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Directorate-General for Health and Food Safety
7.1 What is the SCHEER's overall conclusion regarding sunbeds and UV exposure?
UV is a complete carcinogen, both as an initiator and a promoter (both are needed for cancer to fully develop). The SCHEER concludes that there is strong evidence that exposure to UV radiation from sunbeds causes skin melanoma, squamous cell carcinoma and, to a lesser extent, basal cell carcinoma, especially when first exposure takes place at a younger age. Moreover, there is moderate evidence that sunbed exposure may also cause ocular melanoma. Sunbed use is responsible for a sizeable proportion of both melanoma and non-melanoma skin cancers among the general population and for a large fraction of melanomas that develop in people under the age of 30.
In addition, UV exposure ages the skin and may weaken the immune system. Because evidence shows that exposure to UV radiation from sunbeds causes cancer, and because of the nature of skin cancer induction, safe limits cannot be set for UV irradiance from sunbeds. They cannot be used at all without endangering human health, even if they are used following existing precautions like using them for only short durations, wearing glasses, etc. The bottom line is that using them even once can elevate someone's risk for developing skin cancer, and the only safe way to use them is not to use them at all.
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7.2 How did the Scientific Committee answer the Commission's questions pertaining to sunbeds, as given in the mandate?
1. Does new scientific and medical evidence (collected over the past decade) have a significant impact on the conclusion of the previous Opinion of 2006 with regard to the general health and safety implications relating to the exposure of people to UV radiation (UVR)? If yes, what are the key elements to be considered and how is the health of users of tanning devices for cosmetic purposes (sunbeds) likely to be affected?
There is no difference in the biological (and general health) effects induced by UV-radiation in respect to their origin, the natural solar UV or artificial UV from e.g. tanning devices with the same spectrum as the solar one. UV-radiation from the sun or from tanning devices has been classified by IARC (2009) as carcinogenic to humans (Group 1, IARC). During the last decade there has been increasing evidence that, like UVB, UVA (the main spectral component in usual tanning devices) is mutagenic. It has been shown that UV radiation introduces specific mutations in human genes which drive (“driver genes”) the induction and development of skin cancer. UV-radiation does not only introduce genetic mutations but also epigenetic alterations, which act in concert with genetic lesions to lead to skin cancer. There is moderate evidence that UV-radiation is a risk factor for ocular melanoma and is involved in age-related macular degeneration.
The UVB emitted from sunbeds can induce vitamin D production but there is no need to use sunbeds to enhance vitamin D levels. In summer, short (minutes to half an hour) daily exposures to solar UV of unprotected (e.g., no sunscreens applied) face, arms and hands have been shown to build up sufficient levels of vitamin D. At high latitudes, in the winter a suitable diet is a source of vitamin D.
In addition to the knowledge about the immunosuppressive effects of UVB, there is now evidence for an immunosuppressive effect of UVA in the wavelength range from 350–390 nm. Exposure to UVA and UVB contributes to photoaging.
It is not clear yet whether the perceived positive influence of sunbeds use on mood has a biological basis. There is insufficient evidence that sunbed use lowers blood-pressure except only temporarily, for up to half an hour after exposure. There is currently insufficient evidence for a positive effect on all-cause mortality.
There is strong evidence from case-control studies and cohort studies as well as meta-analyses of a significantly increased risk of skin melanoma associated with sunbed use. The risk increases with the number of sessions and frequency of use. Recent cohort studies show an increase in melanoma risk associated with sunbed exposure at a younger age. In addition, since all analyses have been adjusted for host factors such as tendency to sunburn, hair colour, and for sun exposure, they also suggest that sunbed use adds a specific risk of melanoma independently from individual susceptibility and behaviour in the sun. Moreover, it is estimated that in Europe 5.4% of incident melanoma cases for all ages may be related to sunbed use. This fraction is much higher in melanomas arising before the age of 30 (43% in France, 76% in Australia). Although based on a smaller number of studies than for melanoma, there is strong evidence from individual studies and meta-analyses that sunbed use is also a risk factor for squamous cell carcinoma and to a lesser extent for basal cell carcinoma, especially when exposure takes place at a younger age.
2. Does SCENIHR (who later became SCHEER) uphold the assessment of the 2006 Opinion that the limit value of the Erythemally-weighted irradiance of 0.3 W/m2 (equivalent to an UV index of 12) ensures sufficient levels of protection for the health and safety of users?
No limit value of either irradiance or dose (irradiance multiplied by time of exposure) can be given to ensure protection for the health and safety of the users of sunbeds, due to (a) the evidence of the carcinogenic effects of UVR emitted by sunbeds, and (b) the stochastic nature of skin cancer induction (no threshold levels of UV-irradiance and UV–dose are known).
3. What should be the wavelength range for which the total Erythemally-weighted irradiance should be negligible (e.g. under 0.003 W/ m2)?
The risk of developing skin cancer cannot be minimised because of the stochastic nature of cancer induction. Since there is no threshold for adverse long-term health effects, there is no wavelength range in the use of sunbeds for which the total Erythemally-weighted irradiance is negligible.
