The National Academies of Science (NAS) released its final report on Tuesday afternoon (August 9, 2022) entitled “Environmental Impact of Currently Marketed Sunscreens and Potential Human Impacts of Changes in Sunscreen Usage.” The PASS (Public Access to Sunscreens) Coalition had lobbied Congress to approve this multimillion-dollar sunscreens study which was approved by Congress two years ago (Appropriation Act of 2020, Public Law 116-94). Congress awarded the project to the Environmental Protection Agency (EPA) which commissioned the NAS to conduct the study. The two objectives were:

1. Review of fates and effects on aquatic environment
2. Implications of potential changes

The report basically concluded that environmental exposure and hazard data on sunscreen ingredients are limited and the available research does not equivocally support the conclusion that individual UV filters have a substantial negative effect on marine organisms. The report also stated that restrictions on UV filters may have a negative impact on the use of sunscreens to prevent skin cancer and photoaging.

The sunscreen industry is anticipating the restrictions in Hawaii on the use of UV filters for protection (only zinc oxide and titanium dioxide will be permitted without a prescription) with the Maui law going into effect in October and the Big Island of Hawaii in December of this year. We were all looking forward to reviewing the final recommendations of this NAS study. Unfortunately, this study though very well written, researched and reviewed all aspects of the subject, did not provide regulators and municipalities with conclusions on the use or limitations of sunscreens. The NAS study stated in their final conclusions “Ultimately, finding solutions that respect and minimize harm to the environment while maximizing concern for human health will require cooperation, rigorous and transparent aquatic and human science, and open dialogue between scientists, health professionals, and cross-sectoral government agencies and non-governmental organizations.”

The NAS study made two recommendations:

1.  The EPA should conduct an ecological risk assessment (ERA) for all currently marketed UV filters and any new ones that become available.

2. The EPA with partner agencies (e.g., CDC, FDA, NIH, NOAA, Dept of Interior and NSF) and sunscreen formulators and UV filter manufacturers should conduct, fund or support, and share research and data on sources, fate processes, environmental concentrations, bioaccumulation studies, modes of action, and ecological and toxicity testing for UV filters alone and as part of sunscreen formulations. Additionally, epidemiological risk modeling and behavioral studies related to sunscreen usage should be conducted to better understand human health outcomes from changing availability and usage.

What does all this mean? First, it is a positive development that the NAS study emphasized that protection with sunscreens is an important tool in warding off the hazards of sunlight exposure. Second, that the research is still not conclusive as to the damage attributed to sunscreens on the environment and third, is that further studies are warranted prior to enacting laws by regulators and municipalities that restrict the use of sunscreens for skin protection. In reality, however, this uncertainty will unfortunately not quell the negative impact completely on the use of sunscreens but it is definitely a step in the right direction.

Ed. note: To read the Personal Care Products Council's comments on the NAS review, click here. To read the PASS Coalition statement, click here. 


About the Author
Dr. Nadim Shaath is the president of Alpha Research & Development, Ltd. in White Plains, NY. He has over 30 years of experience in the sunscreen industry. He served as the Chairman of the chemistry department at SUNY-Purchase and the CEO of Kato Worldwide. Recently he published his new book entitled “Healing Civilizations: The Search for Therapeutic Essential Oils and Nutrients” Cameron Books, Petaluma, CA.  [email protected]