Why I Agreed to Not Fight the FTC on Tanning Beds

By Dr. Mercola

On July 29, 2014, a U.S. surgeon general's "Call to Action to Prevent Skin Cancer Report" was released.^1,2,3,4

"Tanned skin is damaged skin, and we need to shatter the myth that tanned skin is a sign of health," said acting Surgeon General Dr. Boris D. Lushniak, "When people tan or get sunburned, they increase their risk of getting skin cancer later in life."

It is quite relevant that this surgeon general was also a dermatologist. The American Academy of Dermatology (AAD) does not advocate getting vitamin D from sun exposure or indoor UV lights. They irrationally state that the sun and UV lights are simply an avoidable risk factor for skin cancer.⁵

The AAD will not even acknowledge different recommendations based on skin type, even though it's widely recognized that darker skinned individuals need far more UV exposure in order to produce vitamin D in their skin.

This oversight puts minorities who are already at an increased risk for many chronic diseases at even greater risk.

FTC Brought in to Combat UV Exposure

The announcement also mentions working with many federal agencies, including the Federal Trade Commission (FTC), to assist with this war against UV light.

On the very same day this "Call to Action" was released, I was delivered an investigative demand by the FTC regarding the sale of UV light systems/tanning beds on my website.

One might believe in coincidences, or one could conclude this dermatologist surgeon general had worked with the FTC as part of the "Action Plan" to quiet my advocacy for responsible UV light exposure and further advance the ridiculous notion that UV is simply a danger without benefits.

We keep very detailed customer records, and this was clearly not a customer initiated action. 

For those who believe my controversial advocacy is unsupported, there are many considerations, and loads of research, that should be carefully evaluated.

The FTC states they had ordered me to stop selling beds in their press release. I offered and had stopped selling UV lights last December 2015 so that I can be free to fully participate in this crucial debate - UV light provides a quite different and preferred method of achieving optimal Vitamin D levels.

At the time the FTC initiated this action, the FDA classified these devices as a Class 1 medical device.  In their own words:  "Class I devices are deemed to be low risk and are therefore subject to the least regulatory controls.  For example, dental floss is classified as a Class I device".

A synonym for low risk can be looked up quite easily, "safe" is a synonym for low risk.  The FTC also suggests that my support of the Vitamin D Council was not disclosed.

The fact that I have supported the Vitamin D Council appears on the footer of every article on the website, along with many of the other non-profits I support.

The Vitamin D Council tested our devices to verify adequate UVB strength was present to stimulate Vitamin D production.  The fact we have provided financial support to the Vitamin D Council is not hidden, we are proud to do so.

Cosmetic Versus Nutritional UV Exposure

UV devices are commonly referred to as "tanning" beds. The FTC is clearly not separating the significant difference between a high-pressure UVA light device purposely made to darken skin versus the use of UV lamps designed for nutritional purposes.

Unfortunately, official classification rules⁶ prevented us from differentiating our UV systems from regular tanning systems by referring to them as "Nutritional UV Therapy" lamps or something similar.

My nutritional views and advice regarding the benefits of vitamin D were distorted by the FTC as being equivalent to the promotion of tanning itself. But commercial sun beds actually fit into two separate categories: 1) Tanning, and 2) Nutrition.

The former addresses how you look, whereas the latter addresses optimization of health, reduction of chronic disease risk, and general well-being — without regard for the actual shade of your skin.

This is a paradigm shift in looking at UV lamp use; it needs to occur, and I predict it eventually will, but I was unfortunately too far ahead of the herd at the present time.

While UV Abuse May Raise Risk of Skin Cancer, Sensible Exposure Can Be Safe

I fully agree with public health experts and the FTC that UV abuse is a serious mistake that can permanently damage your skin and may lead to skin cancer. UV abuse includes prolonged unprotected sun exposure, intermittent exposure, and excessive tanning.

If you have read this site for years, you will know that I always advise sensible exposure to the sun or my UV systems. There's a "Goldilocks zone" within which benefits are maximized and risks minimized.

My point of contention with the FTC, the surgeon general, and the AAD is that the lack of flexibility in their stance is not based on the available science.

I am part of the scientific community convinced by extensive evidence that limited and controlled UV exposure, ideally from the sun but also if need-be from the limited and controlled use of a sun bed, is crucial to a healthy life.

For a moment, just imagine what you would look and feel like if you'd never ever stepped outside — if you literally lived below ground 24/7. You'd develop a sickly pallor and your health would deteriorate. Yet this is essentially the strategy currently being recommended just to prevent skin cancer.

