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Home My WebLink AboutCOM 0771.267 2020-2022 P/CU-nci I b,11 167 COMM.-T/1 In Strong Support of Bill 167, AN ORDINANCE AMENDING CHAPTER 14 OF THE HAWAII COUNTY CODE 1983 (2016 EDITION, AS AMENDED), BY ADDING A NEW ARTICLE RELATING TO PROHIBITION OF NON-MINERAL SUNSCREEN Joe DiNardo—Toxicologist June 1, 2022 a The following comments are based on my experience with product development, regulatory compliance as waZas pret2 clinical and clinical safety testing with some environmental testing of Over-the-Counter sunscreen actives ander formulations dating back to 1976. Dear Chair Rebecca Villegas, Co-Chair Heather Kimball, and members of the Committee on Climates Resilience& Natural Management .= --- I would like to thank the Committee for the opportunity to comment on this very important environmental and human health bill relating to non-mineral sunscreens also known as organic sunscreen actives or soluble organic ultraviolet filters (SOUVF) .The word "organic" in this case simply means that the element "Carbon" is present in the chemical mixture. Zinc and Titanium are elements or minerals (they do not contain "Carbon") that can be found on the table of periodic elements.They are reacted with oxygen to form Zinc Oxide and Titanium Dioxide and have many uses in consumer products. Both ingredients have been shown to be safe and effective sunscreen ingredients by the Food & Drug Administration (FDA) who has the legal authority to determine what is or is not safe for human use. Organic sunscreens are not simply reacted with oxygen, instead they are complex mixtures of many chemicals. For example, the organic sunscreen active "Octocrylene" is a mixture of two chemicals (2-ethylhexyl cyanoacetate and benzophenone).The first chemical "2-ethylhexyl cyanoacetate"contains the poison "cyanide" and the second chemical "benzophenone" (patented in the 1950's as a pesticide) has been shown to cause cancer and was recently banned by FDA (as of late 2020) for use in foods. Octocrylene is an unstable chemical mixture, once in comes into contact with water (in a product or swimming ... etc.) it falls apart making both a cancer causing pesticide and a poison that can harm humans and aquatic life. Avobenzone, a different organic sunscreen active, has also been demonstrated to be unstable and falls apart in the product leaving individuals believing they are protected from ultraviolet light when they are not. These are just two of several reasons why the FDA has removed these organic actives from the list of safe and effective ingredients that can be used in sunscreens. Octocrylene and Avobenzone are not the only organic sunscreen actives in question.The FDA after reviewing the published science has removed all 14 organic sunscreen actives from the safe and effective list, because they demonstrate some form of toxicity. Additionally, all of the organic sunscreen actives are small enough to pass through the skin, go into the blood, and pass through the placenta barrier entering the developing fetus. Many Pediatricians and Dermatologist have recently recognized this issue and are telling their patients not to use organic sunscreens during pregnancy or on children. Simply put, all 14 organic sunscreen actives demonstrate significant toxicity -to human and aquatic life - at a level that required governmental intervention. Comm. No. Ref. To: cirldt W1“ Ref. Date JUN — 1 2°22 — In addition to the toxicity associated with the use of organic sunscreen actives, the science shows that skin cancer deaths rose about 50%since the 1970's regardless of the use of sunscreens and the American Medical Association has recently published a paper projecting that skin cancer will continue to increase through 2040. The World Health Organization stated that "No conclusion can be drawn about the cancer-preventive activity of topical use of sunscreens against basal-cell carcinoma and cutaneous melanoma" and that intentionally increasing one's time in the sun, increases the risk of skin cancer. The theory of sunscreens preventing skin cancer is based on stopping sunburn. Unfortunately, minimizing/stopping skin cancer is a lot more involved that just preventing sunburn. It requires protection from the whole ultraviolet spectrum not just the part that causes sunburn (290 to 320 nm). This is something that Zinc Oxide and Titanium Dioxide are more suited to do (see below). Because of this finding many sunscreen companies have removed the term "skin cancer" from their TV commercials. OffersEbroad-spectrumCbrotection? Absorptionlbands[ ndC riticalNvavelengthiorC heinostUtommonlya sedllUVIIIters*0 Conc.(%)1 UV Attenuation(nm)2 sem® Peak Absorbance -_ Wavelength(nm) 290 . 300 - 10 320.. 330 . 340 ' .1 370 380 r4 :, PBSA(2-phenylbenzimidazole 4 F > -s-sulfonic acid) lCbasal[EellaThelanomaNavelength**E OSAL(octyi salicylate) 5 HSAL(homosalate) 15 I_ em OPABA(octyldimethyl PABA) 8 issomm' OMC(octyl 7.5 a methoxycinnamate) OCTO(octocrylene) 10 OXY(oxybenzone) 6 Mmiinalaima 1 MAN(menthyi anthraniiate) 5 TiO2(titanium dioxide) 25 ik ZnO(zinc oxide) 25 AVO(avobenzone) 3 'The maximum concentration established in the Sunscreen Drug Products for Over-the-Counter Human Use;Final Monogr'; 'The UV attenuation is based on substrate spectrophotometry determinations. Filters were prepared in a repres -- 'Determined at 2%o/w emulsion °Determined at 15%o/w emulsion. SShapeo:_.: *Diffeyl talEiDAMIAcad(IDermatola000;43:.024-35M *McDaniel@tfil, rOsmet®ermatollam.8(87:12y-13711 Note: Only Titanium Dioxide, Zinc Oxide and Avobenzone reach across the ultraviolet spectrum (290 to 400 nm), unfortunately Avobenzone is very unstable and can interact with other chemicals, like the organic sunscreen Octinoxate, to be rendered ineffective. Mahalo!