The British Association of Dermatologists welcomes the publication, today, of the All Party Parliamentary Group on Skin’s (APPGS) recommendations regarding sunbed regulation in England.

The British Association of Dermatologists worked closely with the APPGS to gather evidence and to consult with a range of stakeholders leading to an oral evidence session in the Houses of Parliament in January this year.

Professor Harry Moseley, spokesperson for the British Association of Dermatologists says:

“The evidence shows that despite the promising step forward made by the passing of the Sunbed (Regulation) Act 2010, many providers of sunbed facilities are failing to ensure that they reach basic standards. This proposed regulation would close loopholes, such as under-18s using unmanned tanning facilities, and see stricter enforcement for businesses that continue to irresponsibly use appliances that fail to meet standards, often producing radiant dose levels well over acceptable levels. Proportionate and sensible regulation of sunbeds is important to mitigate that risk and stem the rising tide of cases of skin cancer.

“Skin cancer cases in the UK are rising at an alarming rate and there is little doubt that sunbeds increase the risk of skin cancer in fair skinned populations.”

Skin cancer rates in the UK are high compared with other cancers. There are around 100,000 cases of non-melanoma skin cancer alone each year and the actual figure may in fact be higher due to under-reporting. For melanoma, the most deadly form of skin cancer, there are just under 13,000 cases a year and about 2,700 deaths.

The link between skin cancer and sunbeds has been well documented and in 2009 the International Agency for Research on Cancer (IARC), part of the World Health Organisation, classified sunbeds as a Group 1 carcinogen (carcinogenic to humans), the same classification as given to tobacco.

The 2010 Sunbed (Regulations) Act was the first step in restricting sunbeds and regulations have been enacted in Wales, Scotland and Northern Ireland. Since the introduction of the regulations and the ban on use by under-18s, the number of young people using sunbeds has diminished. However in a report commissioned by CRUK, Public Health England found that of those under-18s still using sunbeds over half had been burnt, including all those who reported frequently using coin-operated/token operated salons, and over half had never been asked to show ID as proof of age.

The recommendations from the APPGS ask for further action and better enforcement of existing regulations, particularly in England:

A Ban on Unstaffed Tanning Facilities
A ban on unstaffed tanning facilities (which already exists under the regulations enacted in Scotland, Wales and Northern Ireland) is considered vital as a way of ensuring that under-18s don’t access sunbeds and that other safety measures are adhered to. Currently regulations in England do not provide for such a ban and the BAD would strongly endorse the recommendation that the Department of Health urgently look into introducing this measure in England.

Appropriate Screening of all Customers’ Skin Types
If staff are not trained to recognise skin types or advise customers on how, for example, very fair, sensitive skin or the presence of an existing skin condition, might disqualify them from using a sunbed, the potential for harm is serious.

The APPGS recommends that the English sunbed regulations be extended to include the requirement that salon staff are fully trained in the different skin types and their associated risk levels when exposed to UV light, and thought should be given to a system of certification to ensure compliance.

Compliance Testing for radiant exposure (dose) and irradiance limits
British and European Standards, agreed in all EU countries, limit the strength (irradiance) of the UV emission. Equipment that emits high levels of UV radiation has the potential to cause increased harm in a short time period. The APPGS recommends that the English sunbed regulations be extended to include compliance testing for radiant exposure (dose) and irradiance limits. It is proposed by the APPGS that the Department of Health undertake a study into the appropriate method of measuring total dosage and irradiance. The agreed method of measurement should then be incorporated into the current list of investigative duties outlined in the 2010 Sunbed (Regulation) Act. In the meantime, however, it is important that operators stay within the currently prescribed limits.

Provision of balanced health information
In Scotland, Wales and Northern Ireland, sunbed regulations already contain provisions for this and might be used as precedents in English regulations. The detail of the content of such health information would be for the Department of Health to decide.

Provision of safety goggles
The 2010 Sunbed (Regulation) Act already contains provision for protective eyewear to be mandatory but the recommendations of the APPGS (and Public Health England) also urge the Government to consider the challenge of verification with the possibility of mandating the type of eyewear to be used – i.e. those verified by a marking scheme.

Licensing
Liverpool City Council raised a concern, shared by many, as to how possible it was to enforce existing regulations without a registry or licensing system. A 2009 survey of Local Authorities suggested that the majority would welcome the introduction of mandatory licensing of sunbed outlets. This could be made possible if the Local Government Association’s plans for a new system of local authority licensing are implemented (as set out in their report “Open for Business: rewiring licensing”).

These recommendations represent a golden opportunity for the UK government to mitigate the unnecessary skin cancer risk from sunbeds through improving regulation, enforcement of regulation and provision of mandatory health information to users.

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Contact:

Deborah Mason 020 7391 6355
Matt Gass 020 7391 6084
Email: comms@bad.org.uk

The British Association of Dermatologists (BAD) is the central association of practising UK dermatologists. Our aim is to continually improve the treatment and understanding of skin disease.
British Association of Dermatologists, Willan House, 4 Fitzroy Square, London W1T 5HQ
www.bad.org.uk
@healthskin4all