Sun Avoiders Get Melanoma Too

It makes even less sense when you consider that even sun avoiders develop melanoma — the deadliest form of skin cancer.

One study, which followed more than 100,000 women for more than eight years, found that melanoma affected less than three-tenths of 1 percent of those who tanned frequently, and less than two-tenths of 1 percent of those who didn't tan.⁷

Not only is your risk of developing melanoma from sun exposure exceedingly small — well below 1 percent — but your risk of developing melanoma does NOT disappear by avoiding sun exposure. It's just one-tenth of 1 percent lower than if you did get frequent exposure.

A number of authorities, including the National Institutes of Health (NIH), have shown UV light helps promote vitamin D production and deliver other health benefits, including improved cardiovascular health and a reduced risk of 16 different types of cancer, including breast cancer.

Research⁸ has also shown that UVB therapy, specifically, does not raise your risk for skin cancer.

UV Light Is Essential for Human Health

We are not nocturnal beings, and while intermittent and overexposure to UV light is a serious issue, it is manageable through common sense and careful attention to some basic elements.

I am firmly convinced that the advice to completely avoid UV light is dangerous and highly irresponsible, as the effects go far beyond vitamin D deficiency. Our bodies produce vitamin D through exposure to UVB light. For those living in northern latitudes, this may only be an option for a few short months each year.

Some may be surprised to know that even southern Florida has no UVB availability from late December to early February, making it impossible for your body to produce vitamin D when exposed to sunshine during this time.

In order to safely mitigate the risks of UV exposure while maximizing the benefits, there are a few factors to consider. We are essentially hairless, and our skin pigmentations differentiated because of our ancestral latitudinal proximities, to optimize skin for sun exposure.

The further from the equator our ancestors lived, the lighter the skin became to maximize the limited availability of the sun, and UV light specifically.

If you accept the essential nature of UV light, then you can conclude safe exposure to sunshine is possible by understanding your skin type, the UV strength, and your duration of exposure. My advice has been clear: you should always avoid sunburn and realize the real danger of intermittent exposure and overexposure.

Pay careful attention to your vitamin D levels, and ideally have a vitamin D test during the peak of summer, and the end of winter to help guide your UV exposure and vitamin D supplementation.

Think of your body as a solar panel; the larger areas of skin — your back and chest — are the best places to expose to the sun for the fastest production of vitamin D. The more skin exposed and the lighter your skin type, the less exposure time necessary. This is how you maximize benefits and decrease risks.⁹

You must also carefully consider your frequency of exposure. If you have been bundled up indoors all winter, your initial exposure should be more limited. This is the common sense advice your grandmother likely provided, and it is surprising this advice has suddenly become so controversial.

UV Light Benefits Health in More Ways Than One

UV light has benefits beyond vitamin D, but don't take my word for it. Please research "Sunlight Has Cardiovascular Benefits Independently of Vitamin D," produced by Richard B. Weller Medical Research Council Centre for Inflammation Research at the University of Edinburgh.¹⁰ One of the key messages presented in this paper states that:

"All-cause mortality should be the primary determinant of public health messages. Sunlight is a risk factor for skin cancer, but sun avoidance may carry more of a cost than benefit for overall good health."

In short, if you're concerned about mortality, and not just mortality from one specific disease, the scales swing very heavily toward sun exposure being of tremendous benefit. This despite a minor risk of melanoma, should you accidentally end up getting burned one or more times in your life. Other papers coming to similar conclusions include the following:

• Journal of Internal Medicine 2016.¹¹ In this competing risk analysis, women with active sun exposure habits did have a higher risk of melanoma compared to sun avoiders. However, they also had a lower risk of mortality from far more deadly diseases than melanoma, including cardiovascular disease. In fact, the authors note that:

"Nonsmokers who avoided sun exposure had a life expectancy similar to smokers in the highest sun exposure group, indicating that avoidance of sun exposure is a risk factor for death of a similar magnitude as smoking. Compared to the highest sun exposure group, life expectancy of avoiders of sun exposure was reduced by 0.6 to 2.1 years."

