Sunless tanning delivers a faux glow by coating your skin with the chemical dihydroxyacetone (DHA). DHA interacts with the dead surface cells in the epidermis to darken skin color and simulate a tan, and the result usually lasts for several days.
While the FDA allows DHA to be "externally applied" for skin coloring, there are restrictions on its use. DHA should not be inhaled, ingested, or exposed to areas covered by mucous membranes including the lips, nose, and areas in and around the eye (from the top of the cheek to above the eyebrow) because the risks, if any, are unknown. According to the CFR, "externally applied" cosmetics are those "applied only to external parts of the body and not to the lips or any body surface covered by mucous membrane" (21 CFR 70.3v). The industry has not provided safety data to FDA in order for the agency to consider approving it for use on these exposure routes, including "misting" from tanning booths.
"Warning--This product does not contain a sunscreen and does not protect against sunburn. Repeated exposure of unprotected skin while tanning may increase the risk of skin aging, skin cancer, and other harmful effects to the skin even if you do not burn." (21 CFR 740.19)
What Does This Mean For The Sunless Process?
When using products containing DHA as a spray or mist, it may be a challenge to avoid exposure in a manner for which DHA was not originally approved, including contact with the area of the eyes, lips or mucous membrane, or even internally. Because of this, the FDA suggests consumers ask the following questions when considering commercial facilities where DHA is applied by spraying or misting:
- Are consumers protected from exposure in the entire area of the eyes, in addition to the eyes themselves?
- Are consumers protected from exposure on the lips and all parts of the body covered by mucous membrane?
- Are consumers protected from internal exposure caused by inhaling or ingesting the product?
If the answer to any of these questions is “no,” the FDA says that the consumer is not protected from the use of sunless products. In this case, the FDA suggests that the consumers request measures to protect their eyes and mucous membranes and prevent inhalation.
What Does This Mean For The Technician Applying Sunless?
Sunless airbrush technicians must take extra care in informing clients to avoid breathing the sunless product during the application process. Consumers also should try to avoid direct application of the product into the eye area as described above, and use a lip balm or other barrier product on the lips and in the nostrils to avoid contact with the mucous membrane.
The FDA’s cautious opinion on DHA most likely stems from relying on limited information found in the product’s Material Safety Data Sheet (MSDS) originating in 1973. From its original use as a topical substance, DHA was listed with three “risk numbers”: R36, R37 and R38.
- R36 Irritating to eyes.
- R37 Irritating to respiratory system.
- R38 Irritating to skin.
These risk numbers are based on pure forms of DHA with no other additives considered such as water and so on. To put this into perspective, the purist form of many cosmetic ingredients fall under the same risk numbers.
To best take advantage of the bronzing effects of sunless products in its newest form, prudent sunless airbrush/HVLP technicians should use care when offering sunless in a spray or mist application.
- Have your clients avoid getting this and other tanning products directly into their eyes. Disposable eye protection may be a good option.
- Protect their lips with lip balm or petroleum jelly.
- A nose filter can be used to protect the mucous membrane and also to provide inhalation protection. You can also offer a disposable face mask for extra protection.
- Disposable undergarments can be used to protect the more private mucous membranes.
- Ensure proper ventilation for staff and clients in the sunless application area of your salon. An overspray booth or overspray fans with filters should be set up to remove overspray in the air. Spray equipment should not be set up near intakes for the salon’s ventilation system.
- Although sunless solution contains no known toxins, the repeated inhalation may cause irritation, as it would be with any substance. Common sense would dictate prudent technicians wear a filtering mask while spraying clients.
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