Ultraviolet tanning equipment: six questions

Recreational tanning, particularly as promoted by commercial salons with ‘sunbeds’ or booths, has generated increasing attention from the regulatory and the biomedical communities. Several agencies have weighed in with opinions on recommended modifications in guidelines, training procedures, regulatory controls, and consumer awareness. Currently there is little uniformity in the guidance provided by trade groups, in recommendations supplied by health agencies and medical associations, or in regulatory approaches taken or proposed by the many countries involved. In an effort to provide a clearer focus for its concerns in this area, the EU Directorate General Health and Consumer Affairs formulated six questions on ultraviolet (UV) tanning, all of a technical or biomedical nature. The questions were stimulated in part by the fact that the European Commission no longer regards the European standard EN 60335-2-27:1997 (‘Particular requirements for appliances for skin exposure to ultraviolet and infrared radiation’) as giving presumption of conformity to the Low Voltage Directive 73/23/EEC. (The latter Directive governs marketing of electrical devices in EC countries.) Initially, the questions were posed to an EU Scientific Committee. Subsequently, industry representatives and the European Commission jointly requested that the scientific community provide answers to the questions. We received the questions with a request for our technical responses and opinions. Our response was in the form of the following essay, submitted earlier this year to the European Commission. We offer it here in the hope of stimulating constructive discussion and comment.