Comments on FDA Proposal to Restrict Artificial Tanning
We recently submitted comments in response to the Food and Drug Administration’s (FDA) proposed rule to restrict the use of sunlamps used for artificial tanning. We concluded that although the proposed rule takes a significant step in reducing the risks of artificial tanning, the FDA should strengthen the justification for this proposed rule. In particular, we recommend that the FDA use more sensible assumptions related to a proposed risk acknowledgment form; consider the negative externalities that accompany sunlamp use to avoid overestimating the consumer welfare loss from the restriction; fully account for the health benefits of restricting sunlamp use; avoid underestimating the habit effect by considering the addictive qualities of tanning; and account for existing state regulations to ensure an accurate assessment of the proposed rule’s costs and benefits. The project was undertaken in honor of Kelly Cosby, one of our former Clinic students, who passed away in November after a brave battle with advanced melanoma.