• Journal of Internal Medicine 2014:^12,13 This 20-year-long study concluded that "avoiding sun exposure is a risk factor for all-cause mortality. Following sun exposure advice that is very restrictive in countries with low solar intensity might in fact be harmful to women's health." Women who avoided sun exposure had double the all-cause mortality rate of those who got regular sun exposure.
• A study published in Public Health Nutrition 2012¹⁴ concluded that: "The overall health benefit of an improved vitamin D status may be more important than the possibly increased cutaneous malignant melanoma risk resulting from carefully increasing UV exposure. Important scientific facts behind this judgment are given."
• A 54-month-long study¹⁵ published in 2013, involving more than 422,800 healthy adults, found that those who were most deficient in vitamin D had an 88 percent increased mortality risk.
• Another 2013 study¹⁶ found that for every one skin cancer death in northern Europe, between 60 and 100 people die from stroke or heart disease related to hypertension. According to the authors:

"We suspect that the benefits to heart health of sunlight will outweigh the risk of skin cancer. The work we have done provides a mechanism that might account for this, and also explains why dietary vitamin D supplements alone will not be able to compensate for lack of sunlight."

Research also shows that UV light:

• Helps treat and prevent the spread of diseases like tuberculosis¹⁷
• Helps kill and prevent spread of antibiotic-resistant bacteria. Data suggests UV light at 254 nm acts as a potent bactericidal, killing drug-resistant strains of S. aureus and E. faecalis in as little as five seconds.¹⁸
• Helps treat seasonal affective disorder and major depression.¹⁹ Schizophrenia has also been linked to maternal lack of sun exposure during pregnancy.²⁰
• Helps maintain vitamin D status in elderly people at a lower cost than that of using oral vitamin D supplementation.²¹ Not only could UV lamps help improve nursing home patients' physical health, they could also help relieve symptoms of depression.

Skin Cancer Campaigns Have Clearly Identified a Serious Pattern of Harm

Utilizing UV light for the sole purpose of increasing the darkness of skin is very common with today's youth and it is something I have never condoned. This website is not a common destination for teenagers. The truth of the matter is, my audience primarily consists of mature adults of various ethnicities who are focused on achieving optimal health through natural inexpensive strategies like sensible sun exposure.

Sadly, there are a few businesses that have adapted their business models to match the pursuit of tanning teenagers, mostly young girls, by exclusively using high pressure UVA bulbs that will quickly darken skin — without UVB available for the production of vitamin D. I agree this is an inadvisable strategy, as chronic UVA exposure has indeed been linked to premature aging and damage of the skin.²²

My interests in UV light, however, are based on the acknowledgement of science, clearly demonstrating that UV light is essential for humans, and that overexposure can be easily mitigated by avoiding careless choices that can result in permanent damage. My positions have been backed up by some of the most credentialed scientists conducting vitamin D research.^{23,24,25,26,27}

Are UVB Lamps a Safe and Effective Source of Vitamin D?

Michael F. Holick, a well-recognized expert, even produced a special report for them in which he noted that "exposure to devices that emit UVB radiation … can improve a person's vitamin D status and overall health and well-being." And that "use of an indoor tanning bed is a viable alternative for a person to obtain their vitamin D ..."

The founding director of the Sunlight, Nutrition and Health Research Center, William B. Grant, Ph.D., has also summed up the contribution UVB devices can make to public health as a source of vitamin D, stating that: "[W]hether from sunlight or a tanning bed, UVB radiation will increase vitamin D levels in the blood. Thus, indoor tanning facilities present a viable option to increase vitamin D levels."²⁸

For many people, sun exposure is not always possible. It may be because of geographic location, time of year, privacy, or a variety of other reasons that make the use of UV lights inside the comfort of home a secondary alternative. I have always stated the sun is your best option, followed by appropriate use of UV lights, with supplemented vitamin D as the least preferred method.

If you supplement with vitamin D, it is crucial that you have your vitamin D levels tested as there is very clearly a six times difference in dosage response

While overexposure to UV light is a serious problem, it is comparable to choking as a hazard of eating food, or hyponatremia as a hazard of drinking water — it does not make either activity inherently unsafe, and to make blanket statements to avoid all of these vital nutrients because of some calculated but incredibly remote risk would be foolish to say the least.

The same can be said regarding UV exposure. Sensible UV exposure is essential. I find the current federal strategy and AAD encouraging complete UV avoidance to be dangerous and extremely misguided. It ignores the overwhelming benefits of appropriate sun or UV exposure and our own obvious evolutionary adaptations.

Evidence Supporting Sunscreen Use to Protect Against Skin Cancer Is Weak

I also believe the false sense of security that sunscreens provide are part of the problem. The evidence that sunscreens protect against basal cell carcinoma and melanoma is actually very weak. One 2011 paper even pointed out that "there is no convincing evidence that sunscreen use protects against cutaneous malignant melanoma."²⁹ Some of the evidence even suggests sunscreens may increase your risk.

