NO to Solarium Ban in NSW Australia

My Name is Jason Zahra and I am deeply concerned about the NSW government announcing they want to ban solariums. I currently run and own 3 professional indoor tanning salons for 12 years.

I don’t think this was really thought out clearly as I am married, I have 3 kids under 8; I have a mortgage just like everyone else and a business loan. Did you know that 1 solarium costs $50,000 depending on the model? I have 12.

When I went into purchasing my first business I did it with great research in 1999, even travelling to the USA. The business is solely Indoor Tanning, and Spray Tanning.

It is a legal and legitimate business that adheres to the Australian Standards. When we had voluntarily regulation it made no difference to our salon as we were following all rules well before law came into play 3 years ago.

I have written to 15,000 of my clients about this proposed ban (which im sure they know through media) and they where just as devastated as I was. We are all a family business and my clients where just as devastated as I was. They love coming to our salon because we are a trusted business, they feel comfortable knowing we have their best interest at heart and they prefer to tan in a controlled tanning environment. Our clients have done their research that’s why they come to us.

I'm also very concerned about misleading media attention and also the risk of losing my business’s and my house. I have worked hard to achieve what we have and I have ALWAYS abided by all the regulations.

My other concern also is Beauty and Hairdresser businesses that don't have the right procedures in place and allow clients to tan daily or allow under 18 year old to tan.

PLEASE don’t punish the business that are doing the right thing, ban and punish those who are not.

We embrace regulation.

UV Light Does Not Deserve the Blanket Label of 'Carcinogen'

The U.S. National Institutes of Health’s National Toxicology Program in 2000 placed ultraviolet light on the federal government’s list of known human carcinogens. In July 2009 the World Health Organization wrote a brief report also declaring that UV light is a Class I carcinogen – a list that also includes red wine, birth control pills, salted fish and other highly used substances that, when experienced in their intended dosages, do not elevate cancer risk. Much like the NIH listing in 2000, WHO erred in not pointing out that the "list" doesn't mean a substance is dangerous in every-day dosages, but only potentially in "overexposure" situations

The report states that the solariums are carcogenic - if this is the case then so is the sun and are you going to close all the beaches and pools and ban people from using other alternatives to receive UV exposure. Can you give me actual facts that all the people that visit solariums are guaranteed to get Melanoma.

People that have contracted melanoma cant guarantee that it was solely on UV light from solariums as you cant tell me these people were never exposed to external sunlight for long periods of time when they were younger. Also I was under the impression that Melanoma can take 20 to 30 years to rear its ugly form so people getting it in there 20s were not exposed from solariums

I would like you to read the following which I received from Tanning Truth.com

Saying that sunlight is harmful and therefore should be avoided is as misleading as saying that water causes drowning, and therefore we should avoid water.

Professional indoor tanning facilities promote balance and educate their patrons about the potential risks of UV over exposure. Consumers are required to read and sign consent forms that include warnings about potential eye damage, photo aging and skin cancer. Warning labels are found on every tanning device and almost always in other general areas. Professional tanning facilities used to require parental consent for teenagers who tan even though most states don't require this measure. But now it is forbidden for under 18 to tan and identification is require for proof of age.

While this serious approach to caution is just good sense, it needs to be noted that understanding the risks of UV exposure is not as straightforward as some suggest. Consider: Research has not established a "casual" relationship Between Melanoma and Indoor Tanning.

Melanoma skin cancer is the most aggressive of the three major categories of skin cancer, accounting for only 5 percent of all skin cancer cases each year, but responsible for a majority of skin cancer fatalities (Approximately 8,000 annually).

While melanoma has captured a great deal of public attention in the past 15 years, much of the discussion has been oversimplified in stating that melanoma is caused by overexposure to sunlight. In fact, the exact nature of the relationship between melanoma and ultraviolet light remains unclear, and the mechanism by which the two are related is still unknown – which is why some independent dermatology researchers even question whether the two are related at all.

