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Home My WebLink AboutCOM 0771.402 2020-2022 Q/COWG bill V1 GOMM.1l Personal Care:Products Council Committed to Solely, Quality&Innovation May 31, 2022 ,�, Members of the Hawai'i County Council '25 Aupuni Street Hilo, Hawai'i 96720 14.4 RE:Opposition to Bill 167 = ' Dear Members of the Hawai'i County Council: On behalf of the members of the Personal Care Products Council (PCPC),1 I am writing to express our opposition to Bill 167, legislation to prohibit the sale or distribution of non-mineral sunscreens.This bill will lead to a serious public health issue by banning essential,safe and effective sunscreen products. • The U.S.has Limited Number of Sunscreen Ingredients to Fight Skin Cancer Sunscreens are a key factor in preventing and reducing the risk of skin cancer and damage from the sun's ultraviolet(UV) rays. Public health organizations, including the American Cancer Society(ACS), American Academy of Dermatology,the Mayo Clinic and the Skin Cancer Foundation, recommend using sunscreen as part of a safe-sun regimen.The Centers for Disease Control and Prevention's Sun Safety recommendations note the importance of daily sunscreen use, including on cloudy and overcast days,to help prevent most skin cancers.And, according to the World Health Organization (WHO),four out of five skin cancer cases can be prevented by following safe-sun practices, including using sunscreen regularly. • Sunscreen ingredients must be approved for use by the U.S. Food and Drug Administration (FDA)and are a crucial and well-recognized tool in the fight against skin cancer and premature skin aging.The U.S. has a limited number of approved sunscreen ingredients to develop products that protect consumers from the harmful effects of solar radiation. Hawai'i Residents at High Risk for Skin Cancer Hawaii residents are at high risk for developing skin cancer.ACS estimates that melanoma,the most serious form of skin cancer,will be one of the leading causes of new cancer cases in Hawai'i in 2022, • with an increase in melanoma rates over the past year. Hawai'i has one of the highest daily UV index •averages in the nation, making protecting residents from sun exposure a public health priority. Environmental Impact of Sunscreens is being Evaluated by the National Academies of Science, Engineering,and Medicine(NASEM) This legislation does not consider the full body of scientific evidence to establish whether UV filters pose an ecological threat to Hawaiian reef systems.This includes considerations such as the suitability and reliability of existing data to assess environmental risks in addition to the well-recognized causes of coral I Founded in 1894,the Personal Care Products Council(PCPC)is the voice and advocate for 600 member companies representing the$499.6 billion global cosmetics and personal care products industry.PCPC's members represent approximately 90%of the U.S.beauty industry and are some of the most beloved and trusted brands in beauty and personal care today.As the manufacturers,distributers and suppliers of a diverse range of products millions of consumers rely on every day—from sunscreens,toothpaste and shampoo to moisturizer,makeup and fragrance—PCPC's member companies are global leaders committed to product safety,quality and innovation. 1620 L Street NW,Ste. 1200 I Washington,DC 20036 1(202)331-17701 www.personalcaRyct x •Ik02 Ref.To: 1' 1 DUNI Ref. Dote JUN d 1 2022 Page 2 of 2 reef decline in Hawai'i and the rest of the world, including climate change, land-based pollution,and other human activities,such as physical damage to corals from recreational activities.2 Policy decisions that will adversely impact public health should not be made ahead of a scientific consensus on this issue.To reduce bias and to synthesize the best available science,the United States Congress directed the NASEM to evaluate the presence and potential impacts of organic and inorganic UV filters in freshwater and marine environments,as well as the potential public health impact of limiting access to sunscreens.The findings of the review,which is sponsored by the U.S. Environmental Protection Agency(EPA),are expected in 2022. Making environmental management decisions on sunscreens based on current insufficient and, in some cases, unreliable scientific data may lead to unintended negative health consequences,such as fewer available sunscreens and an increase in the prevalence of skin cancer while providing limited, if any, environmental improvement. PCPC encourages industry,academia, NGOs,federal agencies and the state of Hawai'i to work together to ensure that both the reef ecosystems and the health of Hawai'i's residents are protected. For all of the above reasons,we respectfully ask that you oppose Bill 167.Thank you for your consideration and the opportunity to comment. Sincerely, Karin Ross Executive Vice President,Government Affairs 2 Mitchelmore,C.L,Burns,E.E.,Conway,A.,Heyes,A.,&Davies,I.A.(2021).A critical review organic ultraviolet filter exposure,hazard,and risk to corals. Environmental Toxicology and Chemistry,40(4),967-988.https://doi.org/10.1002/etc.4948.See also Burns,E.E.&Davies,I.A.(2021).Coral Ecotoxicological Data Evaluation for the Environmental Safety Assessment of Ultraviolet Filters.Environmental Toxicology and Chemistry.DOl:10.1002/etc.5229.See also Dyer,S.D.& Green,N.S.(2021).Use of Eco-epidemiology to Assess the Potential Risks of UV Filters to Corals.Presentation to National Academies of Science,Engineering and Medicine,16 September 2021.https://www.nationalacademies.org/event/09-16-2021/docs/D885731178D23BF914365FE2D192B964EC6504FE7A7B.