MSNBC asked me to gather my thoughts on the FDA and sunscreen. I think the play turned out very well. Here are some key charts:
…In the European Union, sunscreens are regulated as beauty products, which means greater flexibility in the approval of active ingredients. In the United States, sunscreens are regulated as medicines, which means that approval of new ingredients is a lengthy and expensive process. Because they are treated like cosmetics, sunscreens made in Europe can use a wider variety of ingredients that protect better, are also less oily, less chalky and last longer. Does the FDA’s longer and more demanding approval process mean American sunscreens are safer than their European counterparts? No way. In fact, American sunscreens can be less on.
Sunscreens protect by blocking ultraviolet rays from penetrating the skin. Ultraviolet B (UVB) rays, with their shorter wavelength, primarily affect the outer layer of the skin and are the main cause of sunburn. In contrast, ultraviolet A (UVA) rays have a longer wavelength, penetrate deeper into the skin, and contribute to wrinkles, aging, and the development of melanoma, the deadliest form of skin cancer. In many ways, UVA rays are more dangerous than UVB rays because they are more insidious. UVB rays strike when the sun is shining, and because they burn, they are a natural warning. UVA rays, however, can pass through clouds and cause skin cancer without causing obvious skin damage.
The problem is that American sunscreens work better against UVB rays than against the more dangerous UVA rays. In other words, they prevent sunburn better than skin cancer. In fact, many American sunscreens would not meet European standards for UVA protection. It is precisely because European sunscreens may contain more ingredients that they can protect better against UVA rays. So instead of being safer, American sunscreens might be riskier.
Most opinion pieces on the issue of sunscreen end there, but I like to put the lag in sun protection in a broader context:
Dangerous precautions should be a familiar story. During the Covid pandemic, Europe approved rapid antigen tests much faster than the United States. As a result, the United States floundered for months while infected people unknowingly spread the disease. By careful estimation, more than 100,000 lives could have been saved if rapid tests had been available earlier in the United States.
I also discuss cough medicine in the editorial and, of course, I propose a solution:
If a drug or medical device has been approved by another developed country, a country recognized by the World Health Organization as a strict regulatory authority, then its approval should be accelerated in the United States… Americans traveling to Europe do not hesitate to use European sunscreens, rapid tests or cough medicines, because they know that the European Medicines Agency is a prudent regulator, at least on par with the FDA. But if Americans in Europe have no qualms about using pharmaceuticals approved in Europe, then why are those same pharmaceuticals banned for Americans in America?
Peer approval works in other regulatory areas. A German driving license, for example, is recognized as legitimate — meaning no need to take another driving test — in most U.S. states and vice versa. And the FDA recognizes some peers. When it comes to food regulation, for example, the FDA recognizes the Canadian Food Inspection Agency as its counterpart. Peer approval means that imports and exports of food products to and from Canada can be expedited through regulatory paperwork, benefiting both Canadians and Americans.
In short, the FDA’s overly cautious approach to sunscreens is a lesson in how precaution can be dangerous. By adopting a peer-review system, we can avoid deadly delays and provide Americans with better sunscreens, effective rapid tests, and superior cold medicines. This approach, supported by both political sides, can modernize our regulations and ensure that Americans have timely access to the best health products. It is time to move forward and move from caution to action, in the interest of public health and less risky exposure to the sun.