Policy responses and statements
- Name of organisation:
- Department of Health, Social Services and Public
Safety (DHSSPS)
- Name of policy document:
- Regulation of the Sunbed Industry in Northern
Ireland
- Deadline for response:
- 19 February 2010
Executive Summary: The incidence of skin cancer has been rising throughout
the world in recent decades. Factors that have been linked with this
trend include exposure of the skin to ultraviolet (UV) radiation associated
with an increase in foreign holidays and increased use of indoor tanning
facilities (sunbeds).
Sunbed usage has increased significantly in recent years. Their usage
was unusual before 1980 but by the end of the 1990s more than 60% of
women and 50% of men aged 18-50 years had reported using a sunbed.
As sunbeds emit ultraviolet
radiation, many UK, European and global public health organisations
have expressed concern about the increase in use of sunbeds, particularly
among young people.
In Northern Ireland, at present, the indoor tanning industry is not
subject to any form of direct statutory regulation. However, under
health and safety at work legislation, employers and self-employed
people have a duty to assess the risks to workers and
any other people who may be affected by their work or business. There
are no statutory age restrictions to protect children and young people.
There is a perception that sun-tanned skin or a bronzed body equates
to health and beauty. This may explain the substantial increase in
the number of sunbed outlets in Northern Ireland. The predominant skin
type of the indigenous population of
Northern Ireland – known as Celtic skin – has a higher
risk factor than other skin types of developing cancer from ultraviolet
radiation.
Sunbeds are provided in a wide range of cosmetic and leisure outlets
in Northern Ireland, including non-traditional premises, such as video
shops. The Department is not aware at present, of any “self-service” sunbeds
in unsupervised commercial premises in Northern Ireland although it
is aware that they are in use in other parts of the UK.
Increasingly, research is highlighting the risks of exposure associated
with ultraviolet radiation from sunbeds. Of particular concern is the
strength of modern commercial sunbeds which are capable of producing
irradiation equivalent to midday
Mediterranean sunlight.
In June 2009, the Committee on Medical Aspects of Radiation in the
Environment (COMARE) published a report on ‘The health effects
and risks arising from exposure to ultraviolet radiation from artificial
tanning devices’ which among others, recommended that the commercial
use of sunbeds by under 18 year olds should be prohibited.
In August 2009, the International Agency for Research on Cancer (IARC),
published a report which reclassified sunbeds into the highest cancer
risk category, ie. ‘carcinogenic to humans’ (Group 1).
IARC made its decision following a review of research which concluded
that the risk of melanoma is increased by 75% when use of tanning devices
starts before 30 years of age.
The absence of sector-specific regulation or a requirement to register
premises means that information is limited in relation to the number,
type, distribution and maintenance of commercial sunbed facilities.
Self regulation of the industry is currently inconsistent and largely
unmonitored. The Sunbed Association, the industry trade body, estimates
that around 16% of salons are members.
The purpose of this consultation document is to provide background
and information on the recognised risks factors linking sunbed usage
and skin cancer and to seek views on whether and by what means the
sunbed industry should be regulated in
COMMENTS ON
DEPARTMENT OF HEALTH, SOCIAL SERVICES AND PUBLIC SAFETY
(DHSSPS)
REGULATION OF THE SUNBED INDUSTRY IN NORTHERN IRELAND
The Royal College of Physicians of Edinburgh is pleased to respond to the
DHSSPS on Regulation of the Sunbed Industry in Northern
Ireland.
Q1. In respect of each of the measures listed in Section 6, please
state whether you support or do not support its implementation and explain
your reasons.
Measure 1: Prohibit the use of sunbeds by anyone under 18 years of
age in commercial premises.
Supported: Early sun exposure strongly influences risk of melanoma in later
life. Most of total lifetime sun exposure has occurred before age of 20. The
International Agency on Medical Aspects for Research on Cancer (IARC) has reclassified
sunbeds into the highest cancer risk category (Group1) and therefore UV should
be as restricted as alcohol and tobacco to those under 18 years old. The age
restriction should be uniform across the UK.
Measure 2: Prohibit the sale or hire of sunbeds to anyone under 18
years of age.
Supported: There should be a complete ban on sale or hire of sunbeds to all
members of public under 18. Also, as it is likely that there will be less control
over access than in a commercial facility there should be definite warnings
to adults hiring/ buying of both the overall risks and the greater risks to
young people. It would be helpful if those adults hiring or buying could sign
an undertaking that they are aware of the risks to young people and that they
would endeavour to prevent those under 18 from using the bought or hired sunbed.
Measure 3: Place a duty upon the operator of sunbed premises to display
a public information notice on the health risks associated with sunbed use.
Supported: As well as risks of cancer, other risks including sunburn and premature
ageing should be part of the information. This need to be a legal requirement
as it is not in the commercial interests of proprietors to comply. The wording
on the warning should be agreed nationally and based on best medical advice.
Users should be required to sign a consent form ensuring they understand the
risks
Measure 4: Place a duty upon the operator of sunbed premises to provide
customers with detailed written information on the health risks associated
with sunbed use.