The safety of the ingredients used in sunscreens is also a significant concern. The safest and most effective sunscreens are zinc-based. Zinc works because it forms a barrier, and won't absorb into your skin. However, they're the least likely to be worn since they leave a white paste on the skin.

What I Have Done to Improve UV Systems

My product manuals were published online and sent with the systems when purchased. We used only electronic ballasts, due to EMF concerns with magnetic ballasts, and we sold innovative lights that utilized red and blue spectrums over the neck and face, as the skin is thinner and more vulnerable in those areas. This allowed your torso to maximize the UV exposure while providing your neck and face with red and blue spectrum light.

Some also incorporated infrared light, positioned to run down your spine. Infrared light aids with pain relief, while blue light is often used to promote skin health, and red light helps promote collagen production. My UV systems were very specifically designed for the optimization of health, NOT for the darkening of skin.

Unit	# of Bulbs	# of UVA/UVB	# of Red	# of Blue
Sun Splash D-Lite	12	12-UVB ONLY	12 (entire bulb)	0
Sun Splash 8	8	8	0	0
Sun Splash Renew	10	10	2 (face only)	0
Sun Splash Refresh	10	10	2 (face only)	2 (face only)
Sun Splash Refresh Stand Up Booth	30	30	2 (face only)	2 (face only)

Unit	# of Bulbs	# of UVA/UVB	# of Red	# of Blue	Infrared
Vitality D-Lite	18	18-UVB ONLY	18	0
Vitality Refresh 18	18	16	4 (face only)	0	2
Vitality Refresh 24	24	22	2 (face only)	2 (face only)	2
Vitality Elite	32	30	4 (face only)	4 (face only)	2

We were in full compliance with the FDA recommendations for our tanning beds. Our instructions also did not allow for the most sensitive skin types or people under the age of 18 to use these systems. Light skin exposure times started with as little as two minutes of exposure, gradually working up to a maximum of five minutes. This is less than half of the maximum time recommended by the American Suntanning Association.³⁰

We decreased the power of the bulbs in the beds as we knew customers wanted to relax and spend more time lying down in the beds versus the standup units. The weaker bulbs in the beds allowed for longer time of exposure. The lightest and most sensitive skin types were still instructed to avoid use altogether, while those with light skin were instructed to start with four minutes for initial exposure, and then work up to a maximum of 10 minutes.

This is very conservative advice, and helps prevent intermittent exposure, which is a significant factor that increases risk of skin damage. If sun is not available, I advise sensible exposure to UV light systems. This advice is provided to maximize your health outcomes, as we clearly see multiple problems from UV underexposure.

How Great Is Your Risk for Skin Cancer, With or Without Sun Exposure?

The FTC strongly objected to an article I wrote in 2012, in which I suggested that UV lights can be used safely. This despite the fact that my assertions were fully referenced and well-substantiated by very credible experts. Moreover, even the FDA had tanning beds classified as "low-risk" at this time.

It's sadly quite common for many in the media to assume I'm somehow "making things up" as I go, despite the fact that every single strategy I present is backed by peer-reviewed, published science, carefully referenced in each and every article I publish. It's really a case of shooting the messenger, because much of this research simply doesn't get presented in the mainstream media.

So what does "risk" really mean, and is it possible to make UV exposure "safe?" Risk includes irresponsible behavior, as discussed above, but what does risk look like when you're following instructions for sun exposure and/or using a UV system as directed?

As noted in a previous article by the Association of Health Care Journalists (AHCJ),³¹ an oft-repeated quote is that "use of sunbeds before the age of 35 is associated with a 75 percent increase in the risk of melanoma." That does sound like cause for concern, but the devil's in the details, as usual. According to the AHCJ:

"Is it 75 percent greater than an already-high risk, or a tiny one? If you read the FDA's 'Indoor Tanning: The Risks of Ultraviolet Rays,' or a number of other documents from the WHO and skin cancer foundations, you won't find your actual risk.

That led AHCJ member Hiran Ratnayake to look into the issue ... The 75 percent figure is based on a review of a number of studies, Ratnayake learned. The strongest such study was one that followed more than 100,000 women over eight years.

But as Ratnayake noted, that study 'found that less than three-tenths of 1 percent who tanned frequently developed melanoma while less than two-tenths of 1 percent who didn't tan developed melanoma.' That's actually about a 55 percent increase, but when the study was pooled with others, the average was a 75 percent increase.

