SUNSCREEN RESEARCH NEWS
Sunscreen
Photostability
The FDA
Sunscreen Monograph
April 27, 1999
Revised May 4, 1999
Avobenzone is a new UVA absorbing
ingredient recently approved in the US for use in OTC sunscreen products. The stability
during sun exposure of sunscreen products containing Avobenzone is rapidly becoming an
important issue for sunscreen manufacturers, dermatologists and the consumer.
It is well-known that Avobenzone
and other sunscreen ingredients may degrade in sunlight, potentially reducing the
protection factor of the sunscreen product1,2,3. At the same time, it is known
that sunscreen products are tested in panels of 20 human volunteers, according to the FDA
Sunscreen Monograph4 to measure the sun protection factor (SPF). In the SPF
test, sunscreen products on the skin receive doses of ultraviolet (UV) energy simulating
sun exposure. For a product to be labeled as SPF 30, it must prevent sunburn until a UV
dose equivalent to 30 times the minimal erythema dose (MED) is received. This is
approximately equivalent to a full day of summer sun exposure.
Considering the above, we asked,
how can a product be degraded by sunlight and still be protective in the SPF test?
To address the question, we used
an Optronic Laboratories Model OL754 spectroradiometer with an integrating sphere, as
shown below. We applied sunscreens to collagen membrane substrates at 1 mg/cm2,
allowed 15 minutes for drying and mounted the preparations over the opening of the
integrating sphere. Then we irradiated the preparations with simulated solar UV from a
Solar Light Company Model 16S solar simulator and measured the transmitted spectral
irradiance from 290 to 400 nm at 10 minute intervals, for approximately 6 hours. During 6
hours the sunscreen preparations received over 30 MEDs of simulated sunlight. An MED
is defined as 20 mJ/cm2 of erythemally effective UV radiation.
We used the McKinlay-Diffey
erythemal effectiveness spectrum5 to calculate the effective power at each
wavelength and integrated each spectral measurement to obtain the total effective power.
Then we calculated the sunscreen SPF as the ratio of the effective erythemal power
transmitted by the substrate alone to that transmitted by the sunscreen and substrate. We
also calculated the cumulative SPF as the ratio of the total effective energy dose
transmitted by the substrate alone to the total dose transmitted by the sunscreen and
substrate, over the time period of UV irradiation.
The following chart presents the
result for a marketed sunscreen product containing Avobenzone 3%, octyl methoxycinnamate
7.5% and oxybenzone 3%.

The initial SPF was over 100, and
after 30 MEDs the SPF had dropped to the low 20s. However the cumulative SPF was
approximately equal to the labeled SPF. We have observed similar behavior for other
products containing Avobenzone.
These results appear to answer the
question posed above: Products containing Avobenzone degrade in sunlight, but start out
with SPF values several-fold higher than their labeled values. Thus their measured SPFs
are their cumulative SPF values over the period of UV irradiation.
References:
1. Sayre RM, Dowdy JC. Avobenzone
and the photostability of sunscreen products. Photoderm Photomed Photimmunol 1998; 14:38.
2. Sayre RM, Dowdy JC, Sayre DL.
Photoinstability of Avobenzone containing sunscreen products. American Society for
Photobiology, 26th Annual Meeting, 1998, Snowbird UT (Abstract).
3. Sayre RM, Dowdy JC.
Photostability testing of avobenzone. Cosmetics & Toiletries 1999; vol 114, No 5, May
1999.
4. U.S. Food and Drug
Administration. Sunscreen Drug Products for Over-The-Counter Human Use. Federal Register
43:38206-69, August 25, 1978.
5. McKinlay AF, Diffey BL. A
reference action spectrum for ultraviolet induced erythema in human skin. CIE Journal
1987; 6(1):17-22.