While it is believed that melanoma is somehow related to ultraviolet light exposure, this relationship is not straight-forward and the photobiology research community still does not know how it works. That’s because while a minority of associative survey-studies have suggested a correlation between UV from indoor tanning and melanoma, no direct experimental evidence exists to show a causative connection. Even American Academy o fDermatology spokes person Dr. James Spencer admits, "We don’t have direct experimental evidence" connecting indoor tanning and melanoma.

Melanoma is more common in people who work indoors than in those who work outdoors, and those who work both indoors and outdoors get the fewest melanomas. Because this is true, the relationship between melanoma and sunlight cannot possibly be clear-cut. If it were a clear-cut relationship, outside workers would have higher incidence than inside workers. But the opposite is true.

Melanoma most commonly appears on parts of the body that do not receive regular exposure to sunlight. Again, because this is true, the relationship between melanoma and sunlight cannot be clear-cut. If it were, melanomas would appear most often on parts of the body that receive the most sunlight.

18 of 23 epidemiological studies ever conducted attempting to correlate indoor tanning and melanoma incidence show no statistically significant association – including the largest independent study, a 2005 multi-ethnic international European study which reported, "The relationship between UVR and melanoma is very complex and, despite many studies on the topic, remains a controversial issue. Some patterns of sun exposure may also offer protection, as some studies have suggested that people with heavy occupational exposure to the sun exhibit a lower risk for melanoma compared to individuals with intermittent sun exposure. In conclusion, sunbed and sun exposure were not found to be significant risk factors for melanoma in this case–control study performed in five European countries."

A 2009 opinion paper published by an ad-hoc working group representing the World Health Organization’s International Agency for Research on Cancer has been widely misrepresented in the media. That report’s actual conclusion stated, "Epidemiologic studies to date give no consistent evidence that use of indoor tanning facilities in general is associated with the development of melanoma or skin cancer." While the report attempted to suggest that performing a meta-analysis of the old data showed a 75 percent increased risk for those who started tanning at an early age, the authors failed to disclose that conclusion failed to take into account that removing those with skin so fair it cannot tan – called Skin Type I – from the analysis made the overall results statistically insignificant.

Dr. William Grant, founder of the Sunlight, Nutrition and Health Research Center in San Francisco, published a peer-reviewed critique of the IARC report showing that, after adjusting for skin type, the analysis showed no increased risk with indoor tanning.
Closer analysis of IARC report data (by Dr. Mia Papas and Dr. Anne Chappelle) – when separated by unsupervised home tanning equipment verses usage in indoor tanning facilities and medical usage of tanning equipment in doctor’s offices – reveals that no statistically significant increase in risk (6 percent) was attributable to commercial tanning facility usage, while larger increases (40 percent and 96 percent) were attributable to home and medical usage of tanning equipment.

A 2010 University of Minnesota study on fair-skinned Minnesotans claimed to show a connection between tanning and melanoma but actually supported Grant’s point that UV-related risk seems centered on the fairest skin type. But the study also showed that those who got the most outdoor sun exposure had the lowest risk of melanoma – a divergent conclusion to the rest of the paper underscoring that whatever relationship UV and melanoma may have is still not understood.

The relative risk of melanoma is very small – much less than 1 percent and very close to the relative risk for non-tanners – and is often misreported. As reported in the Wilmington News Journal, "Even the IARC’s strongest study – which followed more than 100,000 women over eight years – found that less than three-tenths of one percent who tanned frequently developed melanoma, while less than two-tenths of one percent who didn’t tan developed melanoma. Almost all the other studies in the report did not establish a strong link between the two. The overall risk of contracting melanoma – whether using tanning beds or not – remains well under 1 percent. For that reason, using the 75 percent statistic is misleading, said Dr.LisaM. Schwartz, general internist at Veterans Affairs Medical Center in VT and co-author of "Know Your Chances," a book on understanding health statistics..."Melanoma is pretty rare and almost all the time, the way to make it look scarier is to present the relative change, the 75 percent increase, rather than to point out that it is still really rare."

