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To: Chair Maile David, Co-Chair Aaron Chung, and Members of the Hawaii County
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Hawaii County Council Hearing: 9 am (HST) on Wednesday, June 15, 2022 � ,k
Re: Strong Support for Bill 167
Aloha Chair David, Co-Chair Chung, and Committee Members,
am Lisa bishop, President of Friends of Hanauma Bay and spokesperson for the
Hawaii Coral Reef Stakeholders Hui comprised of hundreds of organizations and
individuals actively working to steward Hawaii's fragile coral reefs.
Thank you for the opportunity to testify in Strong Support of Bill 167 and for your strong
leadership in passing this bill today.
Corals are keystone species to Hawaiis marine wildlife. Healthy coral reefs are vital to
the protection of our islands'coastal infrastructure, beaches, and communities.
However, Hawaii's fragile corals have been adversely impacted by many stressors for
decades, including chemical compounds in non-mineral sunscreens that inhibit coral
growth and degrade the integrity of our reefs. Hundreds of studies in the last twenty+
years have documented the adverse effects of chemical sunscreens on both
environmental and human health. Conversely, no studies have demonstrated that
chemical sunscreens are safe and effective for the environment or public health.
Some additional points which can be confirmed by experts and others testifying in
today's hearing:
1. The FDA, not the National Academy of Science (NAS), is the final jurisdictional
agency for sunscreens. After a thorough review of all existing studies and literature
on the subject, in September 2019, the FDA determined that only the minerals zinc
oxide and titanium dioxide are safe and effective for human use. All of the 14
chemical UV filters on the market in the US are Not Generally Recognized as Safe
and Effective (GRASE). Industry has had over 40 years to prove that they are
GRASE, but has not been able to do so because they are not.
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Q. What is FDA proposing for sunscreen active
ingredients in the proposed order?
A.To establish a final order for sunscreens,FDA is reviewing the active
ingredients in these products to determine whether sunscreens with such
ingredients are generally recognized as safe and effective(GRASE)for OTC
sunscreen use.This proposed order applies only to sunscreen active ingredients
listed in the 1999 stayed(not in effect)final monograph.FDA is proposing the
following categories of sunscreen ingredients:
GRASE*for Not GRASE for use in
use in sunscreens because of
sunscreens safety concerns Not GRASE for use In sunscreens because additional date needed
Zinc oxide Aminobenzoic acid Cinoxate,dioxybenzone,ensulizole,homosalate,meradimate,
and titanium (PABA)and trolamine octinoxate,octisalate,octocrylene,padimate G,sulisobenzone,
dioxide salicylate oxybenzone,avobenzone
*ERASE=Generally Recognized as Safe and Effective,when also in conformity
with all other applicable requirements.
Q: Why are titanium dioxide and zinc oxide the only
proposed GRASE ingredients?
A.FDA's review of publicly available evidence has found sufficient safety data
on both zinc oxide and titanium dioxide to support a proposal that sunscreen
products containing these ingredients(at concentrations of up to 25%)are
GRASE.
2. The NAS "sunscreen study" touted by Industry is not a study. It is a literature review
of available scientific studies already reviewed by the FDA, which determined that
chemical UV filters in sunscreens are not safe and effective. Industry lobbied Congress
for the NAS "study" in order to delay any legislative action by state and county
legislatures to ban the sale of their products, as we are witnessing in today's
testimonials proffered by paid Industry lobbyists.
3. Chemical UV filters in sunscreens are ubiquitous in our world, bioaccumulate and
biomagnify in human and other species'food chains, are toxic at the current
concentrations found in our body and environment, AND there is no evidence that they
reduce any form of skin cancer. In fact, telling people to put these sunscreens on and
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go out into the sun for hours is one of the biggest issues that the World Health
Organization has with sunscreens: "increasing intentional exposure to the sun,
increases the risk for melanoma." Sunscreens may prevent sunburn, but they have not
been proven to prevent skin cancer.
4. Dr Ku'ulei Rodgers who works at the Hawaii Institute for Marine Biology is frequently
cited in Industry testimony as not seeing any evidence of the impacts of chemical
sunscreen on coral reefs. Because she has been specifically cited by Industry as a
local expert on the issue, it is important to clarify that Dr Rodgers is not a toxicologist or
environmental chemist. She has never measured the levels of sunscreen pollution in
Hanauma Bay, studied the effects of chemicals sunscreens on corals in Hanauma, or
published any peer reviewed studies on the effects of sunscreens on corals. With great
respect, Dr Rodgers has the right to her opinion, but her comments should be
considered in context. They are clearly refuted by the hundreds of studies from eminent
scientists from around the world in different disciplines, including NOAH, who do
research the issue and document the toxic effects of chemical sunscreens on corals as
well as public health.
Sunscreen Pollution
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Chemical sunscreens are not the only stressor to our fragile marine environments or
public health, but it is the easiest one to mitigate, and mitigate immediately at no
expense to the taxpayer. Please support and pass Bill 167, a common sense bill that
will measurably benefit the fragile biodiversity of our near-shore marine environments
and coral reefs, as well as current and future generations of Hawaii residents.
With Aloha,
Lisa Bishop
President
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