Suncare Research Laboratories, LLC
740 East Brookhaven Circle
Memphis, TN 38117
901-761-2752
901-761-0350 (fax)

November 2, 1999
The Final Sunscreen Monograph
By Joe Stanfield
The Final FDA Sunscreen Monograph was published in the
Federal Register on Friday, May 21, 1999 (Vol 64, No 98, pages 27666-27693). Following is
a synopsis:
General
The regulation is effective May 21, 2001 for sunscreen
products. Any OTC sunscreen drug product marketed after that date that is not in
compliance with the regulation is subject to regulatory action" [p. 27682]
Note: As of October 13, 1999, the
FDA has delayed implementation of the Monograph until December 31, 2002. At that time they
will issue labeling requirements for UVA protection. I expect them to define requirements
for lamps used in SPF testing more explicitly, also.
The FDA estimates that approximately 12,000 sunscreen
SKU's will have to be relabeled, and some will need to be re-tested, within a 2-year
period to comply with the requirements of the monograph. [p. 27684]
The FDA Monograph represents completion of the process of
developing regulations for OTC sunscreen products initiated in August of 1978, except for
"certain testing issues" and UVA labeling, which the FDA will discuss in future
issues of the Federal Register. Until then, permissible UVA labeling must comply with the
Tentative Final Monograph (May 12, 1993, 58 FR 28194) and its amendments (June 8, 1994, 59
FR 29706; September 16, 1996, 61 FR 48645; April 30 1997, 62 FR 23350 and October 22,
1998, 63 FR 56584).
Permitted Active Ingredients (Maximum Concentrations) [p.
27687]
Aminobenzoic acid (15%)
Avobenzone (3%)
Cinoxate (3%)
Dioxybenzone (3%)
Homosalate (15%)
Menthyl anthranilate (5%)
Octocrylene (10%)
Octyl methoxycinnamate (7.5%)
Octyl salicylate (5%)
Oxybenzone (6%)
Padimate O (8%)
Phenylbenzimidazole sulfonic acid (4%)
Sulisobenzone (10%)
Titanium dioxide (25%)
Trolamine salicylate (12%)
Zinc oxide (25%)
Products with Combinations of Active Ingredients [p.
27672]
The concentration of each active ingredient must be
sufficient to produce a minimum SPF of 2 [in the finished product].
The finished product must have an SPF of not less than
the number of active ingredients multiplied by 2.
Labeling [pp. 27675-27677]
The FDA has established 30 as an upper limit for SPF
labeling. Products with SPF values over 30 may be labeled as "30 plus" or
"30+".
The SPF value for a product labeled "water
resistant" or "very water resistant" will be the SPF determined in the
water resistance test.
Extended wear claims concerning a specific number of
hours of protection and the use of terms such as "all day protection" are not
permitted.
Permissible labeling is limited to prevention of
sunburn.
Solar Simulators for SPF Determinations [p. 27690]
Continuous emission spectrum from 290 to 400 nanometers
similar to sunlight at sea level with the sun at a zenith angle of 10 degrees.
Less than 1 percent total energy output from
wavelengths shorter than 290 nanometers.
Not more than 5 percent of total energy output from
wavelengths longer than 400 nanometers.
No significant time-related fluctuations in output.
Beam uniformity within 10 percent.
Output measured periodically with a calibrated
spectroradiometer.
Subjects [pp. 27690-27691]
Male and female with fair skin (Types I, II, and III,
see below.)
No medication that is known to produce abnormal
sunlight responses
No abnormal responses to sunlight, such as a phototoxic
or photoallergic response
No sunburn, suntan, scars, active dermal lesions or
unven skin tones on the areas of the back to be tested. (nevi, blemishes, or moles will be
acceptable if in the physician's judgment they will not interfere with the study results
Excess hair on the back is acceptable if the hair is
clipped or shaved.
Legally effective written informed consent
Not more than 25 subjects, with the number fixed in
advance by the investigator
At least 20 subjects must produce valid data for
analysis
Skin Types
(From Sunburn and Tanning History based
on first 30 to 45
minutes sun exposure after a winter season of no sun
exposure.)
I--Always burns easily; never tans (sensitive).
II--Always burns easily; tans minimally (sensitive).
III--Burns moderately; tans gradually (light brown)
(normal).
IV--Burns minimally; always tans well (moderate brown)
(normal).
