Yesterday, the FDA issued its final order reclassifying tanning beds from low-risk (class I) to moderate-risk (class II) devices. The order primarily impacts bed manufacturers, in that: (1) it requires that manufacturers include language on tanning beds that explicitly warns against use by persons under the age of 18 years; and (2) certain marketing materials promoting tanning beds must carry additional warning language and contraindications, including “Persons repeatedly exposed to UV radiation should be regularly evaluated for skin cancer.”
While we are disappointed that the FDA did not actively include our industry in this process before issuing the order, it does not come as a complete surprise as it basically implements what the FDA proposed in May 2013. If your employees or customers ask, let them know we remain committed to responsible access to UV exposure for the millions of Americans who choose to tan.
There is nothing you need to do at the present time in your salons. The bed manufacturers have roughly 15 months before the warning labels are required. We’ll keep you updated on any more developments.
Please direct any questions to firstname.lastname@example.org.
American Suntanning Association
A short segment on an episode of the TV program “The Doctors” which aired Wednesday, March 12 attempted to suggest that a 23-year-old woman contracted a MRSA bacterial staph infection from visiting a tanning salon in California.
The woman – identified only as Brittany in the segment – did not identify any tanning salon, but claimed, “One day, after I went tanning, when I got home, I noticed I had a small little pimple on my stomach. I was thinking that it was just going to go away, but it didn’t.” Two weeks later the bump had grown and a friend who worked at another tanning salon allegedly told her she should go to the emergency room.
According to the segment, Britney’s doctor did not tell her that MRSA can be transmitted on just about any surface. “The doctor asked me if I had been in a gym or a tanning salon or anywhere that could have that type of infection in there,” Brittany said.
From there, the segment turned into an attack on tanning – despite never even discussing how the tanning unit was isolated as the source.
According to the University of Chicago MRSA Research Center and the U.S. Centers for Disease Control and Prevention, staph bacteria are one of the most common causes of skin infections in the United States, with one-quarter to one-third of the population carrying dormant staph bacteria. MRSA is a type of staph resistant to most antibiotics, with about 1 percent of the population carrying the bacteria.
According to Medicine.Net, “There are two major ways people become infected with MRSA. The first is physical contact with someone who is either infected or is a carrier (people who are not infected but are colonized with the bacteria on their body) of MRSA. The second way is for people to physically contact MRSA on any objects such as door handles, floors, sinks, or towels that have been touched by a MRSA-infected person or carrier. Normal skin tissue in people usually does not allow MRSA infection to develop; however, if there are cuts, abrasions, or other skin flaws such as psoriasis (a chronic inflammatory skin disease with dry patches, redness, and scaly skin), MRSA may proliferate. Many otherwise healthy individuals, especially children and young adults, do not notice small skin imperfections or scrapes and may be lax in taking precautions about skin contacts.
MRSA can be spread by contact with doorknobs and even doctors’ stethoscopes – a study published this month in Mayo Clinics Proceedings found that stethoscopes are common carriers of MRSA and are dirtier than doctors’ hands.
If asked by clients, please let them know there is no evidence that bacterial infection can be spread on the surface of a tanning unit that has been sanitized with products designed to clean tanning beds between uses. Any media inquiries should be directed to email@example.com.
Industry Seeks to Minimize Overexposure, Supports Responsible Tanning
NEW YORK (Oct. 15, 2013) – The professional indoor tanning salon community supports initial reports of New York City Mayor Michael Bloomberg’s initiative to increase compliance with New York City rules for professional tanning facilities.
The American Suntanning Association – the nation’s largest association of professional suntanning facilities – reached out to the Mayor’s office today to support his initiative. The tanning community has long been a proponent of enforcing existing laws and is already executing many of the precautions laid out in press accounts of Mayor Bloomberg’s proposal. The salon community will support any city-wide effort to increase compliance with the standards already in place in professional salons.
“Our industry has always supported efforts to reduce overexposure and risk. Like many things, UV exposure is all about moderation and responsibility. Salon owners should be held accountable for following regulations and not allow a few bad actors to sully the industry,” American Suntanning Association Advisor Joseph Levy said.
“We agree with the Mayor that there should be additional regulation to crack down on anyone acting irresponsibly and American Suntanning Association salons are happy to work with the Mayor on this initiative,” Levy said.
According to initial media reports, the Mayor’s plan includes the following, all of which the ASA supports:
• Require the health department to inspect tanning salons.
• Crack down on unlicensed operators.
• Require operators of UV equipment to undergo training. Enforce the law that bars
adolescents under 17 from frequenting tanning shops.
