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Chapter 6: Page 1 of 1
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Chapter 7
Chapter
6:
FDA and OSHA Guidelines.
What’s in it and can it hurt me?
The fact is that the majority of
salons offering spray tanning whether by mist on booth or by
airbrushing are violating FDA (Food and Drug Administration)
guidelines with regard to the use of DHA containing products and
exposure limits as mandated by OSHA (Occupational Health and
Safety Administration) to other ingredients that may be contained
in some solutions.
Sad but true! The fact of the matter is that due to poor
education, ignorance of the law or just penny wise and pound
foolish practices, most people calling themselves airbrush tanning
technicians, salon booth owners, and worst of all sales and
marketing personnel of manufacturers are actually unaware or
simply choose to ignore safe practices with regard to atomized
spray tanning products. This ignorance will eventually cause the
industry, clients, salon owners, technicians and insurance
companies problems if this is not corrected and fast.
Most people think that DHA or Dihydroxyacetone is simply a
non-toxic colorless sugar that has been approved for about thirty
years or so. For the most part this is a true statement but here
is where the problems lie. DHA has been approved for topical
application because through testing the FDA has determined that it
cannot be absorbed into the blood steam through the dermis with
the exception of mucous membranes i.e.; lips, eyes, lungs, sinus
tissue, and female genitalia. See link below.
http://www.fda.gov/fdac/features/2003/603_tan.html
Since the advent of spray on
tanning in all its forms; airbrushing, mist on booths, or aerosol
cans, a new problem is starting to reveal itself and that is the
atomized inhalation of the solutions. Did you know that DHA is
allowed to contain arsenic, a poison, and lead a known carcinogen?
Also the FDA does not police the manufacture of DHA and assay its
contents. In other words batches of DHA that are produced by a
host of refineries are exempt from certification. Without
certification nobody can be absolutely sure that the DHA used in
their solutions does not contain more of these potentially harmful
ingredients. According to the FDA’s good manufacturing processes
and to the extent that these ingredients can be avoided, DHA may
contain up to 3 parts per million of arsenic, 20 parts per million
of lead, and 20 parts per million of iron. See link below.
http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=73.1150
These concentrations are extremely
low and pose no immediate health risk when applied topically.
However, repeated inhalation exposure to these levels can be
detrimental to your health. The technicians applying the product
are at a far greater risk due to the fact that they are exposed to
this on a daily basis. Although there have never been any studies
conducted by the FDA or OSHA with regard to repeated inhalation
exposure, common sense will tell you that you do not want to be
breathing poisons or carcinogens at any level. I know that I
certainly don’t.
In addition to the impurities in
DHA that are minor, other ingredients in the solution such as VOCs
(Volatile Organic Compounds) such as SD Alcohol, and Isobutane can
cause additional problems such as nausea, dizziness, respiratory
distress, fainting, numbness, as well as nasal and eye irritation.
These ingredients can be many and a review of each ingredient, its
concentration in the solution, and the MSDS (Material Safety Data
Sheet) must be reviewed before any conclusions can be drawn as to
their safety or lack of it. Exposure limits for each ingredient
are also important and are dictated by OSHA. Here are some
complaints as described above from various products and companies.
See link and PCC (Product complaint codes 13 b and c) toward
bottom of page at
http://www.cfsan.fda.gov/~dms/costop03.html.
Here is the injury code related
to allergic reactions from what I believe is most likely skin
contact. These problems can be allergies to ingredients other than
DHA. Code Injury
Complaint:
14
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Dermatitis (to include rash,
redness, swelling, blisters, sores, weeping, lumps,
inflammation, sunburn, chemical burn, and irritation)
|
19
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Pain (to include itching,
stinging, burning, soreness, and tingling) |
Here are the injury codes caused
from what I believe is atomized inhalation.
23
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Nervous System Reactions (to
include dizziness, headache, irritability, nervousness, and
numbness) |
24
|
Respiratory System Reactions
(to include choking, coughing, sneezing, shortness of breath,
and wheezing) |
25
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Digestive System Reactions (to
include upset stomach, nausea, loss of appetite, vomiting and
diarrhea) |
You will find the body parts codes
listed directly under the injury codes. Just scroll down under
injury codes on the FDA page.
Note:
Some that read this may say that I am putting out information that
is detrimental to this industry. That is true only for the
ignorant. Contrary to the old adage “what people don’t know can
hurt them.” Knowledge is power. Knowing what potential problems
are is the only way to develop safe practices and equipment to
prevent them. The bottom line here is that when used properly in
accordance with FDA and OSHA regulations these types of problems
can be avoided and make the industry safe and poised for viable,
unadulterated growth.
Scentual Sun utilizes only FDA
approved ingredients in all its products and teaches its clients
how to utilize them in a FDA and OSHA approved environment
following the safe practices as outlined with ventilation being a
key factor. This information is just a part of what our training
includes. However, this philosophy is applied to every aspect of
our business and is an integral part of our client’s success and
our technicians and customer’s safety.
Copyright Scentual Sun Tanning Systems 2006. Any unauthorized use
or reproduction of this document is strictly prohibited and
punishable by law.
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Chapter 7
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