The URL can be used to link to this page

Home My WebLink AboutCOM 0771.292 2020-2022 P/Council • 81Ur -t CONtµ.771 r! • ipA merican Mark D.Kaufmann,MD,FAAD President ®• Fh9eademy of Terrence A.Cronin Jr.,MD,FAAD President-elect D� Linda F.Stein Geld,MD,FAAD Vice President • AADermatology Robert S.Kirsner,MD,PhD,FAAD Vice President-elect •• * Association Daniel D.Bennett,MD,FAAD Secretary-Treasurer • • Keyvan Nouri,MD,MBA,FAAD Assistant Secretary-Treasurer ®• ••• Elizabeth K.Usher,MBA Executive Director&CEO HDS o C7. 1. Hawaii!Ucrmatoloploal tioctaty lA9 rbv May 27, 2022 =Y_ The Members of the Hawaii County Council 25 Aupuni Street Hilo, Hawai'I 96720 Dear Members of the Hawai'i County Council: On behalf of the Hawai'i Dermatological Society and the nearly 16,500 U.S. members of the American Academy of Dermatology Association (AADA), we write to urge you to oppose Bill 167, legislation that would prohibit the sale, offer for sale, or distribution in the state of any non-mineral sunscreen without a prescription issued by a licensed health care provider. As dermatologists we dedicate ourselves to promoting habits in our patients that ensure healthy skin. UV radiation damages the skin's DNA, which is the first stage of skin cancer. We oppose this legislation and urge you to strongly consider the broad implications of banning the use of sunscreens containing certain ingredients, bearing in mind the grave dangers of sun exposure without adequate protection that the residents and visitors of Hawai'i face. Chemical (organic) sunscreen filters are an important component of many sunscreen products. They provide ample broad-spectrum protection against UV radiation. This legislation would remove access to chemical filters, leaving only mineral filters, which are less effective. Mineral sunscreen products often leave a whitish residue on the skin. Many, especially individuals with darker skin tones, find these to be unacceptable for use. CORRESPONDENCE ROSEMONT,IL OFFICE WASHINGTON,DC OFFICE PO Box 1968 9500 W Bryn Mawr Avenue,Suite 500 1201 Pennsylvania Avenue, NW,Suite 540 Des Plaines, IL 60017-1968 Rosemont, IL 60018-5216 Washington,DC 20004-2401 EMAIL: mrc@aad.org MAIN: (847)330-0230 MAIN: (202)842-3555 ��1•�rj2 WEB: aad.org FAX: (847)240-1859 FAx: (202)842-4C9inm• No.711 -ll Ref.To: P I CI)UUn it Ref. Date JUN ® 1 202? Oppose Bill 167 May 27, 2022 Page 2 of 4 UV light exposure is a risk factor for all types of skin cancer and sunscreen use is a major photo-protective method. UVA radiation damages deeper layers of the skin and contributes to the development of melanoma, the deadliest form of skin cancer. UVB radiation is the primary cause of sunburn and plays a key role in the development of skin cancer in the skin's superficial layers. Both types of rays suppress the immune system. 1 Unprotected sun exposure is the most preventable risk factor for skin cancer. At least one in five Americans will develop skin cancer. 2,3 Caucasian men, age 50+ are at a high risk of developing melanoma. 4,5,6 In 2022, 530 new cases of melanoma are expected in Hawai'i. 7 The annual cost of treating nonmelanoma skin cancer in the U.S. is estimated at $4.8 billion, and the average annual cost of treating melanoma is approximately $3.3 billion. 8 To prevent skin cancer, the AADA recommends comprehensive sun protection that includes seeking shade; wearing protective clothing, including hats and sunglasses; and applying a broad-spectrum, water-resistant sunscreen with an SPF of 30 or higher to exposed skin. Dermatologists have an interest in patient and public access to safe and effective sunscreen ingredients. The FDA is currently working with industry on safety testing for currently marketed sunscreen ingredients. The FDA is also considering several time-and- extent applications (TEAs) for new sunscreen ingredients to be added to the FDA over-the- counter (OTC) sunscreen monograph. The FDA's conclusion from recent studies on sunscreen ingredient absorption "supports the need for further studies to determine the clinical significance of these findings." FDA further stated that"these findings do not indicate that individuals should refrain from the use of sunscreen." 9 Sunscreen ingredients have been in use for almost 50 years without any reported systemic adverse 1 Lim HW,James WD, Rigel DS,Maloney ME,Spencer JM,Bhushan R.Adverse effects of ultraviolet radiation from the use of indoor tanning equipment:time to ban the tan.Journal of the American Academy of Dermatology.2011 Apr 30;64(4):e51-60. z Stern RS. Prevalence of a history of skin cancer in 2007:results of an incidence-based model.Arch Dermatol.2010 Ma r;146(3):279-82. 