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Why Compatibility and Equivalency Claims Are Important

Compatibility and equivalency claims are important because tanning beds use lamps that emit ultraviolet (“UV”) radiation. It is that UV radiation that causes skin to tan or to burn. If there is too little radiation, skin will not tan; too much radiation will harm skin through burns and otherwise.

Tanning lamps and tanning beds are regulated by the Food and Drug Administration (“FDA”). The FDA has specified the maximum amount of effective UV radiation for tanning beds. The FDA regulates that maximum because overexposure to UV radiation is dangerous, can cause skin injury and can cause allergic reactions, and because repeated

overexposure may cause skin cancer and premature aging of the skin. Thus, the FDA requires that each tanning bed have a timer with a pre-set maximum time, and be designed to give no more than the FDA-specified maximum dose of UV radiation. A bed manufacturer must design a tanning bed – the timer, the distance of the lamps from the person using the bed, the amount of reflection, the make and model of lamps, the number of lamps, and other design factors – to assure that the FDA-maximum UV radiation dose is not exceeded before the timer turns off the lamps. Bed manufacturers must certify to the FDA that their beds, when used with a specified lamp model, will not deliver more than the maximum UV radiation dosage. Placing lamps in the bed that would cause the bed to exceed the FDA specified maximum dosage would constitute adulteration.

Tanning beds must be used with the specified OEM lamp model or with another model that is compatible with the OEM model. FDA guidelines prohibit a lamp from being represented as compatible to an original lamp unless the so-called compatible lamp is as effective, within +/-10%, as the original lamp in causing erythema (sunburn) and melanogenesis. Also, the replacement lamp cannot alter the exposure time of the tanning bed.

Methods for Measuring UV Radiation From Lamps

The UV radiation emitted from tanning lamps is often measured using a spectroradiometer, an instrument that measures the amount of UV radiation at different wavelengths. By measuring the amount of UV radiation emitted from different lamps, a technician can compare the UV radiation emitted by one lamp to the UV radiation emitted by other lamps.

Because different wavelengths have different biological effects on human skin, the FDA has established measurement methods for determining the relative effectiveness – the effect of UV radiation on human skin – for different wavelengths of UV radiation. One method measures effectiveness in causing erythema; the other in causing melanogenesis. If a replacement lamp fails compatibility under either FDA method, the lamp is not compatible or equivalent.

As a salon owner, it is important to use either the lamp that originally came with the bed or an FDA-compatible replacement lamp. This will ensure the safety of your customers and reduce your liability risk.