"Absolute risk just tells you the chance of something happening, while relative risk tells you how that risk compares to another risk, as a ratio. If a risk doubles, for example, that’s a relative risk of 2, or 200 percent. If it halves, it’s .5, or 50 percent. Generally, when you’re dealing with small absolute risks, as we are with melanoma, the relative risk differences will seem much greater than the absolute risk differences. You can see how if someone is lobbying to ban something – or, in the case of a new drug, trying to show a dramatic effect – they would probably want to use the relative risk."-Ivan Oransky, M.D.

The American Cancer Society’s key document measuring cancer rates in the United States– "Cancer Facts and Figures" – says that melanoma rates have not increased since 2000 and that rates are declining for women under age 50 - the opposite of what anti-tanning lobbying groups claim. "During the 1970's, the incidence rate of melanoma increased rapidly by about 6 percent per year. However, from 1981-2000, the rate of increase slowed to 3 percent per year and since 2000 melanoma incidence has been stable," the ACS "Cancer Facts and Figures 2008" reports. "The death rate for melanoma has been decreasing rapidly in whites younger than 50, by 3 percent per year since 1991 in men and by 2.3 percent per year since 1985 in women."

A paper published by the British dermatology community in 2009 showed that "diagnostic drift" and more aggressive screening are responsible for the increase in "reported" melanomas, but that there isn’t an actual increase in thick melanoma lesions, which explains why the mortality rate is not increasing. According to the authors, "These findings should lead to a reconsideration of the treatment of ‘early’ lesions, a search for better diagnostic methods to distinguish them from truly malignant melanomas, re-evaluation of the role of ultraviolet radiation and recommendations for protection from it, as well as the need for a new direction in the search for the cause of melanoma.
Many scientists and dermatologists have taken firm positions that melanoma's connection to UV light is unclear or doesn't exist at all. Dr Bernard Ackerman – a pioneer in dermatology pathology who was recognized as a master dermatologist by the American Academy of Dermatology – the Academy’s highest honor – insists there is no evidence connecting UV and melanoma in his monograph, "The Sun and the Epidemic of Melanoma: Myth on Myth. According to Ackerman: "The American Academy of Dermatology, for decades, has kept up a drumbeat on behalf of faith in an epidemic of melanoma and rays of the sun as the major cause of it, at the same time that it has flayed, incessantly, the tanning bed industry. Although the organization is termed an Academy, never has it presented in fashion academic a whit of evidence, available readily, contrary to its position entrenched, namely, there is no epidemic of melanoma and that tanning beds have not been proven to be a cause direct of melanoma."

"There is no proof whatsoever that blistering sun-burns, no matter the number and even in childhood, enhance risk for development of melanoma and there is no evidence at all that sunscreens prevent development of melanoma. What is more, it has yet to be established that exposure excessive to sunlight (or sun lamps and tanning beds) alone, in the absence of inclination genetic, causes melanoma."
Dr. Sam Shuster, Emeritus Professor of Dermatology at the University of Newcastle, penned "The Skin Cancer Cover-Up" to point out that there is no hard evidence that UV is the cause of melanoma or that there is an actual increase in melanoma incidence.

Dr. Arthur R. Rhodes, Professor of Dermatology at Rush Medical College, in Chicago, believes that melanoma’s public message needs to stop focusing on UV light – pointing out that UV-melanoma campaigns are killing people who get melanoma who failed to recognize the disease because they never spent time in the sun.

