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S I E R RA CLU B
HAWAII ISLAND GROUP
June 6, 2022
Hawaii County Council
25 Aupuni St. �� "„
Hilo HI 96720
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Re: Strong Support for Bill 167
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Aloha Madam Chair David, Co-Chair,and members of the County Council, vj,�te a":
Coral reefs are the rainforest of the ocean and today they face many threats including chemical
sunscreen toxicity. Hundreds of scientific peer-reviewed studies caution us about the harm
petrochemical sunscreens may cause to marine and human life. These chemicals affect coral
growth and reproduction and also harm fish and other marine life-even if you do not plan to swim
or snorkel. Sunscreen chemicals will find their way to the coast when washed off in the shower.
Bill 167 does not take away people's ability to use sunscreen. The application of a small amount of
mineral sunscreen not only protects people,but also helps Hawai`i's coral and marine ecosystems
to flourish and remain healthy for generations to come.
On the other hands, non-mineral sunscreens damage the ecosystem of the coral reefs which helps protect
us from storm surge and erosion, while nurturing a plethoria of aquatic life. The chemicals in these
products can cause DNA damage, deform coral embryos, and induce bleaching events. For green algae
and seaweeds, growth and photosynthesis are affected. For mussels, the young may develop defects.
For sea urchins,the immune and reproductive systems may be damaged, and the young may be deformed.
For fish, fertility and reproduction can be affected,and males may develop female characteristics.
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Corporation Counsel determined that Bill 167 does not interfere with the state sunscreen law. In addition,
the bill has been written to permit certain chemicals instead of banning certain chemicals,thereby
preventing sunscreen makers from reformulating their products to include chemicals not covered by a
potential ban,but are still harmful.
On September 24, 2 02 1,the FDA issued a proposed order concerning nonprescription sunscreen
drug products. In the proposed order,two mineral products zinc oxide and titanium dioxide are
deemed generally recognized as safe and effective ("GRASE") for the use in sunscreens,and
fourteen products are deemed NOT GRASE. Of the fourteen products,two are toxic and the other
twelve products do not currently contain sufficient data to support a positive GRASE classification.
The twelve products that require additional data are avobenzone,cinoxate, dioxybenzone,
ensulizole,homosalate,meradimate, octinoxate,octisalate,octocrylene, oxybenzone,padimate 0,
and sulisobenzone. For over 70 years,The FDA has asked the sunscreen industry to prove that their
petrochemicals are safe and effective and they have not.
The National Oceanic and Atmospheric Administration has already recognized this existential
threat to our coral reefs (See: Sid ica e Chemicals and Marini Lift-i�trcrr:.r:<I.Pgj �.)
Comm. No.,, 1
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Research shows both octocrylene and avobenzone pose known risks to human health as well as to
Hawaii's fragile marine environment. Octocrylene degrades into benzophenone-a"sister"
chemical to oxybenzone that is recognized by the FDA,State of California Prop65, and the WHO to
be a mutagen,carcinogen,and an endocrine disruptor.
Long-term exposure to avobenzone and octocrylene is lethal for some organisms living in
freshwater environments. See fIttp,$../ ll&_cart
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Other chemicals,such homosalate,as have found to be accumulating in the blubber of spinner
dolphins.
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The Sierra Club endorses and supports individuals for elected office who represent and advocate for our
communities' environmental and cultural resources based upon legal precedent, scientific facts and
common sense.
We ask for your strong support for Bill 167 restricting the use of sunscreen petrochemicals that have
questionable effects on the health of humans and marine life in alignment with the Precautionary
Principle precedent set by the Hawai'i Supreme Court,allowing us to protect our environment and
communities for future generations.
Mahalo,
Chuck Flaherty, Chair
Chemical
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Benzophenone Accumulates over Time from the Degradation of
Octocrylene in Commercial Sunscreen Products
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