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Product: Miscellaneous - Association
Advertiser: The Sunbed Association
Medium: Internet (Social Media)
ASAI Code 7th Edition: 2.4(c), 3.24, 4.1, 4.4, 4.9, 4.10, 11.1, 11.8(a)
A series of social media posts on both Facebook and Twitter for Sunbed Awareness Week stated:
Post 1 (posted 14th May 2018)
“Myth 1 – Sunbeds cause melanoma
There is NO evidence that moderate use of a commercial sunbed will increase your risk of melanoma. Studies often quoted to suggest there is a link have been carefully and scientifically reviewed and found to have significant flaws skewing the results.
Find out more in your local Sunbed Association member salon.
Post 2 (posted 15th May 2018)
“Myth 2 – Sunbeds emit UV levels 10-15 times higher than the Mediterranean sun
Sunbeds are required under European law to have a UV output the same as the Mediterranean sun.
Ensure you use a sunbed that is ‘0.3 compliant’.
Post 3 (posted 16th May 2018)
“Myth 3 – There’s no such thing as a safe tan
Tanning is the body’s natural reaction to gradual, moderate UV exposure. Burning is an uncontrolled, over-exposure to UV and must be avoided.
Get your controlled dose of UV in a Sunbed Association member salon
Post 4: (posted 17th May 2018)
“Myth 4 – Sunbeds are not a safe alternative to sun-bathing
Under professional supervision, sunbeds provide a specific dose of UV in a controlled environment, avoiding the risk of burning. UV levels from the sun will vary significantly according to geographical location, time of year and time of day.
Get your supervised tanning session in a Sunbed Association member salon.
Melanoma Support Ireland objected to Posts 1, 2 3 and 4.
They said that the information contained in the campaign was not based on any scientific fact, was dangerous and misleading.
They also considered that the campaign was promoting the use of a WHO recognised Grade 1 carcinogen.
They considered that the campaign discounted all fact based information about sunbed use and its role in causing skin cancer and melanoma.
They considered the statements in Posts 3 and 4 (Myths 3 and 4), that sunbeds were a safe alternative to outdoor tanning and that tanning was safe if done in one of their registered salons, were untrue as they said that it was accepted by the medical community that there was no such thing as a safe tan.
Finally, they objected to the claim in Post 1 (Myth 1) that there was no evidence that moderate use of a commercial sunbed would increase your risk of melanoma.
The advertisers stated that they were a not-for-profit organisation set up to promote best practice in the provision of sunbed services in a professionally run environment. They said that they did not allow home hirers or unstaffed facilities into membership and all of their members operated to their strict Code of Practice which requires the following:
• all customers to be screened for any contra-indications to tanning prior to being allowed access to a sunbed;
• staff to be trained to ensure correct advice and information is provided to customers;
• all legal and regulatory requirements to be complied with;
• sunbeds must be well maintained;
• salons kept clean and run in a professional manner.
They said that at the core of everything they do was the education and promotion of responsible tanning by those able to tan and to always ensure over-exposure and burning was avoided. They said that they encouraged customers to use one of their member facilities where they could be assured of receiving the correct advice and information about responsible tanning and where contra-indications to tanning existed, consumers would be refused use of the sunbeds and advised not to tan in the sun either. They said that their website included a salon locator so consumers could identify a local Sunbed Association member’s facility.
They said that their Chairman had 33 years’ experience in the tanning industry and was a British Standards Committee Member working on tanning salon services, was also an Expert Topic member for the England and Wales Public Health Advisory Committee (PHAC) with the National Institute for Health and Clinical Excellence. They said that PHAC provided guidance on public health policy and as a consequence his knowledge and ‘hands on’ experience, he was a contributor and active participant in the recent inquiry conducted by the “All Party Parliamentary Group on Skin” on sunbed use in the UK.
They believed that there has been a steady attempt to demonise the use of sunbeds which was the result of well-funded campaigns by the anti-tanning lobby, supported by the media and others. They said that as a consequence of this, there was misinformation in the marketplace about sunbed use that was unfortunately presented by reputable organisations as fact when it was not. They said that they had, for many years, attempted to bring balance to the discussion and debate about responsible sunbed use and where necessary, they have independent and robust compelling scientific evidence to back up everything they said and their Sunbed Awareness Week campaign was no exception. They said that they accepted that some of their Myth Busts would be unpalatable information for some as it challenged the belief system established by the anti-tanning lobby, however, this did not mean it was inaccurate or misleading.
They said that their Sunbed Awareness Week was a series of 7 different Myth Busts, a different one presented each day on their Facebook, Twitter and Instagram accounts. They said that a video with further information on each Myth Bust had supported each post.
They said that the complaint from Melanoma Support Ireland had contained a number of accusations and claims that were neither substantiatable under scrutiny nor accurate and they believed they were indicative of the common held myths about sunbed use that they set out to try to dispel with the campaign.