UV Light Does Not Deserve the Blanket Label of 'Carcinogen'. The U.S. National Institutes of Health’s National Toxicology Program in 2000 placed ultraviolet light on the federal government’s list of known human carcinogens. In July 2009 the World Health Organization wrote a brief report also declaring that UV light is a Class I carcinogen – a list that also includes red wine, birth control pills, salted fish and other highly used substances that, when experienced in their intended dosages, do not elevate cancer risk. Much like the NIH listing in 2000, WHO erred in not pointing out that the "list" doesn't mean a substance is dangerous in every-day dosages, but only potentially in "overexposure" situations.

The listing does not mean that moderate tanning will cause skin cancer. The NIH listing criteria shows us why: "The Report does not present quantitative assessments of carcinogenic risk. Listing of substances in the Report, therefore, does not establish that such substances present carcinogenic risks to individuals in their daily lives." This exclusion – in the absence of any direct experimental research on indoor tanning and melanoma – makes this listing almost meaningless. The list does not take into account that there are positive effects to ultraviolet light exposure. Many forms of cancer – including breast, colon, prostate and ovarian tumors – now appear to be retarded or even prevented by regular exposure to ultraviolet light. This omission on the NTP list is conspicuous, given that positive effects are listed for other substances in the government's list of carcinogens that have positive effects, such as the breast cancer drug Tamoxifen, which is a Class I carcinogen.

As a result, thousands of news reports suggest that "sun tanning is as dangerous as tobacco" – a blatant misrepresentation. Smoker’s risk of lung cancer: 15 percent – or 2,000 percent higher than that of non-smokers. Smoking introduces up to 60 man-made known carcinogens into the body – substances the body was never designed to process. Smoking is related to 1 in 3 cancer deaths.

Tanner’s risk of melanoma: 0.3 percent – compared to 0.2 percent for non-tanners (a difference of 1 in 1,000) The body needs ultraviolet light to survive – calling it a carcinogen without that caveat is totally misleading.
One thing we know for certain: You would be dead today if you did not receive any ultraviolet light. The "60 Minutes Program" by focused on 'one person' who was, allegedly going to die from melanoma. She claims that she had 8 sessions. I would have thought 8 sessions ( no mention of how long) would not be an issue unless she stayed in there for 3 months at a time? In any event melanoma is rare, and this is what they don't tell the public as well as the dubious 70% increased risk, which like a lot of studies, are a little jaded. Lobbyists focus on the relevant risk instead of the absolute risk - so when people see a report like was on 60 Minutes, everyone goes 'oh my god, those dangerous tanning beds killing people!'

Not one mention was about vitamin d deficiency etc - the attack was purely on solariums. It was a very unprofessional and incomplete report by 60 Minutes

My concerns are relating to the proposed ban on Commercial Solariums in NSW. I think this is a knee jerk decision and quite confused by it all. If anything Melanoma will still increase as the risk of reckless tanning outdoors will increase with more and more people burning in the harsh sun. Also Melanoma is not just contributed by UV light. Many of the research has noted that melanoma appears on people that don't even tan and cover up daily so why can this be one sided and blamed solely on solariums. They can ban Solariums and not ban smoking, alcohol, high powered cars and motor bikes, which are known to kill more people daily than anything else. The negative research is only listened to - Why does no one listen to the positive research. Lobbyists are doing there best to be one sided and they only have tunnel vision.

I have clients sent to me on a regular basis by doctors for different reasons - some relating to skin conditions, depression and vitamin D deficiencies.

The industry supports tough measures with salons not complying with the rules and regulations.

We have always taught our customers on moderation and education on Tanning indoors and outdoors.

I hope to hear a response from you in regards this and hope you see two sides to this matter. I fully support the laws on indoor tanning and yes we should all be aware on educating people on moderation and how not to overexpose your skin to too much UV light. I also think that we need to concentrate on salons that are not complying to the regulations.

As NSW mentioned that they are going to ban commercial but not home use. This is so ridiculous and wrong how can you control the use at home and who uses them. People will be exposed to UV light in which ever form they wish. They will lay out in the sun more and the control of exposure will be gone to the people that do love to tan. All we are doing is allowing clients to tan in a controlled environment.