Public Health etc (Scotland) Bill Melanoma Support Group

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1 The Scotland, comprising of carers, melanoma patients and volunteers, welcome the opportunity to respond to the above. I would be pleased to give oral evidence and will answer any questions which may arise from the following. Melanoma if not treated with prompt surgery, can be incurable. Through education and by following simple sun protection measures, it is a mostly preventable disease. Dr Louisa Gordon of the Queensland Institute of Medical Research in a recently published study, estimated that 62 new cases of malignant melanoma each year could be attributed to solarium use. People who have only used a solarium once have a 22% increased risk of developing skin cancer. Exposure to normal sunlight, to allow sufficient synthesis of vitamin D, is achieved in twenty minutes a day in Scotland. While we appreciate that some skin diseases such as eczema and acne may benefit from greater exposure, requiring artificial UVA/UVB during the winter months, this should be prescribed by a clinician. Under these circumstances the risk benefit analysis will be discussed with the patient. UVA is meant to be the predominant wavelength in sunbeds, it is of no value in vitamin D synthesis. In drafting the Bill we would request that the legislation is clear, precise and not open to any other interpretation. We would recommend the work of the European Society of Skin Cancer Prevention: Proposed Code of Practice for Artificial Tanning, this can be found at web site; Sub section 1. We would request the consideration of the following : The conditions for licensing of premises with sunbeds should mirror the conditions for licensed premises for the sale of alcohol. The owner, premises and the operator should be licensed. The cost of licences should reflect the responsibility of the licensee. The Bill should require that owners and operators be of good character. The Bill should define a minimum qualification for operators. The operator on duty should be required to have this qualification on display. The owner should be the main person to feel the effects of penalties for breach of regulations.

2 Sunbed premises should be open to inspection by Environmental Health Officers at any reasonable time without notice. The penalty for breach of regulations should be sufficiently severe and should allow an Environmental Health Officer to close the premises immediately. In the event of multiple breaches of legislation in salons under the same ownership, all licences should be withdrawn. The cost of the licence should be appropriate to deter owners from risking its loss. Unmanned sunbeds should be banned. Sub section 2 a. The information to be provided should be: SUNBEDS CAN CAUSE CANCER OF THE SKIN AND EYE. THESE CANCERS CAN KILL YOU. (Type size not less than 250 point) underlined) (The word YOU should be In Scotland between 1979 and ,039(1) people were diagnosed with invasive Melanoma of the skin. The age at which deaths occurred is 20 years onwards. 158 people in Scotland died from melanoma in (1) This is not a curable disease. (Type size not less than 150 point) We would recommend, in addition, the use of the notice proposed by the European Society of Skin Cancer Prevention. b. The information regarding the effects of sunbed use, should be a notice defined by statute as regards size, content, colour and size of type. c. This statutory notice should be purchased from HMSO for each sunbed, the outer door of the premises and each cash desk. d. A notice must be clearly visible beside each machine. There should also be a copy of this notice clearly visible prior to entry to the premises and at each cash desk.

3 Sub section 3 The Operator: The person responsible for managing the safe use of a sunbed. a. This responsibility to include : Ensuring the client is over 18 years of age and has read and understands the statutory notice. The safe placing of the client in the sunbed, ensuring the client is wearing protective eyewear while in the sunbed. Ensuring that the maximum time permitted for use is not breached. Cleanliness of all equipment particularly eye protection. We would recommend a consent form as proposed by the European Society of Skin Cancer Prevention. The owner of the salon should be subject to the same requirements under the Act as the operator with the additional responsibility to ensure: b. that the sunbeds provided have sun lamps no more than the level of radiation to be expected in Scotland on a sunny day. We understand this to be the maximum level of radiation, which the majority of the population can tolerate, without developing erythema in a twenty-minute interval when not wearing sunscreen. c. that sunbeds are fitted with a timer which, on expiry of the maximum time, will turn off the power. d. that sunbeds are regularly serviced and comply with EN with regard to mechanical and electrical safety. The Health and Safety Executive advises employers to warn their employees: Too much sunlight is harmful to your skin. A tan is a sign that your skin has been damaged. The damage is caused by ultraviolet (UV) rays in sunlight. You should take particular care if you have: Fair of freckled skin that doesn t tan, or goes red or burns before it tans. Red or fair hair and light coloured eyes. A large number of moles. In the short term even mild reddening of the skin from sun exposure is a sign of damage. Sunburn can blister skin and make it peel. Too much sun speeds up ageing of the skin, making it leathery, mottled and wrinkled. The most serious effect is an increased chance of developing skin cancer.

4 The H&SE advice is: Keep your top on! Wear a hat with a brim or a flap that covers the ears and back of neck. Stay in the shade whenever possible, during breaks and especially at lunch time. Use a high factor sunscreen at least SPF 15 on any exposed skin. Drink plenty of water to avoid dehydration. Check your skin regularly for any unusual moles or spots. See a doctor promptly if you find anything that is changing shape, size or colour, itching or bleeding. Taking the above into account, why are we debating exposing people to levels of radiation far in excess of what they would experience as an outdoor worker and colluding with an industry which charges them for the privilege of damaging their health and creating a burden for the NHS? We would request that the following points are considered: Dr Harry Moseley reported to the Society for Radiological Protection January 2007, that of 133 sunbeds in 50 different facilities, 83% had sunbeds with UV output exceeding the limit laid down by the British and European standard. This suggests that self regulation is not appropriate. Tan Biz reported ; Limiting of the output of sunbeds to 0.3W/m2. This will affect all new sunbeds frorm 23 July 2007 but we do not yet know when (or indeed whether) it will affect existing equipment in salons as at 22 nd July Lamp manufacturers are currently doing a great deal of testing to find out the minimum changes necessary to be compliant. The above is not in accordance with an industry which seeks to minimise risks. Sunbed premises should be defined as any place where sunbeds are available. This to include clubs, sports facilities or any other premises. This legislation should prevent the hiring or sale of sunbeds for use in the home. Allowing a person under 18 years of age to use a sunbed, other than for prescribed medical treatment, be considered as child neglect.

5 There is evidence from UK and EU expert bodies about the dangers of sunbeds, the general population is gradually becoming more aware see; Death from melanoma is neither swift nor painless and it is in most cases avoidable. Let Scotland be the first country to ban sunbeds completely, it would be appropriate as our population has high numbers of people with types 1 & 2 skin. On economic grounds, the 14,039 people diagnosed with melanoma between 1979 and 2005 would have had at minimum; excison of the lesion, pathology studies and reports, and would have been followed up for a minimum of five years being seen at dermatology clinics at 3 to 6 monthly intervals. The people who had thicker lesions and or secondaries would have required wider excision, grafting, sentinel node biopsies, block dissection of lymphatic glands, with loss of full limb function in many instances. Some would have gone on to require radiotherapy, chemotherapy and in many cases palliative care before losing their life to the disease. A health economist may be able to compute the financial costs to the NHS of this care, it would be a very considerable sum. Pain and suffering is not measurable. The loss of life for the 158 people who died in 2006 in Scotland, included a 22 year old university undergraduate and a 59 year old man, known to us. Their skills and contribution to society is immeasurable as is the loss to their families from a mostly preventable disease. Leigh Smith TD RGN - Scotland References: R.Mackie et al :Melanoma incidence and mortality in Scotland British Journal of Cancer (2007) 96, General Register Office for Scotland date extracted August 2007 European Society of Skin Cancer Prevention : Proposed Code of Practice for Artificial Tanning : Health & Safety Executive Skin at Work: Outdoor workers and sun exposure. The Society for Radiological Protection SRP2 (07) - Press Release

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