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Decision-makers need more information as they navigate protecting both the environment and human health.
By: Sean Moloughney
September 1, 2022
The National Academies of Sciences, Engineering, and Medicine issued a report in August, titled “Review of Fate, Exposure, and Effects of Sunscreens in Aquatic Environments and Implications for Sunscreen Usage and Human Health,” recommending that the U.S. Environmental Protection Agency conduct an ecological risk assessment (ERA) of ultraviolet (UV) filters, the active ingredient used in sunscreens. Given the evidence that aquatic ecosystems in the U.S. and possibly endangered species are exposed to these UV filters, and given the importance of these ingredients in skin cancer prevention, this assessment is urgently needed and should be shared with the U.S. Food and Drug Administration for consideration in its oversight of UV filters, the report concluded. UV filters used in sunscreen have been found in numerous aquatic environments, and in water, sediment, and animal tissue. The report focused on the 17 UV filters used in the U.S. Ecological risk assessments compare the concentration at which exposure to a chemical is expected to occur with research on its toxicity, defining the particular settings and conditions under which an environmental stressor might cause ecological impacts. The environmental risk of UV filters is complex, the report noted, because of the variability among filters, environments, filter concentrations, and sensitivity of exposed species. “An ecological risk assessment will help inform efforts to understand the environmental impacts of UV filters, and potentially clarify a path forward for managing sunscreens,” said Charles Menzie, former executive director of the Society of Environmental Toxicology and Chemistry, principal at Exponent Inc., and chair of the committee that wrote the report. “At the same time, it is clear decision-makers need more information as they navigate protecting both the environment and human health. Federal agencies and industry should fund and pursue research to fill these information gaps.” An EPA assessment should focus on environments that are more likely to be exposed and that may contain sensitive species, the report said. These could include coral reefs in shallow environments near shorelines with heavy recreational use and limited flow of seawater, or reefs where wastewater and urban runoff enter the water. Slow-moving freshwater systems with heavy swimming and recreational activity or wastewater are another priority for assessment. Interaction with other environmental stressors, such as climate change, rising ocean temperature, and pollution and other local conditions, should also be considered in an ecological risk assessment. Given the diversity of important species potentially exposed to UV filters, the assessment should include a broader range of species and biological effects than the standard species normally included in toxicity studies. Because products often contain a mix of multiple UV filters, the ecological risk assessment should examine the impacts of UV filters not just individually, but also when mixed together. The report also confirmed with a high level of certainty that consistent use of high SPF (30 and above) broad-spectrum sunscreens reduces risk for skin cancer, sunburn, and photoaging. Behavioral studies show that sunscreen use is generally inadequate; sunscreen is not used by all who should use it, too little is used, and it is not reapplied frequently enough. Reduced availability of sunscreens preferred by consumers may lead to reduced use, which would be expected to have a negative impact on health, the report said. However, changes in sun protection behavior are not easily predicted with current information, and may be dependent on which UV filters are available in a given situation and whether they can provide broad-spectrum protection in a cosmetically appealing product. The Personal Care Products Council released a statement saying the report “makes clear the environmental and public health data gaps are complex and will require close cooperation among governmental agencies, sunscreen manufacturers and UV filter manufacturers to conduct the needed research. As a science-driven industry, we have been and continue to be committed to advancing robust and reliable research to address these data gaps in both environmental and public health research. “Our industry’s research aims to develop UV sunscreen environmental monitoring data, a validated standardized toxicity testing model for coral and a multi-tiered ERA model for sunscreen UV filters that realistically reflects what occurs in nature. “PCPC member companies remain firmly committed to providing consumers with access to a wide variety of safe, effective and innovative sunscreens. Together, we hope sunscreens will remain as much of a public health habit as wearing your seatbelt.” Consumer Healthcare Products Association (CHPA) President and CEO Scott Melville said the trade group is supportive of the recommendation for stakeholders to work alongside government agencies to generate actionable information for an ecological risk assessment on all currently marketed UV filters. “Importantly, for consumers, CHPA is also encouraged to see the report reinforce the public health benefits associated with the use of broad-spectrum sunscreen and the importance of formulation flexibility to drive consumer use. As we continue to closely monitor this issue, CHPA remains committed to ensuring consumers have access to safe and effective ingredients that meet their varying preferences for sun protection.”
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