July 30, 2014
Barton Bonn, President
American Suntanning Association
PO Box 1907
Jackson, Mississippi 49204
bonnbart@gmail.com
apmillerlaw@aol.com
Dear Mr. Bonn:
Thank you for bringing to our attention the Information Quality Request for Correction submitted on behalf of the American Suntanning Association. We have reviewed the materials submitted with the request and the information presented on the CDC website regarding Indoor Tanning. CDC is committed to ensuring that the information presented to the public on its website and in other materials is accurate and represents the best available scientific evidence. The information contained on CDC's website on Indoor Tanning conveys information about general risks of artificial UV exposure.
The Information Quality Request for Correction recommended the removal of the following sentence from CDC's website: "Using a tanning bed is particularly dangerous for younger users; people who begin tanning younger than age 35 have a 59% higher risk of melanoma." The stated concern with the statement is that it "is scientifically incorrect when applied to US tanning salons that follow FDA-mandated instructions on maximum exposure times."
The statement accurately describes the findings of a meta-analysis by M. Boniol published in in the British Medical Journal in 2012 and is recognized in the literature as the most comprehensive synthesis available. The Boniol meta-analysis is an update of a meta-analysis by the International Agency for Research on Cancer published in the International Journal of Cancer in 2006. The Boniol meta-analysis reported that "the summary relative risk for first exposure to sunbed use starting before age 35 years is 1.59 (95% confidence interval 1.36 to 1.85)." The meta-analysis combined results across a number of studies that examined exposure to artificial UV radiation through a variety of indoor tanning devices, including sunbeds and sunlamps. The statement on the website does not address, either explicitly or implicitly, risk associated with use in the specific context of US tanning salons that follow FDA-mandated instructions on maximum exposure times.
While the statement is an accurate reference of the findings reported in the Boniol meta-analysis, it has potential for being misunderstood. We will be revising the statement consistent with federal plain language guidelines. The revised language will provide greater specificity to the findings of the Boniol meta-analysis as well as additional information from a US-based study by Dr. Lazovitch and colleagues. The revised language will state: "A meta-analysis by Boniol and colleagues in 2012 combined findings from studies from Europe, Australia, and the US. The meta-analysis reported a link between indoor tanning and melanoma."
The information is correct as currently presented on the website. We recognize that some additional clarification and modification of the language may help avoid any misinterpretation or misattribution of the findings to specific settings and or use pattern.
Thank you for the opportunity to provide this information. If you wish to appeal this response to your request for correction, you may submit a written appeal or electronic request for reconsideration within 30 days of receipt of our response. The appeal must state the reasons why the agency response is insufficient or inadequate. You must attach a copy of your original request and the agency's response to it. Also, clearly mark the appeal with the words, "Information Quality Appeal" and send the appeal to the following address:
Centers for Disease Control and Prevention
Management Analysis and Services Office
1600 Clifton Road, NE, Mailstop F-07
Atlanta, Georgia 30333
Fax: (770) 488-4995 or Electronic Mail: InfoQuality@cdc.gov
Sincerely,
Samuel Posner, Ph.D.
Associate Director for Science
National Center for Chronic Disease
Prevention and Health Promotion
cc:
David Espey, M.D., Acting Director
Greta Massetti, Ph.D., Associate Director for Science
Division of Cancer Prevention and Control