IQC 2015-12: American Suntanning Association

08/07/2015

August 7, 2015

Barton Bonn, President
American Suntanning Association
PO Box 1907
Jackson, MI 49204
bonnbart@gmail.com
apmillerlaw@aol.com

 

Re: IQC 2015-12: American Suntanning Association

 

Dear Mr. Bonn:

We have reviewed your information quality appeal related to the CDC website dated March 23, 2015. The Information Quality Appeal you submitted requested removal of two bullet points on the CDC website titled “Indoor Tanning is not Safe”. Your letter requested removal of the following statements:

  • A meta-analysis (a research study that looks at data from other studies) by Boniol and colleagues in 2012 combined findings from studies conducted in Europe, Australia, and the United States. The meta-analysis shows a link between indoor tanning and melanoma.
  • Another meta-analysis published in 2014 by Colantonio and colleagues reconfirmed the association between indoor tanning and melanoma, and also found that newer tanning beds were not safer than older models.

The letter further requested that the following language be inserted:

  • A meta-analysis (a research study that looks at data from other studies) by Colantonio and colleagues in 2014 combined findings from 31 studies conducted in Europe, Australia, and the United States. The meta-analysis shows a link between indoor tanning and melanoma, but negates previous studies that showed a greater risk for younger persons using indoor tanning than for older persons. It also found that newer tanning beds manufactured after the year 2000 were not safer than older models.

We respectfully decline the request to remove the statements, because they are scientifically supported and accurately describe the findings in the published studies they reference. Although the Colantonio meta-analysis was published after the Boniol meta-analysis, the findings are not entirely inconsistent across the two meta-analyses. Scientific findings are typically considered in the aggregate, and one published study or meta-analysis is not considered to “supersede” or “overturn” previously published research. Both of the referenced meta-analyses (Boniol et al., 2012, and Colantonio et al., 2014) support the statement that “Studies have shown consistently that indoor tanning increases a person’s risk of getting skin cancer, including melanoma.” Both meta-analyses reported significant associations between indoor tanning and risk for melanoma. The statement does not refer to risk relative to age of users.

Both of the meta-analyses (Boniol et al., 2012, and Colantonio et al., 2014) cited on the website are rigorously conducted studies published in two of the field’s leading peer-reviewed journals, the British Medical Journal and the Journal of the American Academy of Dermatology. Although there are some nuanced differences in the findings across the two studies, the main findings are highly consistent in reporting an association between indoor tanning and melanoma. The findings from these and other meta-analyses along with a significant body of literature have consistently shown that indoor tanning increases the risk of developing skin cancer, including squamous cell carcinoma, basal cell carcinoma, and melanoma. The findings consistently document a strong association between increased risk of melanoma and indoor tanning use, although the magnitude of association varies from study to study, reflecting different populations, settings, and methodologies. The World Health Organization (WHO) classified UV-emitting tanning devices as “carcinogenic to humans” (Group 1) in 2009 based on strong evidence linking use of these devices to increased risk of skin cancer. In addition, the U.S. Department of Health and Human Services’ Report on Carcinogens states that “exposure to sunlamps or sunbeds is known to be a human carcinogen.”  Based on the body of research on the links between indoor tanning and skin cancer, the statements on CDC’s website are accurate, and correctly reflect the findings of the cited meta-analyses.

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 InfoQuality@cdc.gov or 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

 

Sincerely,

Lisa C. Richardson, MD, MPH
Director, Division of Cancer Prevention and Control

 

cc:
Greta M. Massetti, PhD, Associate Director for Science, DCPC
Samuel F. Posner, PhD, Associate Director for Science, NCCDPHP

 

References

  1. Boniol M, Autier P, Boyle P, Gandini S. Cutaneous melanoma attributable to sunbed use: systematic review and meta-analysis. BMJ 2012;345:e4757.
  2. Christenson LJ, Borrowman TA, Vachon CM, et al. Incidence of basal cell and squamous cell carcinomas in a population younger than 40 years. JAMA. 2005;294(6):681-690.
  3. Colantonio S, Bracken MB, Beecker J. The association of indoor tanning and melanoma in adults: systematic review and meta-analysis. J Am Acad Dermatol 2014;70(5):847-57.
  4. International Agency for Research on Cancer, World Health Organization. Exposure to Artificial UV Radiation and Skin Cancer. Lyon, France: International Agency for Research on Cancer; 2006. Accessed May 20, 2015.
  5. International Agency for Research on Cancer Working Group on Artificial Ultraviolet (UV) Light and Skin Cancer. The association of use of sunbeds with cutaneous malignant melanoma and other skin cancers: a systematic review. Int J Cancer. 2006;120(5):1116-1122.
  6. NTP (National Toxicology Program). 2014. Report on Carcinogens, Thirteenth Edition. Research Triangle Park, NC: U.S. Department of Health and Human Services, Public Health Service; 2014.
  7. Wehner MR, Shive ML, Chren MM, Han J, Qureshi AA, Linos E. Indoor tanning and non-melanoma skin cancer: systematic review and metaanalysis. BMJ 2012;345:e5909.