Has it become unethical to market tanning?
Posted on | June 28, 2010 | No Comments
Author:
Jason Voiovich
Ecra Creative Group
Key Points:
1. A recent U of M study seems to remove all doubt – tanning (in any amount) is strongly linked to the most dangerous form of skin cancer, melanoma.
2. A combination of FDA, FTC, FCC, and state regulations will probably restrict tanning services in a variety of ways, but are not likely to kill the industry altogether.
3. If tanning will still be sold (in some form), “informed consent” could be the most prudent path forward from an ethical perspective.
I am not sure why this was a surprise to anyone.
Researchers at the University of Minnesota recently published a studying in which they found that people who use any type of tanning device, for any amount of time, are 74 percent more likely to develop a melanoma.
Holy crap.
Melanoma is not the more-easily-treated form of skin cancer. Melanoma is the really bad stuff. Of course, this comes as no surprise to experienced dermatologists, many of whom report an alarming increase in melanoma – especially among young people. And even less surprisingly (and more sadly), they say, among mainly young women in their teens and early twenties who using tanning salons.
Yes, that could still be correlation rather than causation, but I think we’re past that nuance on this issue, aren’t we?
As I write, the Food and Drug Administration is reviewing recommendations from a scientific advisory panel that would ban or severely limit indoor tanning use for those under 18. And if the feds don’t act, many states are thinking of taking up their own legislation.
Much of discussion in the marketing field as it relates to tanning will undoubtedly revolve around how to get young people to stop using tanning salons. Much like the “Truth” campaign to attack teen smoking, any anti-tanning efforts are likely to focus on dangers of tanning, what skin cancer looks like, and how it can kill you – not years down the road – but quickly.
Not that the messaging will be easy, or that it is not a professionally interesting problem, but I’d like to look at the issue from the other perspective for just a moment.
I’d like to pose the following question: How will tanning salons continue to market themselves? And if they do, is it ethical to do so? If it is, under what circumstances?
The knee-jerk reaction might be to say “shut them all down”, much like some would like to do to the tobacco industry. But that’s not only a mental copout, it’s also unrealistic. So long as tanning salons have a legal right to exist, and so long as they do not violate FCC guidelines on deceptive advertising, they have every right to communicate with their audience.
Let’s start with the first question, which speaks directly to target audience. Whether it is the FDA who lays down the law, or the FTC (Federal Trade Commission) who does it, or the states, the industry should count on being severely restricted in marketing to those under the age of 18.
That’s not as easy as it sounds.
The tobacco industry struggles with this as well, as does the liquor industry. If you advertise, say, in Cosmo, you would be reaching (primarily) an adult female in her late 20s to early 30s. But about 16-18% of your audience will be under 18. How do you select a media that will not reach who it is not intended to reach? (And let’s assume good intentions, that the industry does not want to reach younger people – which certainly is not a given – but that’s a topic for a different time).
Needless to say, this can get complicated fast. The chart below summarizes the coming maze of potential restrictions the tanning industry could face as it continues to communicate with its customers.
Needless to say, the tanning industry will need to get much better at selectively reaching its audience, and much more careful (creative!) regarding its messaging. The problem is, the tanning industry is highly fragmented. Unlike the barriers to entry in tobacco which consolidate the industry into a few very large players, even the “good guys” in tanning will need to compete with a huge pool of smarmy ones.
But beyond the legality lies the much more complicated ethical argument.
Assuming a combination of FTC, FDA, FCC, and state regulations will effectively remove the “under 18″ ethical issue, the tanning industry still will need to address the increasingly undeniable fact that it markets a dangerous product.
One argument would couch ethics in terms of the legal lay of the land. So long as the industry does not violate society’s written rules, it has every right to exist and market within that framework.
Another argument might ask the industry to weigh the benefits of tanning (self-esteem, enjoyment, etc) against the drawbacks (a risk – but not a guarantee – of skin conditions, including its most dangerous cancer). If the risks outweigh the benefits, so the argument goes, ethically you must cease.
A third path might raise the issue of “informed consent”. If the consumer enters the tanning salon with full knowledge and grasp of the risks, and choosing to partake anyway, then there is no ethical issue. The burden would be placed on the industry to educate its customers in order to make sure they can make the choice demanded of them eyes wide open.
I’m conflicted.
As a professional persuader, how could I use my abilities to help convince someone to engage in an activity I know could harm them – especially younger people? There is not only the question of a life cut short, but also the cost to society to care for very sick people when it could be avoided.
On the other hand, I am not sure I want to live in a world where someone (a government agency?) decides for me what products or services I can or cannot use. Of course, that already happens on a large scale, but how much more control do we want to cede?
My father had a way of thinking about things like this that I think will help us here. He reminded me to be careful of having too strong an opinion on anything. The world is full of millions of colors, only two of which are “black” and “white”.
I think he’s correct. Neither position is acceptable. Salons should be able to market their product, but it needs to be controlled. Balance may not make everyone happy, but I think it’s the best answer we’ve got right now.
Related Links:
U of M study links tanning beds to higher risk of skin cancer
Tags: FCC > fda > FTC > tanning
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About
Jason Voiovich
Ecra Creative Group
Phone: 651.209.2778
Principal and co-founder of Ecra Creative Group, a Minneapolis, MN based creative services firm specializing in brand development, reputation process management, naming/trademark, and product launches to drive measurable business results.
