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HomeMy WebLinkAboutCOM 0771.472 2020-2022 P/Counb ,bill 167 CAMM.711 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 SUNSCRE04 r, Joe DiNardo—Toxicologist ` ©� June 15, 2022 The following comments are based on my experience with product development, regulatory compliance asovell aspke- clinical and clinical safety testing with some environmental testing of Over-the-Counter sunscreen actives"d 'Ic- formulations dating back to 1976. *_J =`_ Dear Chair Maile David, Co-Chair Aaron Chung, and the members of the Council. 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 (it becomes inactive, not effective) in the product leaving individuals believing they are protected from ultraviolet light when they are not. Additionally, the actives Homosalate and Octisalate both have the ability to breakdown into chemicals that we know produce birth defects. These are just a few of the reasons why the FDA has removed these organic actives from the list of safe and effective ingredients that can be used in sunscreens. Octocrylene, Avobenzone, Homosalate and Octisalate 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. Comm.� Ref.Tb. M Ref.DC7"® Additionally, the impact that these chemicals have in humans are not the only concern. There are numerous studies that have been published demonstrating that these chemicals are toxic- at the levels they are found at in the environment-to numerous aquatic species. The National Oceanic and Atmospheric Administration (NOAA) Official View (https://oceanservice.noaa.gov/news/sunscreen-corals.html) states that "Common chemicals used in thousands of products to protect against harmful effects of ultraviolet light threaten corals and other marine life." Please note that not only is coral listed as being harmed by these chemicals, but so are green algae, mussels, sea urchins, fish and dolphins. SUNSCREEN CHEMICALS D MARINE LIFE How sunscreen chemicals enter our environment: The sunscreen you apply may not stay When we swim or shower,sunscreen may vkk an your skin. wash off and enter our waterways v. How can affect marine life: Chemicals in some sunscreensCan impair Accumulates in tissu , that can harm marine life: es. n induce defects In young. growth and photosynthesis. Can induce bleaching,damage MUSSELS •3-Benzylidene camphor DNA,deform young and even kill. •a Methylbe"Vildene _ph or •Octocrylan, •Bent.phen.ne-] •8enzophenone-8 OD-PABA nano-Titanium divide o-Zinc.vide Can damage Can decrease fertility and Can accumulate in tissues and zin.ate immune and reproductive reproduction,and cause female be transferred to young. •O.yberuo e systems,and deform young. characteristics In male fish. Here are a few ways to and -iarine life: Consider sunscreen without chemicals that can harm marine life,seek shade between I am&2 pm,and use Ultraviolet Protection Factor(UPF)sunwear. 4. a %;7 Seekshade Umbrella Sun hat ten UV Sun glasses Sun shirt Leggings Simply put, all 14 organic sunscreen actives demonstrate significant toxicity-to human and aquatic life - at a level that required governmental intervention. 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". They go on to explain that intentionally increasing one's time in the sun, increases the risk of skin cancer. The theory of organic sunscreen actives preventing skin cancer is based on stopping sunburn. Unfortunately, minimizing/stopping skin cancer is more involved that just preventing sunburn. It requires protection from the whole ultraviolet spectrum (290—400 nm) 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 they absorb across the whole spectrum. Because of these findings many sunscreen companies have recently removed the term "skin cancer" from their TV commercials. Offers broad -spectrum protection? bands and critical wavelength for the most commonly used UVfilters* ®Basal Cell& AIM.noma Wavelength** *Djffey et al J Am Acad Dermatol.2000;43:1024-3S&**McDaniel et al,J Cosmet Dermatol 2oi8,37:2.24-137 Note: Only Titanium Dioxide, Zinc Oxide and to some extent 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 and is rendered ineffective—leaving only Titanium Dioxide and Zinc Oxide as full spectrum absorbers. The graph above was published over 22 years ago by Diffey ... it is time to face the facts that organic sunscreen actives are Not Safe or Effective for their intended use in humans and they are environmentally damaging or as NOAA summarized in their infographic, they threaten corals and other marine life! Mahalo!