3 Robinson JK.Sun Exposure,Sun Protection,and Vitamin D.JAMA 2005;294: 1541-43. 4 Siegel RL, Miller KD,Jemal A.Cancer statistics,2017.CA Cancer)Clin.2017;67:7-30. S Little EG,Eide MJ.Update on the current state of melanoma incidence.Dermatol Clin.2012:30(3):355-61. 6 NAACCR Fast Stats:An interactive quick tool for quick access to key NAACCR cancer statistics.North American Association of Central Cancer Registries.http://www.naaccr.org/.(Accessed on 3-10-2016). American Cancer Society.Cancer Facts and Figures 2022.https://www.cancer.org/content/dam/cancer- org/research/cancer-facts-a nd-statistics/an nual-cancer-facts-and-figures/2022/2022-cancer-facts-and-figures.pdf 8 Guy GP,Machlin 5,Ekwueme DU,Yabroff KR. Prevalence and costs of skin cancer treatment in the US,2002-2006 and 2007-2011.Am J Prey Med.2015;48:183-7 9 Matta,MK, Florian,J,Zusterzeel,R,Nageswara RP, Patel,V,Volpe,DAPhD,et al. Effect of Sunscreen Application on Plasma Concentration of Sunscreen Active Ingredients:A Randomized Clinical Trial.Journal of the American Medical Association 323,No.3(2020).267. Oppose Bill 167 May 27, 2022 Page 3 of 4 side effects. This issue highlights the urgent need for new safe and effective sunscreen ingredients in the United States. With the approval of ingredients that utilize alternative UV filters, the public's health will be better. The AADA continues to participate in the discussion with the FDA and manufacturers regarding availability of current and new ingredients. We are concerned about the potential environmental impact of UV-filters. The potential adverse effects related to the levels of UV-filters in the water supply and marine life (as well as humans) are an emerging science. A review of 12 studies evaluating 14 different organic UV filters in seawater near coral reefs determined that the majority of concentrations found in seawater were in the nanograms per liter range. Nine papers reported toxicological findings from no response to a variety of biological effects; these effects were detected in the micrograms per liter to milligrams per liter range, namely, at least 1000-fold higher than those reported in seawater in real life. 10 The review concludes "there is currently limited evidence to suggest that corals are adversely impacted by environmental exposure to UV filters." Our organizations advocated for the enactment of the Further Consolidated Appropriations Act, 2020, by which the U.S. Congress directed the Environmental Protection Agency(EPA) to contract with the National Academy of Sciences (NAS)to conduct a scientific literature review of current sunscreens' potential risk to the marine environment. The study will consider scientific literature on the potential public health implications as a result of reduced use of sunscreens. This type of research is necessary to understand how UV filters may affect the environment. We encourage you to consider these ongoing efforts before taking any action to remove a product that has been proven to be effective against skin cancer. Based on current data, removing specific sunscreen ingredients and products from the market would be premature. Doing so would deprive the public of an integral component of photoprotection to decrease the risk of skin cancer. Please consider the public health consequences of removing access or attaching stigma to sunscreens containing certain ingredients. We urge you to oppose Bill 167 for the reasons above, and we request that the Hawai'i County Council give the FDA more time to evaluate new sunscreens for public use and for the NAS to conduct its review and report its 10 Mitchelmore CS, Burns, EE, Conway A, Heyes A, Davies IA.A critical review of organic ultraviolet filter exposure, hazard,and risk to corals. Environ Toxicol Chem. 2020(00);00:1-21. Online 2 February 2021 in Wiley Online Library (wileyonlinelibrary.com). DOI: 10.1002/etc.4948 Oppose Bill 167 May 27, 2022 Page 4 of 4 findings. We appreciate the opportunity to provide written comments on this important public health issue. For more information, please contact Lisa Albany, director of state policy for the AADA, at LAlbany@aad.org or (202) 712-2615. Sincerely, Mark D. Kaufmann, MD, FAAD President American Academy of Dermatology Association Patrick Ellison, MD, FAAD President Hawaii Dermatological Society