JOHN @ URI

There is no regulation yet on whether or not the existing sunbeds on the market will be "grandfathered" or have to meet these regulations within 6 months. The European nations will also have to come up with there own enforcement and rules which include all these regulations. Kind of like the FDA regulations, some states have no enforcement at all & others are very strict.

Don, have you tested any of the new sunlamps being implemented in Europe? I just met with a prominate Euro lamp manufacturer last week, they were both pleased & surprised by what can be produced & still meet the regs.

Your right, there won't be as many. But there will be a sufficient amount to provide plenty of Vit D. How much do you get in a 12 min VHOR session currently? I'm sure 15 minutes will supply the average person with the recommended daily dose.

Yeah with out the ITA (which is mainly Manufacturers & distributors) the under 18 rule would have already been implemented in many states. The salons & manufacturers need to work together to fight these things.

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Don Smith

I have spent a considerable amount of time looking at the "impact" of the 0.3 MEIL because I believe that this "directive" will surface here in the USA later this year, primarily because the vendors have shown (in Europe) that they won't fight it. [Is it possible that both the vendors and the dermatology community will be in favor of adopting the 0.3 W/m^2 MEIL in the USA?]

Here is what happens when sunbed equipped a traditional and a new era (160w) sunlamps are replaced with 0.3 W/m^2 compliant sunlamps.

Traditional:

- Goes from 0.549 W/m^2 to 0.3 W/m^2

- The Te (4.0 MED) time (FDA EAS) goes from 13.8 minutes to 24.5 minutes

- The Tt (Tanning) time goes from 18.4 to 28.6 minutes.

New Era:

- Goes from 0.556 W/m^2 to 0.3 W/m^2

- The Te (4.0 MED) time (FDA EAS) goes from 13.8 minutes to 26.4 minutes

- The Tt (Tanning) time goes from 7.9 to 15.3 minutes.

Does that look like a step in the right direction?

If your "point" is that new era 0.3 W/m^2 compliant sunlamps have more tanning power than 0.3 compliant traditional sunlamps, you are correct. If, however, your "point" is that the 0.3 W/m^2 new era sunlamps will be acceptable to USA clients (who want shorter session times), you are sadly mistaken.

And to those "misguided" individuals who believe that the 0.3 W/m^2 MEIL will result in a reduction of the efforts of the anti-tanning coalition to destroy the European indoor tanning industry, I have some ocean front property here in AZ to sell you. The sad fact of life is that a small group of rabidly anti-tanning regulators have won a major victory in Europe and this "win" will embolden them to enact more onerous provisions.

tanfixr

A simplified and direct issue is, how/why do the regulators in Europe think that the "dose rate" or intensity is a scientifically valid target for regulation, rather than the dose?

And since there is no sensible or reasonable answer to that question, how do we keep the FDA from making the same mistake of forgetting the most basic of photobiological principles (reciprocity)?