalogs on electronic media may not receive information about the associated hazards and risks until the products are delivered to their homes and unpacked.

Finally, to simplify appropriate lamp replacement, the FDA is considering the development of a biological efficacy rating scale for UV lamps intended for use in sunlamp products. Lamp technology continues to evolve, affecting the levels of UV exposure, the spectral characteristics and, therefore, the biological efficacy of ultraviolet lamp radiation. Presently, a label that specifies the type of lamps suitable for replacement in the product is required on sunlamp products and in the user instructions. As new lamps and new lamp manufacturers enter the marketplace, it is increasingly cumbersome to keep track of individual lamp designations that are compatible with the product and compliant with the standard. In order to simplify the process, especially for industry and state regulators, the FDA is considering a uniform grading/rating system.

Comments to the ANPRM were received in July 1999 and have been under review since then. In September 1999, W. Howard Cyr, Ph.D., director of the Center of Devices and Radiation Health, updated the Technical Electronic Product Radiation Safety Standards Committee (TEPRSSC) on the status of the ANPRM and the CDRH’s recommendations based on the comments received by the deadline. Dr. Cyr noted that all of the comments had not yet been evaluated, and his office was still in the process of reviewing additional comments.

Representatives of the indoor tanning industry, including LOOKING FIT®, traveled to the Baltimore area to be present at the TEPRSSC meeting.

The biggest news for the indoor tanning industry came in this statement from Dr. Cyr: "The FDA never had plans to ban sunlamps. That request was from the Academy [of dermatologists]." He strongly emphasized that since the melanoma-sunlamp connection is not well established and indoor tanning is a personal choice with fairly well understood risks, there are no current plans to ban sunlamps.

It is important to note that although this non-aggressive position by the CDHR is extremely positive for the indoor tanning industry, it is only the first step in a long road to our final goal.

Since then several meetings have occurred to discuss possible amendments. The most recent meeting was held in October 2003 where TEPRSSC called for rule changes associated with indoor tanning, the FDA last year was given the green light to develop amendments to the U.S. performance standard for sunlamp products. Current rules that are being considered for change include revised warning labels, addition of warning labels to all indoor tanning purchasing information, modification of the definition of eyewear, more stringent limits on eyewear effectiveness, adoption of maximum timer setting of 3 MEDs, and implementation of coding systems for sunlamps.

Before final acceptance of any changes, FDA must submit a proposal for final acceptance. The public comment period has not yet been established. The next TEPRSSC meeting was scheduled for Oct. 4, 2006, but was canceled. The next meeting has not been rescheduled.