In other words, even if the risk of melanoma was 75 percent greater than two-tenths of one percent, rather than 55 percent greater, it would still be far below 1 percent."

To give you perspective on just how small a figure one-tenth of one percent (0.1 percent) is, think of comparing a dime to a $100 bill. The difference in risk between a tanner versus a non-tanner for developing melanoma is equal to 1 dime out of 1,000 dimes.

How to Dramatically Reduce Your Risk of Skin Cancer From the Sun

Now, in order to minimize risk while maximizing benefits of UV exposure, here are a few factors to consider. If you pay close attention to these, you can determine, within reason, safe exposure durations.

• You should know your skin type based on the Fitzpatrick skin type classification system that has been around for decades. The lighter your skin, the less exposure to UV light is necessary. The downside is that lighter skin is also the most vulnerable to damage from overexposure.
• For very fair-skinned individuals and those with photodermatitis, any sun exposure may be unwanted and they should carefully measure vitamin D levels while ensuring they have an adequate intake of vitamin D, vitamin K2, magnesium, and calcium.
• For most individuals, safe UV exposure is possible by knowing your skin type and the current strength of the sun's rays. There are several apps and devices to help you optimize the benefits of sun exposure while mitigating the risks. The D Minder app is my personal favorite.

Follow grandma's advice and be extremely careful if you have not been in the sun for some time.Your first exposures of the year are the most sensitive, so be especially careful to limit your initial time in the sun.

The Perfect Storm for Vitamin D Deficiency Has Arrived

When you look at the overall picture, it's clear to see that we are building the perfect storm for serious negative health outcomes due to vitamin D deficiency.

1. The U.S. Preventative Task Force suggests vitamin D testing is unnecessary.
2. The Institute of Medicine (IOM) recommends inadequate dosages of vitamin D (600 IUs a day up to age 70, and 800 IUs if you're over 70). As pointed out in a 2014 paper,³² the IOM underestimates the need by a factor of 10 due to a mathematical error. This error has never been addressed. Moreover, more recent research³³ suggests it would require 9,600 IUs of vitamin D per day to get a majority (97.5 percent) of the population to reach 40ng/ml.
3. The American Medical Association (AMA) uses 20ng/ml as sufficient, but research shows 40 ng/ml should be the cutoff point for sufficiency in order to prevent a wide range of diseases.
4. The U.S. government and the AAD recommend avoiding UV light entirely.

What I fear is that there is no longer balance or common sense being applied in media or policy. We are now being told that UV light is nothing but an avoidable cancer risk, and that all UV should be avoided. I find this to be extremely dangerous and negligently irresponsible, as science is proving how essential UV light is for human health. By denying this point we are endangering our society and denying our evolution and history.

We are not nocturnal beings; we should not be living our entire lives indoors or underground like moles. UV light is essential; overexposure is the problem. There is no denying this simple fact, and to refuse to fine-tune recommendations because it's "too confusing,"³⁴ as if Americans are incapable of understanding the complexity, does the public a great disservice.

At least two-thirds of our population is vitamin D deficient, and for very obvious reasons. We are told to avoid the sun, by either staying indoors or slathering ourselves with toxic sunscreen. The ramifications of this kind of blanket policy are very real. As one of my readers on a vitamin D article from earlier this year wrote:

"After being diagnosed with malignant melanoma, I was told by [my] dermatologist to stay out of the sun completely! Was advised to use an umbrella when walking from car through the parking lot. Absolutely NO SUN.

I was terrified. [I] gave up my beloved golf and stayed inside almost all the time. Ten years later I was diagnosed with BREAST CANCER. When I started hearing about lack of vitamin D and cancer I confronted my dermatologist. Her response was 'I am sorry, We just didn't know the importance of D.' True story, and guess what I am doing ... Golfing again and [going out] in the sun!"

Dermatologists Refuse to See the Bigger Picture

By focusing on one single side of UV research — the potential harm of overexposure to the skin — the government and dermatologist associations are doing the public a great disservice. The AAD, the same group who advocates for Botox and laser hair removal, has a myopic view of UV light that is having serious negative impacts to our health.

Ironically, dermatologists utilize UV light, red light and other wavelengths for phototherapy for the treatment of many skin diseases, such as psoriasis and acne. The belief is that dermatologists can carefully supervise the treatments to ensure that the benefits outweigh the risks, and that individuals do not possess the knowledge to utilize light devices at home.

