|Agency:||Federal Trade Commission|
|Rule:||Proposed Consent Agreement In the Matter of the Indoor Tanning Association; FTC File No. 082 3159|
Comments:In regards to the FTC's settlement with the Indoor Tanning Association, I would like to explain my disappointment in the FTC's position, it's remedies, and it's Consumer Alert. It's unfortunate that the FTC has decided to confuse the difference between overexposure, i.e. burning, and mere exposure in a non-burning fashion, which may or may not lead to a cosmetic tan. By doing so, the FTC, has joined in with the pharmaceutical industry, some dermatologists, and special interests group, in confusing the public about healthy exposure to UV. The notions that UV exposure in a non-burning fashion, getting a cosmetic tan in a non-burning fashion, and that tanning increases your risk to skin cancer, are all misleading in themselves. In the history of science there has never been a study to question whether mere exposure to UV in a non-burning fashion leads to any adverse affects. Additionally, by using the 2009 report by the IARC, the FTC has overlooked a very important fact that the IARC itself makes plainly clear: the elevation of indoor tanning units to category 1 does not specify quanity of exposure. Just like all the other category 1 items, sunlight, alcohol, mineral oil, salted fish, arsenic, etc. quantity of exposure is never explained. This is the problem with relying on the IARC. I suppose we should stop drinking a glass of red wine for heart health and stop using most cosmetics, including SPF, which contain mineral oil or derivatives, petroleum jelly, petrolatum, etc. Furthermore, suggesting 10-15 minutes of outdoor exposure to face and hands is a bold claim to be made by the FTC since this measure is not scientifically proven and is currently debated amongst scientists. Food sources listed in the consumer alert do not give sufficient amounts and do not give the proper type of vitamin D (vitamin D2 vs vitmain D3 made from UV exposure). Blood serum levels and proper amounts of vitmain D are currently being debated by the scientific community. So claiming very minimum exposure to hands and feet from outdoors and poor food sources is an overtly inappropriate claim to be made by the FTC. In conclusion, I would like to say that relying on the Cancer Society and Dermatological Society alone is not doing due diligence especially considering the growing number of scientists, medical doctors, and yes, dermatologists, who are finding that vitamin D levels are too important to completely avoid UV exposure. Even the ACS has admonished the dermatologists for their staunch stance against UV exposure. Getting moderate UV exposure from an indoor UV device from an indoor tanning salon for a cosmetic tan in a non-burning fashion, for cosmetic skin conditions like psoriasis, eczema, and acne, for chronic pain like fibromyalgia and back pain, for seasonal affectiveness disorder, and for many other reasons should by an individual's choice. Please do not allow the FTC to take a stance on something that the scientific community has not agreed upon and as science is currently evolving.