This is a copy of the testimony submitted to the FDA by Amy Waldrop, a melanoma survivor and advocate against the use of tanning beds for minors. She is appearing before the FDA today to speak out about the dangers of tanning and raise awareness…

Division of Dockets Management
Food & Drug Administration
Docket No. FDA-2009-N-0606

Written Testimony on Reclassification of Indoor Tanning Beds to the Center for Devices and Radiological Health, March 25, 2010
Amy Waldrop
Virginia resident

Good afternoon.  My name is Amy Waldrop.

I’m not here to represent a tanning device manufacturer or medical association.   My interest in this matter was not born from a product sale, political agenda, or financial stake.  I am a Mom with a unique perspective on tanning beds.  As a teenager, I used and operated tanning beds.  At the age of 41, I was diagnosed with melanoma.  I have teenage daughters who are argue that tanning beds are safe, even after seeing my surgical scars.  As parent in today’s society, we have many issues to debate with our children – whether or not it is safe to lie in a bed of carcinogenic exposure in order to get a good tan, should not be one of these issues.  The government should simply not allow an industry to sell carcinogens to the public, particularly to our children.

I am appealing to the FDA to protect the health and safety of all of our children and grandchildren by calling for legislation to ban the sale of tanning bed exposure, at least to minors.  I communicate with hundreds of melanoma patients, many under the age of 30.   A common theme in their stories is teenage tanning bed USE, not misuse.  It’s true that not every person who uses a tanning bed will get melanoma or skin cancer, just as it’s true that every user of a defective product or drug that is pulled from the shelf over a legitimate health or safety concern is hurt or killed.  That said, skin cancer is the number one cancer in the United States; melanoma is the leading cause of cancer death in women between the ages of 25-35; and tanning beds do significantly increase the risks of skin cancer and melanoma.

Many adults, and certainly the majority of teenagers, don’t have the judgment or experience to understand the risks and safety concerns associated with tanning bed use.  Consumers who do look for information about tanning beds are more likely to visit the Indoor Tanning Association’s (ITA) website for information then they are an FDA website.  The ITA’s site contains inaccurate and misleading information.  For example, they say that there is no connection between melanoma and tanning bed use.  What if a parent stops after reading that statement and signs a parental consent for their child to tan and that child later develops melanoma?  Who is responsible?

According to the FDA website,

“The FDA is responsible for protecting the public health by assuring the safety, efficacy, and security of products that emit radiation.”  What does that mean?  Well, to me responsibility means taking ownership of a problem caused by an action or inaction; Protecting is preventing the occurrence of danger; and Security means we don’t have to worry.  Short of a ban, the FDA cannot reasonably shield the public (especially our minors) from injury, damage or destruction and keep them free from danger. What the FDA can do, is recommend federal legislation to prohibit an industry from selling a carcinogenic product exposure to the public.

The FDA website includes valuable information about the dangers of tanning bed product exposure.

  • There is no such thing as a healthy tan.
  •  Tanned skin is damaged skin.
  • Women under the age of 35 who use tanning beds more than once a month are 55% more likely to develop melanoma, a type of skin cancer that killed close to 9,000 people in the United States last year.
  • Approximately 85% of tanning facilities require teens to have written parental consent.  Parents are providing these consents.
  • Close to 90% of a survey of over 3000 tanning facilities across the country indicated that tanning salons violated the FDA’s recommended exposure time to tanning beds.

Clearly, the FDA understands the risks of tanning beds and knows, particularly with teenagers, that warning labels, time limitations, and parental consents have not worked.  We cannot afford to wait in hopes that a catchier label or new operating procedure imposed on tanning bed operators will keep our children out of harm’s way.

Tanning bed exposure is touted by the tanning industry as a healthy source of vitamin D and viable treatment option for certain medical conditions; however, I’ve yet to find a medical insurance company that will reimburse a physician-prescribed trip to “Bronze Beach Babes” tanning salon for unsupervised medical care (I hope this isn’t part of the healthcare plan).  If tanning beds are viable products for medical use, then by all means, the industry should develop another line of products for medically supervised use.

My daughters have told me that if tanning beds were “that bad” they wouldn’t be legal.  As a society, we are accustomed to warning labels on everything from ladders to mini-blinds.  We have a certain expectation that our government prohibits the “really bad” products from being sold on the market.  Why not in the case of tanning beds?  For some reason, it’s acceptable for this industry to sell carcinogenic product exposure to the public so we can all have a nice tan.  What am I missing?

As a nation facing a healthcare crisis, we need to be smart.  The federal government has directly and indirectly funded many of the medical research studies that the FDA cites on its own website.  These studies confirm the significant health risks associated with tanning bed exposure. How can we all stand silent while this industry sells carcinogenic exposure?  Why should we ignore the numerous, costly studies that all say the same thing – tanning exposure is dangerous, particularly at a young age.   We are talking about lives lost and billions of healthcare dollars spent each year on skin cancer and the numbers are increasing.

Are we more concerned about sustaining employment levels for this industry than we are protecting the health and safety of the public?  Closing our eyes to the results of these costly research reports; slapping a re-designed warning label on the side of a tanning bed; and imposing a few more unenforceable guidelines on an industry that has a history of blatantly ignored the rules, will not let any of us off the moral or financial hook for poisoning our minors.

Several skin cancer survivors have shared their personal stories and photos with me to include with my testimony.  These photos are included with this submission.  Take a good look at these photographs – these are daughters, friends, Moms and loved ones.

If you’ve always thought that only light eyed, fair skinned people get skin cancer, see for yourself.  People with all skin types can and do develop skin cancer.  If you’ve thought that skin cancer and early stage melanoma is “not a big deal” because most of the time it’s “cut out and cured,” take another good look at these stories.  Even early staged melanoma patients have physical and emotional scars that remain long after their cancers are “cut out and cured.”

In closing, I’m simply asking the FDA to fulfill your own mission statement relating to tanning beds.  Protect the public health by assuring the safety, efficacy, and security of products that emit radiation.” We need FEDERAL legislation for a ban on the sale of tanning bed exposure, at least to minors.  Thank you.