The scientific literature shows quite clearly that the overall health benefits of UV exposure outweigh the risks when the precautions discussed above are implemented. The reason for this is because higher vitamin D levels have been shown to offer significant protection against a number of cancers. There's even evidence showing it helps protect against melanoma.

In fact, higher rates of melanoma are found among those who have low vitamin D levels; among indoor occupations; and in areas of the body that rarely or never see the light of day. To put it simply, UVB appears to be protective against melanoma — or rather, the vitamin D your body produces in response to UVB radiation is protective.

As noted in The Lancet:³⁵ "Paradoxically, outdoor workers have a decreased risk of melanoma compared with indoor workers, suggesting that chronic sunlight exposure can have a protective effect."

But more important than the potential protection against melanoma, vitamin D has been shown to significantly reduce internal cancers, along with chronic diseases such as heart disease, which kill far more people than melanoma does. Unfortunately, what is typically known in science takes decades to put into practice: an embarrassing tradition in medicine that puts many lives at risk each day.

Dermatologists Advertise, Use and Believe UV Therapy Is Safe and Effective

Polling³⁶ shows that 99 percent of dermatologists believe sensible UV exposure is the primary source of vitamin D, and a viable treatment for non-lethal skin conditions such as psoriasis. Eighty-eight percent also recommend the use of UV lamps as a form of treatment for various cosmetic skin diseases, and 28 percent recommend patients use tanning salons as a cost-effective self-treatment option.

Yet the industry as a whole still lobbies against all UV exposure. Why is the AAD so inconsistent and contradictory? Moreover, despite their war against UV exposure, dermatologists freely advertise the use and safety of UV therapy, including the following:

• Hirsh Dermatology promotes the use of UV light as a safe and successful treatment option for skin conditions such as psoriasis, eczema, vitiligo, and many others³⁷
• Riverchase Dermatology states that "UV light therapy (ultraviolet phototherapy) has been proven for over 100 years. Recent studies show that narrowband UVB lamps (UVB-NB) have virtually NO incidence of causing skin cancer," and that "Ultraviolet phototherapy has been recognized as safe, effective, and economical and has stood the test of time."³⁸
• Dermatology Associates of the Bay Area states that: "For the right patients and with close monitoring by a dermatologist, UV light therapy can be a safe and effective treatment …"³⁹
• Even the AAD issued guidelines for using UVB therapy for the treatment of psoriasis in 2009.⁴⁰

Dermatologists insist that it's their supervision that makes it safe, but research⁴¹ has demonstrated that at-home use of UV devices is a cost-effective alternative that is just as safe and effective as treatment received in hospitals and clinics. Moreover, research⁴² shows (as Hirsch Dermatology asserts) that UVB therapy (which is what my UV products use) will not raise your risk for skin cancer.

So what's all this scaremongering about then? Well, for starters, by promoting sun avoidance, dermatologists profit.⁴³ There's not a wrinkle that can withstand a Botox injection, not to mention if you want "safe" UV exposure, you'll need to pay them for it.

Flawed Research Used as Basis for FTC's Stance on Tanning Beds

The FTC's stance on tanning beds being dangerous is based on two seriously flawed meta-analyses^44,45 showing a causal link between sun or tanning bed exposure and melanoma. Holick presented the FTC with a special report in which he detailed the many problems with these studies. For starters, he noted that meta-analyses are "fraught with inherent biases and in some cases corruption of data files, and that problem was found to compromise the conclusions by Boniol et al. 2012." ⁴⁶

Recall bias is another common problem in retrospective assessments such as these, as patients with melanoma who are aware that tanning bed exposure might be associated with cancer are more likely to report having used one. Among some of the other problems Holick noted were the following:

• The studies fail to document or take into consideration the type of tanning bed used, which is an important detail in terms of risk. High-intensity UVA lamps have been associated with increased risk for immune suppression and melanoma, when compared to medium intensity lamps that emit both UVA and UVB radiation.
• The JAMA Dermatology study⁴⁷ reported on overall use of a tanning bed. They did not document the frequency, or the duration, of use. "Thus, they did not provide an objective approach for the evaluation of a tanning bed exposure as it relates to the development of melanoma," Holick notes. "They also did not take into account intermittent or chronic sun exposure and sun burning experiences all of which can influence risk for melanoma."

This is an important point, as the evidence suggests it is high-intensity intermittent exposure that carries a risk of melanoma — people who are very light skinned who go to Cancun for a week and bake themselves to a crisp, for example. Or those who stay out in the sun for hours on end on a couple of weekends a month.