In response to the complaint that the information in the campaign was not based on any scientific fact, they said that this was a rather sweeping accusation as there were 7 myth busts across the week and it suggested that the complainant was claiming that there was no scientific evidence to substantiate any or all of the myth busts. They said that there were hundreds of peer-reviewed scientific papers that collectively supported their myth busts and they referred to a number that would address the complaints made.
In response to the complaint that the information in the campaign was dangerous and misleading, they said that the aim of the campaign was to bust myths and promote responsible tanning by those able to tan and encourage anyone wanting to use a sunbed to use one of their member facilities. They said that each myth bust included a responsible course of action which were the sign offs to each post. They said that they were clearly encouraging consumers to seek out appropriate advice and information and controlled exposure to UV. They said that everything they did was about promoting responsible tanning by those able to tan and to ensure consumers should seek out one of their member salons, where they would be screened appropriately and those without any contra-indications to tanning would be provided by appropriate advice from trained staff about how to tan responsibly, avoiding over-exposure and burning.
In regards to the complainants’ reference to the WHO’s list of carcinogens, they said that this was a typically disingenuous comment as the sun had been listed as a Grade 1 carcinogen at least 10 years before sunbeds were added, which they considered was a matter of ‘housekeeping’. They referred to the fact that many other everyday products were included on the same list, such as alcohol, HRT, processed meats and salted fish. They said that being on this list was not proof of an actual risk and that it was all about relative risk and dosage. In the case of sunbeds, they said that this would relate back to screening for contra-indications to ensure appropriateness to tan and avoiding over-exposure and burning.
In response to the complaint that the campaign had discounted all fact based information about sunbed use, they said that the complainant had not provided any evidence of the ‘fact based information’. They considered that this complaint was evidence of the need for their campaign to bust the myths that exist and are accepted as fact and that many did not want to accept any correction on.
In response to the complaint that sunbed use had a role in causing skin cancer and melanoma, they said that this was a common held myth, yet the fact that there was absolutely no scientific evidence that demonstrated a causal link between responsible sunbed use in a professional salon and melanoma. They said that long-term cumulative exposure and over-exposure to UV light may increase the risk of basal-cell carcinomas which were functionally benign skin lesions, while not cancers they are commonly referred to as skin cancers, which do not spread and kill. They said that these can be successfully removed and made up over 90% of all ‘skin cancer’ incidences. They said that conflation of these lesions and melanoma was a typical scaremongering tactic of the anti-tanning lobby but it was disingenuous in the extreme and obscured reality.
In response to the complaint that the statement that sunbeds were a safe alternative to outdoor tanning was untrue, they said that this was an actual twist on what the myth said. They said that the anti-tanning lobby claim that sunbeds are not a safe alternative to sunbathing. They said that their myth bust had referred to having a sunbed session under professional supervision in a controlled environment, i.e. where a customer has been screened and identified as appropriate to tan, and was then provided with a controlled dose of UV that would prevent over-exposure and burning. They said that it was a fact that the intensity of the sun would vary significantly according to a number of factors including the time of the day and year and the geographical location, and that individuals could not measure this with confidence to ensure they avoided over-exposure and burning, having established that they are appropriate to tan. They said that testament to this fact were the burned red bodies all too visible on holiday when over-exposure and burning had unfortunately occurred.
In regards to the complainants’ statement that it was accepted by the medical community that there was no such thing as a safe tan and to their objection to the claim that tanning was safe if done in one of their registered salons, the advertisers said that while they would not object to saying “safe tanning” under the right circumstances, there was nowhere in their campaign that they made such a claim. They said that to suggest this was disingenuous. In any event, they said that they did not accept that the medical community as a whole claimed that there was no such thing as a safe tan. They said that while this was the position held by many Dermatologists, it was not the belief held by all and that many other medical professionals recognised the value of moderate UV exposure for optimum health.
In response to the complainants’ assertion that the claim there was no evidence that moderate use of a commercial sunbed would increase a risk of melanoma was untrue, they said that as a melanoma charity, they considered that this was one area where they believed there should be an expectation from the complainant to be fully aware of the science to substantiate such a claim. They said that, at best, this was further evidence of the challenge that existed to have organisations and individuals accept they have bought into the myths. They said that at worse, it was a disingenuous attempt to perpetuate the myths.
They referred to the World Health Organisation (WHO) and the International Agency for Research on Cancer (IARC), who together published a study in 2007 which IARC officials in 2009 claimed established a ‘limited’ and ‘weak’ correlation in a meta-analysis of previous surveys attempting to correlate sunbed usage and melanoma incidence. They said that independent scientific analysis of this data source irrefutably clarified that any increased risk was associated with medical use UV equipment and to a much lesser degree, home use equipment, but not with professional sunbeds. They said that this report was regularly quoted and relied upon when claiming a link between sunbed use and melanoma. They said that it was essential that meta-analyses carried the weight of all the studies that they summarise and that this credence made it imperative that meta-analysis could be trusted to be an impartial tool and made the validity of meta-analytic summary a far more important issue than measurement error. They said that the data could often be skewed by some weighted data and thereby obscured the results, therefore, they considered that meta-analyses were a crude blunt tool that lose important detail.