Supported. This would be considered good practice but the nature of
the information should be nationally agreed and in line with that given in
other areas of the UK.
Measure 5: Prohibit an operator of sunbed premises from making unfounded
or unproven claims attributing health benefits to sunbed use.
Supported: This is a very important measure as many unfounded claims are made
not the least of which is that the tan produced by a sunbed will significantly
enhance skin protection if going on a holiday to a sunny climate. All potential
customers seeking health benefits from exposure to UV devices should be advised
to contact their GP.
Measure 6: Place a duty upon the operator of sunbed premises to ensure
adequate protective eyewear is worn by the customer.
Supported: Customers should be made aware of the risks of UV damage to the
eyes and the need to wear proper protection (provided free of charge). There
should be a duty of care to ensure proper protection is worn and that the proprietor
is using properly approved goggles/glasses as not all provide a safe level
of protection. UV exposure can result in acute inflammation of the eye resulting
in distressing symptoms and facial burns. It can also lead to increased risk
of cataract formation in later life and eye cancer.
Measure 7: Place a duty on the operator of sunbed premises to register
with a local authority or other body with regulatory functions.
Supported: Operators have failed to introduce and monitor compliance with
sensible standards on a voluntary basis and therefore there should be legislation
and effective enforcement annually through local authority inspectors.
Measure 8: Place a duty upon the operator of sunbed premises to limit
the number and/or frequency of sunbed sessions that they provide to any individual.
Supported: The overall risk is directly related to both the number of exposures
and the total units of light energy received. Each individual starting
a course of treatment would need a detailed history/ health check to include
concurrent illnesses, drugs (some can enhance the effects of UV light inadvertently),
skin type (type one pale complexion / red hair should be strongly advised to
avoid completely), individuals with multiple moles or freckles or customers
with a family history of skin cancer.
Measure 9: Place a duty upon the operator of sunbed premises to ensure
that staff are trained to a specified standard.
Supported: Staff in commercial centres will require training to identify
individuals at risk; a simple risk stratification proforma could be developed
by health authorities to support staffing this and also how to monitor frequency
of sessions and manage adverse incidents.
Measure 10: Prohibit the provisions of user-operated sunbeds in unsupervised
commercial premises.
Supported: This is essential; where such premises have been available
it has resulted in cases of serious burns, a child could easily make use of
unsupervised premises and there would be no mechanism to ensure proper education
and advice has been received by clients or restriction on frequency or total
number of exposures.
Measure 11: Place a duty upon the operator of sunbed premises to ensure
that all sunbeds adhere to specified British and European standards.
Supported: Adherence to standards will reduce risk. A number of national
and international groups have issued recommendations regarding the use of sunbeds
e.g. the British Photodermatology Group of the BAD (BPG/BAD), the British Medical
Association (BMA), the National Radiological Protection Board (NRPB), the Health & Safety
Executive (HSE) and the World Health Organisation (WHO) and the International
Commission on Non-Ionized Radiation Protection (ICNIRP).
Standards change over time. As more research becomes available it may become
necessary to further tighten restrictions on UV exposure so operators should
have duty of care to keep up with the National/International standards.
Q2. Please provide any other measures that could be considered for
regulating the industry.
Tanning enhancers and accelerator products should be avoided as there are
safety concerns.
Q3. Please provide any issues or difficulties that would need to be
resolved regarding the enforcement of any of the measures listed.
All UV light emitting machines are not equal. Machines will have to be calibrated
regularly and therefore by whom (In Northern Ireland all medical UV emitting
machines are under the control of the Department of Medical Physics).
Who will compose the public information and warning notices? This should
be a co-operative effort with medical physics, dermatologists etc
Who will set and provide the training program for operators?
Local authorities will have to be resourced to enforce the legislation.
Clear complaints procedures must be in place for users.
Q4. Are any of the measures listed likely to have an adverse impact
on any group of people correlating to one or more of the nine distinctions
made in Section 75(1) of the Northern Ireland Act 1998?
Unaware of any issues.
Q5. Please provide any general comments or evidence on the possible
health, economic and social impacts of regulation, whether adverse or beneficial.
Consultant dermatologists see a significant increase in all the three main
types of skin cancer (basal cell carcinoma, squamous cell carcinoma, malignant
melanoma) and this has taken up an increasing proportion of their workload.
Figures for melanoma with the province show an increasing incidence of around
10% per year, doubling in each of the last 2-3 decades, so the potential impact
on health is significant. Skin cancer now accounts for over 25% of all cancers
and in young women melanoma is now one of the biggest causes of non-traumatic
death. Given the overall size of the problem and that it is increasing at a
significant rate any measures which can reduce the overall risk to patients
should be welcomed. Climate change in the province may tempt more young
people to use sunbeds and many dermatologists would recommend a complete ban
on their use.
Copies of this response are available from:
Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.
Tel: 0131 225 7324 ext 608
Fax: 0131 220 3939
[18 February 2010]
|
