Spark Discussions About Indoor-Tanning Devices

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“Strong evidence suggests that using a tanning bed during adolescence or young adulthood can increase the risk of early-onset melanoma by over 40%,” Jeffrey E. Gershenwald, MD, wrote in an opinion piece for Newsweek.1 Dr. Gershenwald is Professor of Surgical Oncology, Medical Director of the Melanoma and Skin Center, and Co-Leader of the Melanoma Moon Shot at The University of Texas MD Anderson Cancer Center, Houston.

The use of indoor-tanning devices is currently prohibited for those younger than age 18 in about one-third of states, including Texas and the District of Columbia. Even in states without such a prohibition, the U.S. Food and Drug Administration (FDA) requires indoor-tanning devices to be labeled with a black-box warning that they should not be used by those younger than age 18. About the time the black-box warning became finalized was when “the regulatory environment for what class of medical device a sun lamp was considered” also changed, Dr. Gershenwald stated in an interview with The ASCO Post. “It used to be in class I, which is the same class as tongue depressors and Band-Aids. Indoor tanning devices were moved to class II, the same class as x-ray machines.”

Restricting Use to Adults Over 18

The effects of ultraviolet (UV) radiation “add up over one’s lifetime,” and “UV radiation exposure in youth and teenagers puts them at a greater risk for skin and eye damage later in life,” according to the FDA Consumer Updates.2 “That’s why the FDA now is proposing a rule to protect youth from the risks of these devices by restricting use only to adults age 18 and older,” the FDA report continues. “This proposed rule also would require indoor-tanning facilities to inform adult users about the health risks of indoor tanning and to obtain a signed risk acknowledgment from these users.”

After the rule was proposed in December 2015, “it went through the typical public comment period,” Dr. Gershenwald said, which was followed by “a quiet phase, when the FDA is digesting all the comments and questions,” but there have been no further announcements concerning the status of the rule. “From the standpoint of trying to raise awareness about the impact of legislation on healthy behaviors, state legislative efforts are all the more important right now to impact adolescents and young adults, because there is no national ban,” Dr. Gershenwald stated. More than 20 organizations, including ASCO and the American Academy of Pediatrics, have endorsed a joint position statement supporting state and federal legislation to prohibit the use of indoor tanning by those under age 18.3

Counseling Teens and Their Families

In 2015, before the FDA proposed restricting the use of indoor-tanning devices to adults aged 18 and older, Dr. Gershenwald and several colleagues wrote in an editorial in the Annals of Surgical Oncology4:

When the FDA issues a black-box warning for a prescription medication or medical device, it communicates associated potentially serious and life-threatening risks to the consumer and, significantly, to the health-care provider. However, in this instance, the agency’s warning requires action from a for-profit industry without the involvement of a conventional health-care provider. Here, the clinician’s familiar role in vetting black-box warnings (ie, for patient safety) is assumed by an industry with a long-standing history of deceptive consumer communications. Clinicians should also continue to provide counseling to teens and their families about avoiding indoor tanning, emphasizing the meaning of the black-box warning.

Dr. Gershenwald also advised clinicians to help patients understand that they need “to respect the sun,” knowing that it is generally impossible, because of either the work we do or the activities we enjoy, to totally avoid sun exposure. “But if you can try to moderate exposure and respect the sun and use tools of sun safety, that is a way to mitigate risk. That is a practical approach.” 

DISCLOSURE: Dr. Gershenwald is an advisor for Castle Biosciences and Merck.


1. Gershenwald J: Skin cancer is on the rise, focus on prevention. Newsweek, May 18. 2017. Available at Accessed July 7, 2017.

2. FDA proposes new safety measures for indoor tanning devices: The facts. FDA Consumer Updates page, updated July 22, 2016.

3. Joint Position Statement on Indoor Tanning. February 2015. Available at Accessed July 7, 2017.

4. Gottlieb M, et al: Teens and indoor tanning. Ann Surg Oncol 22:701-703, 2015.

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