They also referred to 2009 published research from the Dermato-Endocrinology titled A Critique of the International Agency for Research on Cancer’s meta-analyses of the association of sunbed use with risk of cutaneous malignant melanoma. They said that the conclusion of this study was that “this meta-analysis of the association of CMM risk with respect to sunbed use by the IARC does not support the evidence that sunbed use is a risk factor for CMM when the confounding factors of skin phenotype and latitude are considered. The IARC study only claims association, not causality, and the criteria for causality do not appear to be satisfied.”
They also referred to research published at the North American Congress of Epidemiology in 2011 titled ‘Differential Risk of Malignant Melanoma by Sunbed Exposure Type’ whose conclusion stated that “When professional sunbed usage is considered independent of home and medical exposures, there is no association with melanoma”.
The advertiser said that what the IARC working group failed to disclose was that the data from the studies they examined also showed that:
A. There was no statistical connection between indoor tanning usage and melanoma for people with skin types dark enough to tan. (“Critique of IARC Meta-Analysis of the Association of Sunbed Use with the Risk of Melanoma. Dermo-Endocrinology”). They said that the only connection was with people with ‘Sky Type I’ (fair/sensitive skin) who use home tanning units for therapeutic reasons, but crucially, are screened from tanning in professional sunbed salons.
B. Closer analysis of data from the IARC report, when separated by unsupervised home usage of UV equipment versus usage in professional sunbed facilities and medical usage of medical UV equipment in hospitals and clinics, revealed that no statistically significant increase in relative risk was attributable to commercial tanning facility usage (6%), while larger increases were attributable to home (40%) and medical usage (96%) of UV equipment. They said that by removing skin type I, the relative risk was insignificant. They also said that the often quoted “75% (or 59% Boniol) increase” was an amalgamation of all studies and therefore should never have been attributed solely to professional sunbeds.
The advertiser also referred to two recent peer reviewed papers which showed how the data used by IARC was flawed. They said that these papers confirmed the reasons they have provided and the fact that the quality of the research itself did not meet the generally accepted standards required.
They also referred to two significant studies that robustly challenged the conclusion of the IARC report due to the inappropriate data source:
1. The European Journal of Cancer published in 2005 A Multicentre epidemiological study on sunbed use and cutaneous melanoma in Europe (1). They said that it sought to prove a causal relationship between sunbed use and melanoma, however the conclusion stated “sunbed and sun exposure were not found to be significant risk factors for melanoma in this case-control study performed in five European countries.” (2)
2. In 2011 the International Journal of Cancer published a Letter to the Editor from the Section of Epidemiology and Biostatistics, Leeds Cancer Research UK Centre, Leeds Institute of Molecular Medicine and Cancer Genetics, on the “Relationship between sunbed use and melanoma risk in a large case-control study in the United Kingdom” At the conclusion of the Letter, the Section of Epidemiology and Biostatistics said that “in summary, we have found no evidence for sunbed use as a risk factor for melanoma.”
The advertisers said that exposure to sunshine was essential for life and that tanning was the body’s natural reaction to UV and moderate exposure to sunlight/UV was neither unhealthy nor dangerous. They said that a tanned skin was less likely to be burned but that it was correct that precautions did need to be taken when exposing the skin to UV light to ensure over-exposure or burning does not occur.
Finally, they said that their campaign had been supported by peer reviewed scientific research and had been specifically focussed on raising awareness of the myths that surround sunbed use, combined with education and information about responsible tanning by those who can tan in a professional environment, that is, a Sunbed Association member salon.
(1) European Journal of Cancer 41 (2005) 2141-2149
(2) The ASAI Executive noted that the conclusion also stated “the results could, however, be affected by recall bias and self selection in controls. The deleterious effect of frequent sunbed use, however, remains an issue which is not fully answered…”
The Complaints Committee considered the detail of the complaint and the advertisers’ response, including the research they provided.
Complaints 1, 3 and 4:
While the Committee noted from the advertisers’ response that the aim of their campaign was to bust myths and promote responsible tanning by those able to tan, they did not consider that the campaign had specified that the myth busts were applicable only to those with a skin type that could tan. In the circumstances the Committee considered that the omission of such a reference was misleading and in breach of Sections 4.1 and 4.4 of the Code.
The Complaints Committee noted that the promotion of sunbeds, subject to criteria laid down in the Public Health (Sunbeds) Act 2014, was not prohibited. They Committee did not make a finding in this complaint.
The Committee noted that the ‘Myth Busted’ in Myth 1 – that there was no evidence that moderate use of a commercial sunbed would increase ‘your’ risk of melanoma was based on discounting those with Skin Type 1 from the relevant research. They considered the claim (that there was no evidence) was an absolute claim that had not been substantiated and was in breach of Sections 4.9 and 4.10.
The advertising must not reappear in its current form.