To Whom It May Concern:
As a health professional and consumer of sunscreen products, I applaud the agency’s effort to instill public confidence that sunscreen products will be allowed to be labeled as “Broad Spectrum” only after passing a standardized testing method. Skin cancer remains a significant public health problem in the United States and is considered a preventable cancer. The public requires continued education on primary prevention strategies such as avoiding sun exposure, wearing protective clothing, and the use of an appropriate sunscreen product. The relabeling of sunscreen products will provide consistency and standardization of information, so consumers can make informed decisions.
I am writing this letter to ask for reconsideration of the capping of sunscreen SPF labeling at 50+. Evidence provided and supported by the American Academy of Dermatology Association, Florida Suncare Testing Inc., and Johnson & Johnson Consumer Products Worldwide demonstrate that sunscreens with higher SPF (> 60) have been shown to prevent and reduce the harmful effects of the sun on high risk patient populations. I live and practice nursing in southwest Florida. A major focus of my education with patients and community is to protect the skin from the sun's harmful rays by incorporating the use of sunscreen into the daily routine. I encourage people to select sunscreen products with the highest level of Sun Protection Factor available. It has been in my own experience that I received the greatest protection from sunburn when using products that contain SPF of 60 and 85.
I am encouraged that the additional data provided during the extension period may be clinically sufficient to support eliminating the SPF cap. Capping the labeling under the new ruling of SPF 50+ will limit the public's ability to make choices for greater protection from the suns harmful rays.
Thank you for the ability to offer comments,
Robin McGuinness RN
Robin J McGuinness - Comment
This is comment on Proposed Rule
Sunscreen Drug Products for Over-the-Counter Human Use: Request for Data and Information Regarding Dosage Forms; Extension of Comment Period
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