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Source document:
SCCP (2006)

Summary & Details:
GreenFacts (2007)
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Sunbeds& UV Radiation


6. What comments were expressed on the findings of this assessment?

The source document for this publication states:

4. Comments received during the public consultation

23 comments were received mainly from public health bodies and the sunbed industry. Some from public health bodies felt the SCCP committee had not sufficiently emphasized the health risks of sunbed use and those from industry felt that we had made too much of these risks. Some comments from public health bodies were accompanied with their own documents on the risks of UVR including that from sunbeds. There were several comments on vitamin D, some stating that there was no evidence of benefits other than for skeletal health and others stating that these benefits were better established than we had stated. Overall, there were many comments on detail, some of which have been addressed but none of which alters the overall conclusions of the SCCP committee.

There were a few common themes in the comments that we have specifically addressed:

  • The erythemally weighted irradiance limit that was originally given was too high and we have now reduced this to 0.3W/m2 which is in accord with other bodies
  • There was no discussion on the effects of UVR on melanoma of the eye. This has now been addressed along with the inclusion of a study that shows a relationship between sunbed use and melanoma of the eye.
  • The lack of inclusion of CIE action spectra that have now been included in Figure 2.

Comments received:

  • Afsse (Agence Française de Sécurité Sanitaire Environnementale), InVS (Institut de Veille Sanitaire), afssaps (Agence Française de Sécurité Sanitaire des Produits de Santé)
  • Afsset (Agence Française de Sécurité Sanitaire de l’Environnement et de Travail)
  • BEUC, the European Consumers’ Organisation
  • The British Medical Association
  • Cancer Research UK
  • Dr. Jean-Pierre Cesarini, France
  • Charité – Medical University, Germany
  • Ir. G. Crevecoeur, Belgium
  • Dr. Jan C. van der Leun (Ecofys BV, the Netherlands) and Dr. Paul Donald Forbes (Toxarus, Inc., USA)
  • European Sunlight Association, Belgium
  • EUROSKIN (European Society of Skin Cancer Prevention), Germany
  • Gezondheidsraad / Health Council of the Netherlands
  • UK Health Protection Agency
  • Dr. Ph. Autier, France
  • Bayerisches Staatsministerium für Umwelt, Germany
  • Dr. Nji Ousseni, France
  • State Non-Food Products Inspectorate, Lithuania
  • Public Health Authority, Slovakia
  • Nordic Radiation Protection and Health Authorities
  • Dr. Alexander Steinmann, Germany
  • SUNARC, USA
  • Dr. Paul Donald Forbes (Toxarus, Inc., USA)
  • Hospital Universitario de la Princesa, Spain

Source & ©: SCCP "Opinion on Biological effects of ultraviolet radiation relevant to health with particular reference to sunbeds for cosmetic purposes (2006)"  4, Comments received during the public consultation, p.26


The Three-Level Structure used to communicate this SCCP Opinion is copyrighted by GreenFacts asbl/vzw