European Sunlight Association

Introduction

This summary highlights the shortcomings the European Sunlight Association has identified in the SCHEER preliminary opinion on the “biological effects of ultraviolet radiation relevant to health with particular reference to sunbeds for cosmetic purposes”. These shortcomings undermine the report’s credibility and reflect a patent bias against indoor tanning and sunbed use.

1. Flaws in the approach taken by SCHEER and the Working Group on sunbeds

The composition of the Working Group brings into question the impartiality and independence of its work. Not only does the working group not include any expert on UV radiation, but SCHEER chose to involve two external experts who are both known for their anti UV position. Additional and more widespread relevant expertise in the committee would have been advisable to draft such an important opinion, as would have been the inclusion of experts from different “schools of thought”.

The draft opinion’s conclusions are largely based on studies which do not reflect the current situation in Europe. Most of these studies were carried out before the entry into force of the 2007 EN 60335-2-27 standard which puts a limit of 0.3W/m² on UV radiation from sunbeds (equivalent to Mediterranean sun). Yet, SCHEER’s mandate is to assess whether the 0.3W/m² irradiance limit ensures sufficient levels of protection in view of “new medical evidence over the past decade”. SCHEER is referencing only 11 from the 143 recent studies ESA submitted; in most instances its conclusions from these studies are selective and any positive findings are being played down. To highlight just one example, SCHEER seems to have conflated indiscriminately data about commercially exploited sunbed for cosmetic/feel-good purposes with that for home and medical usage of UV equipment.

SCHEER thus concludes that there is no safe limit for UV irradiance without providing reasons or indeed evidence that the 0.3 W/m² limit (recommended by the very committee preceding SCHEER!) in place since 2007 is not safe anymore.

2.  A biased approach, which does not acknowledge existing ways to control risks

The draft opinion reveals a biased approach with regards to product risk assessment. What is referred to as evidence counting against sunbeds must also be applied to natural sunlight. Excessive exposure to UV radiation — whether from the sun or from a sunbed — can be detrimental. The opinion stresses UV emitting devices are considered a Group 1 carcinogenic by WHO, but this categorisation only means an agent can cause cancer, not that it does. Group 1 also includes processed meats with a relative risk increase of 17%, and natural sunlight with a relative risk increase of 61%[1], when sunbeds’ relative risk is estimated at 16%. SCHEER also appears to base its draft conclusions largely on the relative risks run by so-called “skin type 1” persons (“never tans, always burns”) – a minority who are in any case screened out by tanning facility staff in an initial ‘admission test’.

A sound risk assessment requires taking into account the use of a product and possibilities to reduce associated risks, which SCHEER has not done. The indoor tanning industry has taken a number of measures to ensure swift implementation of existing regulation (both at EU and national level) and customers’ safety, which the draft opinion ignores. Most recently, the ESA introduced a new European Standard on training & service provision in cooperation with CENELEC and the Austrian Standards Institute (ASI) (EN16489) and developed a certification, training & labelling scheme for this new standard to facilitate its national implementation. Effective implementation of existing legislation should be the priority. In the Netherlands, successful cooperation between sunbed operatorsand market surveillance authorities resulted in 90% compliance with existing legislation via a number of measures: leading manufacturers have introduced a sunbed passport to facilitate authorities in controlling sunbeds at studio locations; an automatic software security checks when a customer returns too often; training for all employees is mandatory; mystery shopper visits are being carried out on a regular basis.

3. Lack of balance and accuracy

Targeting sunbeds as a primary cause of melanoma is highly dubious as there is an evident inherent imbalance in the risk assessment.  No study has yet demonstrated a causality link between the risk of melanoma and sunbed use. An obvious reason for that is that many primary factors affect melanoma trends among which are family history with skin cancer, sunburns, especially at an early age, or moles.

Sunbeds can actually offer a safer tanning environment than the beach: sunbeds in Europe are limited to 0,3W/m2, they keep track of the exposure time and the UV-index is stable. Meanwhile, sunscreen abuse or misuse is a much more important problem since sunscreen blocks Vitamin D production and permits greater UVA exposure. In fact, some studies even found that the more sunscreen people use, the higher the risk of developing skin cancer[2]. The public should be aware of these risks as well; singling out sunbeds may give a false sense of safety.

4. No consideration of the benefits of UV radiation

The draft opinion also fails to properly assess the beneficial effects of UV radiation, such as the production of Vitamin D, but concentrates almost exclusively on the negative effects. Yet, beneficial effects are widely documented and there is growing awareness of the risks associated with Vitamin D deficiency which affects a large part of the European population, especially at northern latitudes. Recent studies have demonstrated the positive effect of UV-B induced vitamin D on bone health, and the fact that controlled but regular UV exposure lowers the risk of developing heart disease.[3]

[1] Gandini S, et al., Meta-analysis of risk factors for cutaneous melanoma: III. Family history, actinic damage and phenotypic factors doi:10.1016/j.ejca.2005.03.034

[2] Autier P. et al., Sunscreen use and intentional exposure to ultraviolet A and B radiation: a double blind randomized trial using personal dosimeters, Br J Cancer. 2000 Nov; 83(9): 1243–1248

[3] Lindqvist PG, Epstein E, Nielsen K, Landin-Olsson M, Ingvar C, Olsson H (Karolinska University Hospital, Lund University, Lund, Sweden). Avoidace of sun exposure as a risk factor for major causes of death: a competing risk analysis of the Melanoma in Southern Sweden cohort. J Intern Med 2016; doi: 10.1111/joim.12496.

Cashman, K. et al. (2016). Vitamin D deficiency in Europe: pandemic?, The American Journal of Clinical Nutrition, 2016 103: 1033-1044.