As the new year rolls in, many salons take this time to “gear up” for the upcoming prime season of indoor tanning. Equipment maintenance that may have been put off now becomes an absolute must with the season now in full focus. A central piece to that maintenance is sunbed and sunbooth lamp replacement.
Our industry is regulated by one of the most stringent of all regulatory agencies: the Food and Drug Administration. The FDA has regulated our industry since the inception of modern indoor UV tanning systems by 21CFR1040.20, a federal regulations code that ensures the safety of tanning clients nationwide.
Aimed mainly at equipment manufacturers, this CFR, or Code of Federal Regulations, includes timing systems, exposure schedules, labeling and replacement lamp compliance. In order to continue offering indoor tanning services, you need to abide by the codes.
Let’s focus on lamp compliance for now. All UV systems must comply with this CFR and for this purpose, your sunbed’s output is tested with an original or OEM lamps. The system can only provide up to 4 Minimal Erythemal Doses (MED) on a skin type II person.
An erythemal dose is the least amount of UV that induces a reddening of the skin. All sunbeds can only produce a maximum of 4. The amount of lamps, the lamp’s intensity, the thickness of the acrylic, and the output of the ballast system will all weigh in on the total output or exposure time.
When the lamp has gone through its useful life, you can either stay with the original lamp or choose an FDA-compatible replacement. Either is alright, since regulations make it possible to standardize everything.
Here’s where it’s important to choose the correct lamp. Simply because a lamp fits or has the same listed wattage, does not necessarily mean it’s FDA-compliant. When choosing the correct lamp, always ask the supplier if it is FDA-compatible with the sunbed or booth’s original lamp.
Choosing a non-FDA compatible-lamp can line up a series of unintended consequences for the owner. With the increasing popularity of red light therapy systems, some salons may also contemplate replacing or retrofitting a sunbed with red light therapy lamps.
It is imperative to select a compliant RLT system from a reputable manufacturer rather than attempting to retrofit existing sunbed equipment. Retrofitting or relamping an existing sunbed or sunbooth with RLT lamps can be hazardous.
This alters the device’s original design and potentially voids insurance coverage, as the product is now a misbranded, non-compliant medical device. It has not been approved by the FDA as a compliant system with those specific RLT lamps, labeling or timing system.
It can also void the bed’s UL /CE/ ETL listing, as the unit has not been certified with those replacement lamps and can expose the operator to liability. However, RLT systems may be also sold with “hybrid” lamps that offer a mix of red light as well as UV to produce a cosmetic tanning effect.
Red light replacement lamps that are registered as FDA-compliant to a sunbed’s original OEM lamps are also available. These replacement lamps must come with an FDA compatibility letter to the original sunbed lamp.
Other similar types may be available, but without FDA compatibility. If one chooses to use these, the system’s owner risks liability and the system’s electrical certification. As you can imagine, that’s a gamble no one should take.
Worried about your sunbed’s certification? Curious about lamp standards? We got you. For more information on this and other applicable subjects, take our Sun is Life salon certification course at www.sunislife.com.
