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Unlimited and Unrestricted access to ultraviolet radiation: A case for effective state regulation over the indoor tanning industry. Meghana Desai Aruru, PhD (Candidate), MBA, B.S.Pharm J.Warren Salmon, PhD Dept. Of Pharmacy Administration University of Illinois at Chicago maruru1@uic.edu.
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Unlimited and Unrestricted access to ultraviolet radiation: A case for effective state regulation over the indoor tanning industry Meghana Desai Aruru, PhD (Candidate), MBA, B.S.Pharm J.Warren Salmon, PhD Dept. Of Pharmacy Administration University of Illinois at Chicago maruru1@uic.edu
Agenda • Introduction • Tanning practices • Epidemiology of UV radiation on skin • Fitzpatrick skin type classification • Indoor Tanning Industry • Policies pertaining to indoor tanning • Discussion & Questions
Introduction • UV tanning – outdoors (sun) & indoors (tanning units) Prevalence of indoor tanning is defined variously as any use in the past 6 or 12 months or frequent use in the past 12 months • NCI – Skin cancer most common form of cancer in U.S, diagnosed in more than 1.5 million Americans each year • Increasing incidence of melanoma and non-melanoma skin cancers 2005 : 59,580 melanoma cases, 7,770 deaths 2006 : 62,190 melanoma cases, 7,910 deaths (estimated) • SEER statistics - an average of 18.8 life-years lost per melanoma death. Melanomas addressed in Healthy People 2010, growing concern in AMA, WHO, AAD
UV Radiation 200 nm 280nm 320nm 400nm UVC UVB UVA (absorbed by ozone) (highly carcinogenic) (weakly carcinogenic) Acute & Chronic effects from UV radiation • Short term – itching, nausea, pruritis, xerosis Long term - polymorphous light eruption, disseminated superficial actinic porokeratosis, mid-dermal electrolysis and actinic granulomas, melanomas, basal and squamous cell carcinomas • Pre-existing photosensitivity in Lupus Erythmatosus, Polymorphous Light Eruption, Porphyria, and Rosacea significantly exacerbated by exposure to indoor tanning
Emergence of tanning • 1930’s & 40’s – Medical profession encouraged sun exposure as benefit to children • 1948 – First reported studies of vitiligo with oral & topical psoralen • Development of ‘tan’ for cosmetic purposes – French designer Coco Chanel • 1970’s – Development of UVA beds for medicinal purposes • Commercialization soon after with formation of the Indoor Tanning Association
Skin cancers Melanoma in U.S – • Incidence rates rising by 4-8% each year • Lifetime incidence is 1/71 • 3% of all cancers • 1% of all cancer deaths • Most common cause of death in women 30-39 years
Skin cancers - Melanomas Risk factors: • Family history • Red/Blond hair • Ample UV exposure (freckling on upper back, history of 3 or more sunburns before age 20, 3 or more outdoor jobs before age 20) • Actinic keratosis • Skin types I & II • Advanced age • Atypical or congenital nevi
Skin types Fitzpatrick’s classification – 1977 SED = sub erythemal dose
Skin type assessment • Sun sensitivity or skin type remains constant during a lifetime • Self assessment by individual tanners • Assessment by low-wage, insufficiently trained tanning salon operators
Indoor Tanning Association • Total Number of Professional Indoor Tanning Facility Businesses: 25,000 • Total Number of Professional Tanning Business Employees: 160,000 • Total Professional Indoor Tanning Facility Customer Base: 30 million • Total Revenues Professional Indoor Tanning Facilities: $5 billion
Indoor Tanning Industry Misleading advertisements &/or falsified messages: • Promoting UV protection through indoor tanning (lack of sufficient epidemiological evidence) • Promotion of health benefits through Vitamin D production • Promotion of trade-offs of certain internal cancers • Stand against sunscreens
Indoor Tanning Industry • Significant advertising & promotion to students • Formed a Political Action Committee (PAC) to prevent ban on under-18 tanning
Indoor Tanning Industry Tanning salon operator education: • Through 2 private institutions – National tanning Training Institute (NTTI) and International Smart Tan Network (ISTN). • No training for skin typing • No training for radiation related burns and/or emergency procedures • No demonstration of equipment handling
Indoor Tanning Source: www.cartoonstock.com
Tanning Salon Operators Source: www.cartoonstock.com
Regulation & Legislation FDA – regulates equipment, adherence to performance standards, warning signs (FDA, 21 CFR Ch.1 § 1040.20) • Regulation since 1979 – Federal standards adopted to protect customers from eye and skin injuries • 1985 – Amendments by allowing longer exposure times for UVA emitting lamps • 1986 – Policy letter published on recommended exposure schedules • Currently – no regulation or monitoring of exposure times of patrons, no requirements for maintaining much information
Regulation & Legislation • FTC – prohibits deceptive advertising • Individual states governance
Screening • Differences of opinions: • AAD, ACPM – regular screening • IOM, NCI – insufficient evidence for screening • USPSTF, CTF – screening at-risk population • Early detection of melanomas: High 5-year survival rate • External & visible cancer with known risk factors
Discussion According to Sharon A. Miller at the FDA’s Center for Devices and radiological Health: “FDA does not recommend the use of indoor tanning equipment” Comments: -FDA does not regulate prevalence of indoor tanning - Currently no legislation protecting minors explicitly - No safeguards in place to protect the general tanning population - No requirements for exposure schedules or monitoring of UV radiation sessions in tanning salons
Discussion • Significant efforts by AAD, WHO, AMA to ban under-18 tanning • Involving health professionals to detect melanomas and other skin cancers • Regulation over exposure schedules with mandated record keeping • Risk communication to adolescents – immediate perceived benefits versus long term health issues • Development of melanomas at later ages – Medicare burden
Conclusion • UV exposure presents a significant and serious public health problem • State health departments should mandate cancer risk reduction • Need enforceable state regulatory safeguards in place • Consumer awareness alone does not change tanning behaviors
Conclusion • Under-18 adolescents typically do not understand risk-benefit tradeoffs • Concern about additive effects from both indoor & outdoor tanning from studies • Concern about proposed tanning addictions • Need for also stepping up oversight by FDA & FTC • All suggestions are reasonable and not overly burdensome
Conclusion • Increasing vigilance by state health departments over indoor tanning activities including monetary penalties • Monitoring tanning salon operator training to include in depth understanding of skin cancers in relation to UV radiation • Public Health commitment required for best course of action