After wrapping up its correspondences to the U.S. Food and Drug Administration, the Indoor Tanning Association could find itself defending our industry against the U.S. Centers for Disease Control!
On August 5, 2013, the Centers for Disease Control (CDC) requested information from the public on “preventing skin cancer through the reduction of UV exposure.” Though it is unclear as to the CDC’s motivation for seeking this input, members of the Indoor Tanning Association (ITA) are alarmed because the language used in the Federal organization’s call for comment automatically links UV exposure with illness. Needless to say, the ITA responded to the CDC on this issue, and the tanning organization plans to continue monitoring the situation and reporting on its developments.
Although the CDC doesn’t have specific regulatory powers over indoor tanning, the organization’s duty is to protect public health and safety through the control and prevention of disease, injury and disability. “It’s unfortunate that the CDC opened this issue for comment late in the summer,” said John Overstreet, ITA Executive Director. “This gave us little time to marshal the scientists and researchers who support a balanced UV-exposure policy from our government. From the nature and wording of this request for information, it seems the organization has already made up its mind, and we can only assume our political enemies have a role in this.”
Working with the organization’s Ultraviolet Light Research and Education Foundation, Overstreet says the ITA responded to the CDC’s request for comment with two extensive scientific literature reviews. “Since the 2009 IARC Report has been the driving force behind most Federal and state policy makers’ proposed restrictions,” Overstreet said, “much of our review focused on the limitations and questionable findings within that report. It also illustrates the ways the report’s conclusions are inappropriate for policy-making in the U.S.”
In its comments, the ITA argued that public health will be best served if the CDC assures balanced communications to the public regarding the risks and benefits of UV exposure. “Given the nature and issues of the studies currently available,” Overstreet said, “the question is whether the existing body of research adequately captures the nuance of this complex biological mechanism. Based on the state of the science and absence of real consensus, any definitive risk statement by the CDC is essentially the declaration of a consensus where none yet exists.”
The ITA’s letter to the CDC comes on the heels of the tanning organization’s correspondence with the U.S. Food and Drug Administration. On May 6, the FDA announced its intention to reclassify tanning equipment and sunlamps to Class II medical devices, and is also considering other safety control measures. If the order is finalized, tanning unit manufacturers will have to submit a pre-market notification (510(k)) showing their products have met certain performance testing requirements, address certain product design characteristics and provide comprehensive labeling regarding risks of use. If approved, the tanning industry will have one year to comply with the new requirements.
In response to the FDA’s announcement, the ITA listed and submitted its questions regarding what it believes are inaccuracies in the reclassification recommendation. Among the ITA’s many concerns, the organization’s members are convinced that the FDA’s 510(k) process will be expensive and time consuming for tanning equipment and sunlamp manufacturers to complete.
The ITA firmly believes the CDC’s request for public comment is a significant issue facing the tanning industry today. The organization urges all salon owners to contact the ITA to help support our industry. Salon owners wishing to do so can call 888.377.0477. To review the ITA’s comments to the CDC, visit theita.com.