V--Rarely burns; tans profusely (dark brown)
(insensitive).
VI--Never burns; deeply pigmented (insensitive).
Test Sites [pp. 27690-27691]
Located on the back between the beltline and the
shoulder blade and lateral to the midline
A minimum of 50-square centimeters in area, outlined
with ink, drawn with the subject in the test position, e.g. upright or supine
Application of test materials [p. 27691]
2 milligrams per square centimeter
Spread using a finger cot
Applied in a blinded, randomized manner
If only one sunscreen drug product is being tested, UV
radiation doses will be applied in a randomized manner.
Minimal Erythema Dose [p. 27687]
The MED is the UV energy dose required to produce the
first perceptible redness reaction with clearly defined borders on unprotected or
protected skin.
Evaluation of Responses [p. 27691]
The Evaluator must not be the same person who applied
the test products or administered the doses of UV radiation.
Erythema responses are evaluated 22 to 24 hours after
exposure.
The erythema responses should be evaluated using either
a tungsten light bulb or a warm white fluorescent light bulb that provides a level of
illumination at the test site within the range of 450 to 550 lux.
Subjects should be in the same position used when the
test site was irradiated.
Some exposures should produce no effect; of those that
produce an effect, the maximal exposure should be no more than twice the total energy of
the minimal exposure.
Determination of the MED for Unprotected Skin [p. 27692]
The MED for unprotected skin is determined by
administering a geometric series of 5 exposures represented by (1.25)n e.g. 6,
8, 10, 13 and 16 seconds.
Usually a preliminary MED series is administered on the
day before the SPF test and the result determines the doses administered to unprotected
and sunscreen-protected skin which are used to calculate the SPF.
Determination of Individual Subject SPF values [p. 27692]
A series of 7 doses will be administered to the
sunscreen-protected sites. Doses will be determined by the preliminary MED and the
expected SPF of the product.
For products with an expected SPF less than 8, the
exposures will be the preliminary MED of unprotected skin times 0.64X, 0.80X, 0.90X,
1.00X, 1.10X, 1.25X, and 1.56X, where X equals the expected SPF of the test product.
For products with an expected SPF between 8 and 15, the
exposures will be the MED of unprotected skin times 0.69X, 0.83X, 0.91X, 1.00X, 1.09X,
1.20X, and 1.44X, where X equals the expected SPF of the test product.
For products with an expected SPF greater that 15, the
exposures will be the MED of unprotected skin times 0.76X, 0.87X, 0.93X, 1.00X, 1.07X,
1.15X, and 1.32X, where X equals the expected SPF.
The SPF value of the test sunscreen is then calculated
as the ratio of the MED of sunscreen-protected skin to the MED of unprotected skin.
Determination of the Test Product's SPF Value and PCD [p.
27692]
Use SPF values from at least 20 test subjects.
Compute the mean SPF value, x, and the standard
deviation, s.
Find the upper 5-percent point from the t distribution,
t.
The label SPF equals the largest whole number less than
(x - A). {Typically, a product with a mean SPF of 15 would be labeled 13, by this
approach.}
Determine the Product Category designation: If (30 + A)
< x, the PCD is "High"; if (12 + A) < x < (30 + A), the PCD is
"Moderate"; if (2 + A) < x < (12 + A), the PCD is "Minimal"; if
x < (2 + A), the product shall not be labeled as a sunscreen drug product and shall not
display an SPF value.
Water Resistant or Very Water Resistant. [pp.
27692-27693]
An indoor pool, whirlpool, or jacuzzi maintained at 23
to 32 deg.C is used.
The term "Very Water Resistant" replaces the
current "Waterproof" category.
For a "Water Resistant " product, the label
SPF is the SPF value determined after 40 minutes of water immersion; for a "Very
Water Resistant" product, the label SPF is the SPF value determined after 80 minutes
of water immersion.
We invite your questions and comments regarding problem
areas, particularly those associated with testing methodology, and will display them on
this page.
Suncare Research Laboratories
740 East Brookhaven Circle
Memphis, TN 38117
901-761-2752
901-761-0350 (fax)