FDA is preparing a proposal to increase consumer awareness of tanning bed risks.

The question is if FDA's proposal to increase consumer awareness of tanning bed risks is based upon facts or anecdotal fiction spread through communication in mass-media?

A clear indication of the latter is found in a statement in FDA's press-announcement about their proposal to increase consumer awareness of tanning bed risks:

“According to the American Academy of Dermatology, there is a 75 percent increase in the risk of melanoma, the deadliest type of skin cancer, in those who have been exposed to ultraviolet radiation from indoor tanning, and the risk increases with each use”.

IARC (2006) Exposure to Artificial UV Radiation and Skin CancerThe figure used by AAD (as in FDA's press-announcement) is actually coming from the IARC report from 2006, “Exposure to Artificial UV Radiation and Skin Cancer”, which laid the ground for IARC's classification of tanning beds as carcinogens in Group I (dangerous to humans) in 2009.

In addition to Dr. William Grant's critique of the IARC report, showing that tanning in commercial indoor tanning salons was a statistically insignificant part of the meta-analysis in the report, there are some other issues with the referral to the statement from AAD about “a 75 percent increase in melanoma”.

1. Dermatologist who are members of AAD have billions to gain from getting a monopoly on indoor tanning. 

AAD_2011-Corporate-Partner-Circle-Members

2. The corporate sponsors (corporate partners circle members, see image) of AAD consists of companies which are making huge profit either from the treatments of the victims of over-diagnosis of skin-cancer or from people trying to protect themselves from skin-cancer. It is quite obvious that none of those commercial companies has any interest in reducing skin-cancer diagnoses. On the contrary, they are also, together with AAD, the Skin-Cancer Foundation and other similar organizations, the sponsors of screening campaigns for early detection of skin-cancer, the real cause of the over-diagnoses.

3. The “75% increase” refers to is based upon a relative increase found in the meta-study made by IARC in 2006 of “ever” use of tanning beds. In real figures the statistical risk was still below 0.3%.

The use of relative statistical figures is a fraudulent way to hide real figures and forbidden, for example, in the promotion of gambling.

Also the “ever” use of tanning beds before the age of 35 is a very unscientific criteria. To quote an often used parallel by the opponents to indoor tanning, it would be like saying that smoking one cigarette would increase the risk of lung-cancer with 75%. Even if it might be a statistically viable relative figure, it goes without saying that this is a totally ridiculous statement. 

The IARC-report from 2006 report is actually using a much less affirmative language. Here is the quote from the conclusion in the IARC study “Exposure to Artificial UV Radiation and Skin Cancer” (2006), the real origin of the “75% increase” statement (emphasizes mine): 

Our systematic review of published studies, conducted mainly in North America and Europe, of the association of indoor tanning facility use with melanoma revealed an association of early age at first use (less than approximately 30 years) with melanoma risk. These studies consistently indicated a moderate strength of associationwith a summary relative risk of 1.75 (1.35–2.26). The association with ever use of these facilities, or use more than 15 to 20 years prior to diagnosis of melanoma, was weak, and evidence regarding a dose–response relationship was scanty. The evidence is limited by variation in characterization of exposure, potential confounding by sun exposure or other variables, and the low power to detect associations that become evident only following a prolonged lag period after exposure.”

4. Most of the case-control studies in the meta-analysis made by IARC collected the skin-cancer “cases” from the national cancer registers of skin-cancer incidences  It is by now a more and more officially known fact that the statistics of incidences contains a huge-number of over-diagnosis of skin-cancer. Even experienced and qualified dermatologists estimates the number of false diagnosis needed to catch one real skin-cancer to at least 10 to 1 and in non-specialized clinics the relationship can be as high as 93 to 1. None of the studies used in the meta-analyses made any adjustment for the possibility of over-diagnoses among the number of “cases” in the studies.

Taking into account the issues above, it seems quite possible that FDA's Proposal To Increase Consumer Awareness Of Tanning Bed Risks may be misguided by AAD and other organizations which, for various reasons, have the extinction of commercial indoor tanning on their agenda.

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