Slow, steady, regular exposure for a short amount of time — just enough to turn your skin slightly pinkish — is the recommended way of maximizing benefits while minimizing risks.

• The meta-analyses fail to properly account for sun exposure and lifestyle. While they took sun exposure into account, they were only able to adjust for variable sun exposure in a small subset of the studies included in the overall analysis. They also admitted that tanning bed users had a tendency to adopt unhealthy lifestyle habits, such as smoking, which has been associated with increased risk for melanoma.

Holick also provided a list of recent studies showing your melanoma risk may be elevated by a number of common lifestyle factors, including low coffee consumption^;48 low vitamin D levels and human papilloma infection;⁴⁹ alcohol consumption^;50 and genetics^.51 One 2014 study⁵² also reported that vitamin D deficiency was associated with increased risk for melanoma — and more importantly, more aggressive types of melanoma.

Low vitamin D also lowers your chances of survival in the case you do develop melanoma,⁵³ and sun avoidance is the primary cause for low vitamin D.⁵⁴ Other factors that may signify an increased risk for skin cancer includes having just a handful of irregular moles on your body.

People with 50 or more moles have a significantly reduced risk of developing more invasive melanoma, according to recent research.⁵⁵ Disturbingly, British researchers found that kids now spend less time outdoors than prison inmates,⁵⁶ setting themselves up for any number of future health problems, not to mention worsening those they already have.

• The BMJ study also has a veracity problem. The authors have admitted that corruption of a data file resulted in an incorrect summary estimate, which they now claim to have corrected. According to Holick: "They now report first exposure to sunbathe use starting before age 35 years is 1.59 ... and not 1.87."

In conclusion, Holick notes: "Both of the meta- analyses suggesting that tanning bed exposure increases risk for malignant melanoma are open to question. This is because of how the authors performed their analyses and not taking into consideration other significant confounding variables including alcohol consumption, coffee consumption, vitamin D status, smoking, and genetics." For more information from Holick, please take a look at my interview with him.

Education Is More Important Than Sales

In the end, it's not a wise use of resources fighting the FTC, so I chose to settle and agree to no longer sell my UV systems in order to continue educating you about the very real health benefits of UV exposure — a primary source of vitamin D production in the human body — and the risks of deficiency.

I choose to stop selling any products providing UV treatment because of my dedication to fully participate in the crucial debate over sunshine, Vitamin D, and UV therapy.  The average level of Vitamin D is dangerously low, most acutely with people of the darkest skin types.

Severing commercial ties with UV products in a formal agreement with the FTC permits me to speak boldly and authoritatively as a health care advocate.

By not wasting time and money on fighting the FTC I am able to use these resources to bring you cutting edge strategies, like optimizing mitochondrial dysfunction, that will radically improve your health and minimize your risk of chronic disease.

After all, health education is my business. I have never been one to accept conventional thoughts on most topics, especially when it comes to health. I promote therapies that are natural, safe, time-tested and inexpensive. Sensible sun exposure is a perfect example of this approach.

These recommendations aren't just guesses; they're backed by extensive evidence-based research, and my site offers a range of nutritional products and lifestyle advice commonly denied or ignored by established authorities.

When it comes to optimizing vitamin D, I offer advice on the benefits of carefully controlled UV exposure and other vitamin D-boosting strategies — including food and supplements, based on the strongest scientific evidence available, and the consensus view of researchers and established experts within the field.

Instead of simplifying to the point of being detrimental, I offer easy-to-understand guidance on how to sort through the complexities in order to reap the greatest benefits with minimal risk.

Widespread vitamin D deficiency, primarily caused by lack of sun exposure, is too critical a public health issue to ignore. Tens of thousands of studies have been done on the health effects of vitamin D, and research shows it's involved in the biochemical function of all cells and tissues in your body, including your immune system and function.

When you're deficient in vitamin D, your health can deteriorate in any number of ways, because your cells actually need the active form of vitamin D to gain access to the genetic blueprints stored inside the cell.

In certain regions or at certain times of year, UV exposure is not available from the sun and artificial UV lights must be considered and further researched. I will be providing more research funding to ensure the public is not further pushed into the epidemic of vitamin D deficiency.

Raising vitamin D levels among pregnant women is of particular concern, as deficiency affects both the mother and her child in the short and long term. This is why I have dedicated myself to promote valuable health initiatives such as GrassrootsHealth D*Action study,⁵⁷ and the Protect Our Children NOW! Campaign,⁵⁸ which aims to reduce preterm birth rates by 50 percent.

