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Aloha Chair David and Co-Chair Chung,
Since we will be on a plane at the time of the hearing, Dr. Denis Dudley and Dr. Sharyn
Laughlin request that Lisa Bishop be allowed to read our testimony below into the
record on our behalf. We felt that it was crucial to have testimony with a clinical
perspective from two MDs who are in very relevant disciplines - Dermatology and
Perinatology/Reproductive Endocrinology. After all, skin cancer is a clinical medical
problem and the adverse effects of Soluble UV Filter (petrochemical) sunscreens are
mostly endocrine disruption and reproductivelperinatal toxicity.
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In the Matter of Bill 167 - Strong Support
To : Chair Maile David, Co-Chair Aaron Chung, Members of Council - a- ----
June 14, 2022
Submitted by:
- Denis K. Dudley MD, Maternal-Fetal Medicine & Reproductive Endocrinology.
- Sharyn A. Laughlin MD, Dermatology/Photobiology.
A Benefit Risk Analysis of Sunscreen Use:
• Since 1973 sixteen publications establish that sunscreens do not prevent skin
cancer. Early warnings from Autier et al and the International Agency for Research
in Cancer (IARC) in 1995 (Int J of Cancer 1995) and over the next 10 years five
more studies from IARC, WHO, the EPA, all said there was no evidence that
sunscreens prevented skin cancer.
• From 2015 to 2022, seven reviews confirmed earlier studies: Sanchez et al
Cochrane Database Syst Rev 2016, Silva et al Eur J Dermatol 2018, Waldman &
Grant Kels J Am Acad Dermatol 2019, Rueegg et al Int J Cancer 2019, Dudley et al
Current Probl Dermatol 2021, DiNardo & Downs Toxicol 2021, Matouskova &
Vandenberg Environmental Health 2022.
• ONLY one contemporary study Green et al J Clin Oncol 2011 showed a benefit of
poor validity with a selection and funding bias. This single flawed study is used to
claim that sunscreens prevent skin cancer.
Conclusion: There is no credible evidence that sunscreens prevent skin cancer.
Since 90% of global sunscreens are Petrochemical the lack of benefit indicts
them and may not include mineral products. There is an explanation for the
failure of petrochemical products. They can only achieve UVB-BIASED protection
where up to 10X more UVA than UVB reaches your skin (Dudley et al Curr Probl
Dermatol 2021). Zinc oxide at 20-25% with superior UVA filtering can offer the UVA
protection that modern science shows is needed to prevent skin cancer.
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• All 12 petrochemical UV filters were designated - NOT Generally Regarded As
Safe and Effective (GRASE) by the FDA in 2019, and still remain as "Marketed
Unapproved". ALL enter human blood and pollute every organ in the body,
including the brain, and the fetus. Many studies from 1995 and the recent FDA
studies in 2019 and 2020 prove they are bioavailable to humans and wildlife. The
CDC using data from the National Health and Nutrition Examination Survey
(NHANES) warned that 95.8% of Americans age 6-70 both genders had
oxybenzone contamination (Calafat 2011). 100% of pregnant women and 98% of
non pregnant women were contaminated as well (Woodruff TJ, Environ Health
Perspectives 2011). ONLY the 2 mineral filters do not pollute our bodies or the
environment and are still considered GRASE by the FDA.
• Many studies- too numerous to list - confirm the ubiquitous contamination and
toxicity from petrochemical sunscreens to humans, many animal species, fish,
mussels, crustaceans, turtles, eggs of marine birds, dolphins, sea grass, and the
food web. They are described in Matouskova and Vandenberg (Environmental
Health 2022) and Carve et al, who chronicled 453 international studies on the
pollution and toxicity to humans and the environment (Science of Total Environment
2022). Two other reviews (from many) document toxicity. Wang J et al J Environ
Res Public Health 2016, and Ghazipura et al Reproductive Toxicology 2017. Few
dermatologists may read these journals, which could explain why they remain
largely unaware of the No Benefit- Only Risk paradigm.
• Studies from the FDA and others on blood levels only assess limited application
over days and weeks. They give no insight in to the actual human contamination
from the daily and repeated use of bioavailable petrochemical sunscreens over
long use or a lifetime.
• The toxicity in humans linked to the use of these chemicals with potential or actual
genotoxic and Endocrine Nervous Disruption (END) effects include, but are not
limited to, early miscarriage, fetal growth problems, birth defects, abnormal puberty,
metabolic syndrome, obesity, pre diabetes, polycystic ovarian syndrome, infertility,
endometriosis, thyroid cancer, and prostate cancer, to name the most studied.
Summary:
• It is malfeasance to expose a human fetus to these petrochemical agents with
known END effects and possible genotoxicity. They are structural analogues to
DDT and other END chemicals like Bisphenol A (BPR) and resemble human
estrogen with the ability to displace human hormones of several types. All 12 have
the potential to do this, based on the Endocrine Principle of isoform function in
humans. Randomized control trials will never be ethical or feasible to address fetal
toxicity, and animal work is invalid as humans have different dose response
physiology to END effects.
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• Physicians have a duty of care and sacred obligation to do no harm (medicine's
first rule). This is only achieved by avoiding petrochemical sunscreens in all
patients. Millions of newborns are born polluted - an egregious example of
intergenerational injustice. Some dermatologists are now embracing our advice for
caution. Viola & Grant Kels in the J Am Acad Dermatol 2021, now advise that only
mineral filters be given to women of child bearing age and in pregnancy. We ask
what is the difference for young children or any adult.
• The global water reservoirs, wildlife, the entire environment, and human civilization
are polluted by petrochemical sunscreens with no human benefit. Zinc oxide is not
bioavailable and is w/o risk to humans. It is not accumulating in the environment,
and provides better UVA and Broad Spectrum protection against skin cancer and
sun damage.
• All of us - physicians, scientists, regulators, lawmakers, and every citizen must take
responsibility, and act to protect our progeny and the planet. We advocate that it is
arguably malpractice, for physician to continue using petrochemical sunscreens in
any patient, given the present state of knowledge. The Hawaii example is
courageous and leads the way. Sadly, it is an exception rather than the rule.
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We thank you for the opportunity to testify in strong support of Bill 167.
Denis K. Dudley MD
Sharyn A. Laughlin MD
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