Objection to proposed amendments to the Radiation Control Regulation 2003 in NSW

Tanning in solarium beds or sunny beaches, have been one of the controversial issues over the past few years. After the massive campaign in 2008 and closing down the majority of the non-compliant tanning salons across the country, Australia has adopted one of the toughest regulations in the world for the indoor tanning industry.

Current standards don’t allow people under the age of 18 and those with skin photo type 1 to use solariums. Now the NSW Department of Environment Climate Change and Water (DECCW) has suggested a new change which will ban people under the age of 30 and those with skin photo type 1 and 2 from using solariums. Although it sounds like a brilliant idea to wipe out the remaining solarium industry by changing the rules, there are several reasons why we all have to be cautious not to rush into making rash decisions.

We have all heard a lot about wanting governments to implement sound ‘evidence based policy’, yet it is rather disappointing when a State Government makes a recommendation that is almost entirely based on emotion, with a few references sprinkled in for flavour. Reading through most of the articles and studies attached to the DECCW proposal, one can see it is not possible to statistically compare natural and artificial UV induced skin cancer simply because everyone is exposed to sunlight during their daily lives but only some choose to go to solaria for a limited period of time. It is also statistically impossible to state ‘indoor tanning can increase the risk of skin cancer’ as solarium consumers expose their skin to natural sunlight more than the average population; either to sunbathe on the beach or to show their tanned skin on the street. Furthermore, most of these references are not statistically reliable because they have a very small sample size, run over a very short period of time, have no control groups, quality of the questionnaires or interviewers are unknown, researchers could possibly be biased against solariums, some have conflict of interest (sponsored by sunscreen companies), and so on.

Currently, 18 is the legal age in Australia which allows people to drive, smoke, vote, drink, etc. While adult Australians can opt to expose themselves to other proven harmful goods and services, it seems discriminatory to ban them from indoor tanning. This would definitely result in tan fans moving to their backyards or local beaches i.e. unmonitored tanning. Throughout history, tanning has gone in and out of fashion. Unlike a few decades ago when dark tan was in fashion, a natural looking tan is perceived trendy these days. According to several studies, both men and women view a tanned body as more healthy or physically attractive than a pale body.

Hence, the most effective way of dealing with the UV tanning issue would be a long-term investment in changing the fashion rather than closing down solarium beds. (to read more go to http://www.tanrayz.com.au/media/SolariumOpenLetter.pdf )