Trailblazers Always Pay a Price

By refusing to distinguish between UV therapies that boost vitamin D and devices designed to darken your skin, the FTC is confusing — deliberately or otherwise — cosmetic versus nutritional application of UV light. My sun exposure recommendations have always been clear on the purpose for UV exposure. You need it for optimal health, not to produce a darker tan.

I'm in the business of helping you take control of, and build, better health, not changing the color of your skin. (That's an unavoidable side effect of most sensible sun exposure, but when done responsibly your skin color wouldn't necessarily undergo a dramatic change.) It is my sincere hope that, in the near future, nutritional application of UV sun lamps becomes recognized as the health-promoting technology it can be, when done right.

The cost of being a health pioneer is typically significant, but the sheer importance of this information makes me dedicate myself to the task even more doggedly.

Radiologists attacked me for stating mammograms were oversold; dieticians attacked me for criticizing the horrible government dietary recommendations — especially about the ridiculous advice about healthy fats.

Chemical corporations have threatened me for expressing dangers about PFOA's, shills have publicly attacked me for sounding the alarm about pesticides, synthetic fertilizers, and the devastation GMOs are causing on this planet.

Public health officials have attacked me for showing how clearly water fluoridation issues are misguided, and for speaking out against the bizarre practice of using mercury for dental fillings.

The junk food industry has been equally unpleasant, as my cautionary advice to avoid aspartame and other junk food additives have proven equally correct over time.

But the list of my vindications goes on and on, so I know it's just a matter of time before the weight of the evidence finally drowns out the naysayers.

The fact of the matter is, when you're the opposition to major industry, you get attacked. Holick also suffered punishment for talking about advantages of UV light. He was even forced to resign from his job as a professor of dermatology at Boston University.⁵⁹ That's no excuse for quitting though. Especially when you know you're right, and you have the weight of the evidence backing you up.

The Science Is Clear: UV Light is Essential, Overexposure is the Problem

In this case, dermatologists have done severe damage to the public health by fighting an irrational and dangerous war against the sun and UV light devices — unless, of course, that UV light comes in the form of a paid service provided in their office. We need to fight back against this sun-scare campaign because there are simply too many lives at stake. Fortunately, many others are now bucking the status quo by recommending sun exposure.

In a March 10, 2016 "Positive Choice" newsletter covering cancer prevention and general wellness, it states, in unequivocal terms:⁶⁰

"It is true that too much sun exposure, and especially sun burns, contribute to skin cancer. But the message to avoid the sun altogether may be misguided. Our increasing knowledge about vitamin D, the sun, and how they affect our immune system has us re-thinking the recommendation to avoid the sun completely ...

Most people have heard of the studies that connect sun exposure to skin cancer. But there are many studies that suggest sun exposure (and maximizing vitamin D levels) plays a role in decreasing risks of at least 16 different types of cancer including lung, pancreatic, breast, ovarian, prostate, and colon cancers. Without question sun exposure and the vitamin D we make when in the sun is vital to health ..."

The newsletter goes on to state that "For healthy people, moderate sun exposure (two to four times a week for 15 to 30 minutes) is not a problem," and lists a number of "healthy sunbathing tips" — all of which are virtually identical to my own, and the reason for this is likely because they are also looking at, and basing their recommendations on, the available science.

Veterinarians will tell us about the importance of UV lighting for our pet reptiles,⁶¹ but when it comes to the importance of UV light for our own health, our own doctors keep us in the dark — this despite the fact that the science of UV and its essential nature to human health has been known for centuries.⁶²

Truly, we should individualize and optimize UV exposure for maximum health benefits. Instead we're fighting against narrow-minded skin doctors who refuse to accept the massive harm UV abstinence is causing. The AAD's advice to avoid all UV exposure is right on par with tobacco companies saying cigarettes are safe — as UV abstinence may cause as many deaths as smoking.

Diet is also completely ignored by dermatologists. Regularly consuming processed vegetable oils may predispose you to skin damage that can lead to cancer for the fact that these oils are so easily oxidized.

Healthy fats are needed for healthy skin, so another simple way to limit your risk is to eat healthy saturated fats, dietary cholesterol, and other healthy oils that resist oxidation. Foods rich in carotenoids also help reduce your risk,⁶³ and supplemental astaxanthin has been shown to help protect against UVA-induced skin photo-aging, such as sagging and wrinkles.⁶⁴