• Launch a public education campaign about the dangers of too much UV exposure.
For more information about ASA visit www.TanResponsibly.org.
October 9, 2013.
Today the Indoor Tanning Association (ITA) and the American Suntanning Association (ASA) announced a cooperative strategy for 2014 and beyond to promote and defend our industry.
The ITA, founded in 1999 is the industry’s oldest trade association and has historically represented the interests of every indoor tanning market segment including tanning salons. The ASA was organized one year ago as a salon-only organization. Over the past year, there has been some redundancy with both groups working independently on issues that impacted all segments of the industry. This plan is designed to optimize and increase industry resources particularly in efforts related to Washington, D.C.
Under the new arrangement, the ITA will continue to represent the tanning industry but will focus its resources primarily on manufacturer related tanning equipment and tanning products issues. The ITA will also focus on Federal policy, Federal regulations and the industry political action committee fund.
The ASA will continue to manage all state lobbying, scientific relationships, and media and PR efforts on behalf of its members in the tanning salon market segment. The ASA will also continue to handle federal lobbying issues affecting tanning salons.
The two groups will share information and work closely on all issues that impact our industry. ITA Executive Director John Overstreet will work closely with ASA President Bart Bonn to implement this strategy.
The two organizations are pleased to announce this plan. There is broad agreement that cooperation is a key element for increasing our capabilities to protect and then grow our industry. We encourage everyone in our industry to step up and get involved.
ASA Members and Supporters,
The U.S. Centers for Disease Control is collecting public input until Sept. 4 for a report intended to convince the U.S. Surgeon General to release a public statement on UV and skin cancer. It seems apparent this is part of the American Academy of Dermatology Association’s lobbying initiative to get surgeon general’s warnings put on sunbeds to continue their “sun scare” campaign to liken UV to smoking.
To help get CDC to meet with ASA scientists, we’d like you to send a united message that CDC needs to work with us before they proceed with any kind of report. ASA is submitting a scientific response to this. For our industry to succeed in this campaign, it is critical that we send as many letters as possible echoing this concern.
So we’ve made it easy for you to submit a response electronically.
1. Click here to go to the comment submission page
2. Type in your personal response or copy and paste the text below into the comment box
3. Fill out your information
4. Click “Continue” to review your submission
5. Check “I read and understand the statement above” and then click “Submit Comment”
Dear CDC -
A very brief 30-day public comment period (Aug. 5, 2013-Sept. 4, 2013) for a report which will have major public policy ramifications is incapable of producing material worthy of this broad-reaching topic for the following reasons:
(1) The main premise of your Notice — “preventing skin cancer through reduction of UV exposure” —and your broad statement that “A majority of skin cancers are caused by exposure to ultraviolet (UV) radiation from the sun or from indoor tanning devices” is very limited. It leads one to infer that you are already predisposed to a conclusion that most science suggests is not as black-and-white as your Notice infers and which is actually debated in the scientific community.
Melanoma skin cancer is more common in indoor workers than outdoor workers, who receive many times more UV exposure, and is most common on parts of the body that do not receive regular UV exposure. What’s more, melanoma mortality and incidence are increasing fastest in older men — the group least-likely to be addressed by this Notice’s stated areas of focus.
Further, your statement that “An estimated 3.7 million cases of basal and squamous cell carcinomas …are diagnosed in the U.S. annually” shows a lack of understanding of this issue. That figure refers to dermatology’s estimated number of procedures — not cases. One case is often represented by dozens of procedures, and there is no actual incidence registry of either of these cancers in the United States nor is there any government number showing an actual increase in these diseases.
(2) This document calls for policy about UV exposure to be based solely on the basis that any UV exposure leads to skin cancer (a conclusion that, again, is debated — a debate which is not reflected in your Notice) at a time when science is clearly starting to understand the broad-reaching benefits of regular UV exposure — benefits that are both vitamin D-related and which are now understood to be solely related to UV exposure itself. Acknowledgement of these fields of research is fully lacking in your Notice, nor is there any indication you have involved any of these disciplines in your process.
(3) Your announcement was buried in the Federal Register at the end of summer during a period when very few of the affected scientific fields or stakeholders would see this document, let alone have sufficient time in 30 days to respond.
This topic deserves a higher-level conversation before a CDC report or a Surgeon General recommendation about UV exposure should be drawn. I would like to join many Americans who insist that you conduct a more thorough, public and inclusive panel of experts and public participants to examine the broad-reaching affects of UV policy fully before proceeding. As it is, your Notice suggests your public understanding of this issue is based solely on the dermatology industry’s lobbying points.