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Old 02-23-2012, 03:47 PM   #1 (permalink)
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Open response to the Waxman letter to the FDA

First I would like to introduce myself since I am new to this forum.

I am Dale Nance, CEO of Solari USA LLC. and we are in the process of becoming sponsors of TanTalk.com so I hope the moderators will not consider this post as spam.

I wanted to share a letter I wrote to the ITA in response to the Waxman letter to the FDA Commisioner. If you have not read the letter, it is in the latest ITA update email or can be found here:


My response sent to the ITA follows:

After reading the Waxman letter dated 2/17/2012 to the FDA commissioner, I felt compelled to write this response.
I am sure the members behind this letter feel that they are acting on behalf of the best interest of the public. For this, we should commend them. However, they seem to be using limited information which does not look at all factors concerning the increasing incidence of skin cancers. Their citations focus more on the effect and less on the cause. There seems to be a concerted effort by special interest groups to attack the tanning industry using the same, very generalized assumptions about the cause of skin cancers. The simple answer is to blame the tanning beds and the tanning industry. Although this may be politically convenient, it does not paint a realistic cause of photo induced skin cancers.

One statistic quoted in the letter implies that the rise in the incidence of skin cancer since 1980 is directly proportionate to the use of tanning beds. This is simply bad science and very poor statistical analysis. Many other factors which actually have some scientific study behind them paints a much different picture. For example, the use of sunscreens over this same period have increased proportionally with the incidence of skin cancers. It has been reported that the highest incidence of skin cancers in the world occur in Northern Australia. It has also been reported that Northern Australia has the highest use of sun block in the world. Since it has been shown that many chemicals used in sunblock are actually free radical generators, there seems to be a more realistic connection between use of sunblock and skin cancers. I have included several links at the bottom of this letter to substantiate my position.

I have seen, on more than one occasion, that these groups use wording which is misleading when they try to make their case before various audiences. They tend to use broad, generalizations to demonize the tanning industry. One such statement assumes that UV rays are inherently carcinogenic. If this statement or implication were true then every time a healthy skin cell was exposed to UV rays, it would turn into a carcinoma. This is simply not the case. Although I have not personally reviewed every citation put forth in the letter, I have serious questions of how they attained their conclusions. Were the test subjects screened for preconditions? Were they screened for dietary considerations, skin inflammation or other health anomalies or vitamin deficiencies? They seem to assert that the sun itself is a carcinogen. From the standpoint of common sense, I seriously doubt something as natural as the sun is a danger to life forms. Knowing that current tanning lamp technology reduces some of the UV spectrum and is therefore actually safer than tanning outdoors. These indoor tanning sessions are of limited duration and professional staff administer and oversee these sessions. Of course I know all of this is not news to you or the position of the ITA.

I would like to make you aware of the many research studies which suggest that the problem is not the UV rays, but the condition of the skin when exposed to UV rays. Many studies over the past 12 years suggest that a lack of antioxidants in the skin is the leading cause of reactive oxidation species (ROS). The studies suggest that UV induced peroxidation, releases free radical electrons which may cause damage in the epidermis. These electrons tear through tissue such as collagen and lipids. They can also penetrate cell walls and damage cell DNA. When a cell is damaged in this way, it sometimes replicates out of control. We call these cancer cells. Just as their name implies, antioxidants in our diet or topically applied, protects the skin by attracting and attaching to free radical electrons, thereby slowing or even stopping this process. So there is indeed a cause and effect here, but it is the lack of antioxidants in our diets, the removal of natural skin oils by bathing, and the chemicals we use on our skin which seem to be the problem.

As a sun tanning product manufacturer and member of the ITA, I would like these governmental bodies to know these facts. I would also like them to know that we are continuing research to bring safer oils, lotions and other skin tanning products into the market place. Our current line of products have the highest concentrations of topical antioxidants on the market and we feel that this form of skin protection will be the trend of the future. These antioxidants have been clinically tested and demonstrate that they can prevent the formation of cancerous tumors in hairless rats even after excessive doses of UV radiation.

Thank you for all you are doing to educate the public and officials about safe and responsible tanning.


Dale Nance
Solari USA LLC

Antioxidant Citations:

Sunscreen and Cancer:
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Old 02-24-2012, 12:49 AM   #2 (permalink)
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Re: Open response to the Waxman letter to the FDA

I very much commend and thank you on behalf of our industry. Also, not sure if you may or not be aware of the recent findings of The International Journal of Cancer-Relationship between sunbed use and melanona risk", which is a large case-controlled study in the United Kingdom at Leeds Cancer Research UK Centre, with the support from the Department of Dermatology, University of L'Aquila in Italy.

This study shows no link between sunbed use and melanoma AND this study is recent, so not sure if this would be helpful to add to your citation list.

Thank you again!!
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Old 02-24-2012, 11:19 AM   #3 (permalink)
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Re: Open response to the Waxman letter to the FDA

Thanks Turbo Girl!

I was not aware of this study, but a quick search turned up here:


I am impressed with the results of this study since it looks at genetic and other risk factors of the test subjects, and found no increased risk.

This is exactly my point, there are more factors, such as vitamin defeciencies, that are not considered in their citations.

The industry must fight back with scientific studies like these to counter the witch hunt.
If not, you can expect more government intervention, taxes, warnings, etc.

In light of the accusations made in the Waxman letter from "sting" operations, I would advise posting this study in your salons.
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Old 02-24-2012, 10:23 PM   #4 (permalink)
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Re: Open response to the Waxman letter to the FDA

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