Fitzpatrick skin types at the front desk: what they are and what the law asks

What the Fitzpatrick scale measures

The Fitzpatrick scale is a six-level classification of how skin responds to ultraviolet light: how easily it burns and how well it tans. It is defined by how skin behaves in the sun, not by skin color alone. Texas writes the scale into its tanning statute and defines it by "the skin's reaction to the first 10 to 45 minutes of sun exposure after the winter season."

The wording in the table is the Texas definition in Health and Safety Code 145.002. Pennsylvania's Indoor Tanning Regulation Act uses the same six descriptions. Illinois uses its own table with two columns, sun sensitivity and pigmentary response, so its Type I reads "Always burns easily" and "Little or no tan."

Where the scale came from

Dermatologist Thomas B. Fitzpatrick created sun-reactive skin typing in 1975. His 1988 paper in Archives of Dermatology, "The Validity and Practicality of Sun-Reactive Skin Types I Through VI," explains the original purpose: to classify people with white skin so doctors could choose the right starting dose of ultraviolet A for PUVA, a then-new psoriasis treatment.

He described several patients with a "dark" phenotype, meaning brown or even black hair and in some cases brown eyes, who still had severe phototoxic reactions at starting doses he called "obviously too high." Hair and eye color alone could not predict how a person would respond. That is why skin typing asks how skin behaves in the sun, and not only what color a client's hair and eyes are.

The FDA tells the same history. In a 2015 proposed rule it described "the historical Fitzpatrick skin typing system" as developed "to predict skin reactivity in phototherapy," with Type I "the fairest and most sensitive" and Type VI "the darkest and least sensitive to UV radiation." The scale was built to choose a starting dose, and that is still its job in a salon.

What federal rules say about skin type

Federal law puts skin type into the manufacturer's paperwork. Under 21 CFR 1040.20(d)(1)(iv), each tanning bed or booth label must carry "a recommended exposure schedule including duration and spacing of sequential exposures and maximum exposure time(s) in minutes." Under 1040.20(e)(1)(iv), the user instructions must include "instructions for determining the correct exposure time and schedule for persons according to skin type."

So the salon's task is to match each client's type to the schedule for the unit they are about to use. Our guide to the tanning exposure schedule covers how to read one, and FDA tanning bed regulations covers the rest of the federal rules.

A change has been proposed but is not final. In December 2015 the FDA proposed amending 1040.20 (Federal Register document 2015-32023). Every exposure schedule would carry the warning "Skin Type I individuals (always burns, never tans) should never use sunlamp products," and the skin-type instructions would be dropped because one schedule would serve Types II through IV. When the FDA withdrew its separate under-18 proposal on March 16, 2026, it said the 1040.20 amendments were "not affected by this withdrawal."

As of 2026-09-29 the 2015 amendments have not been finalized. The rule in force still asks manufacturers for exposure instructions by skin type, and neither 21 CFR 1040.20 nor the device labeling rule at 21 CFR 878.4635 contains a Type I warning.

Which states put skin type into the salon's duties

Some states go further than the federal label rule. The five below were read in each state's own code on 2026-09-29. This is not a complete list, so check your state in our tanning laws by state hub.

The details differ. In Texas the customer determines their own type. In Ohio a certified operator reviews scored questions with the client, unless a device does the typing. Pennsylvania wants staff able to recognize a type but does not list it among the record fields. Write your intake form to your own state's wording.

How to type a client at the front desk

1. Type every UV client before the first session. Ohio requires it on the first visit, and every other step below depends on it.
2. Use a written questionnaire, not a glance. Ohio requires questions on sun sensitivity, natural coloring, recent tanning history, medications and medical history, each given a numerical value and totaled. Illinois publishes a scored questionnaire in Appendix B of its rule, covering eye, hair and skin color, freckles, how skin reacts to the sun and recent tanning habits, with the total mapped to a type.
3. Record the type, the date and who decided it. That is the client in Texas and a certified operator in Ohio.
4. Set times from the unit's own label and instructions. Start from the manufacturer's schedule for that type on that unit, and never exceed the manufacturer's maximum exposure time. Texas, Virginia, Pennsylvania and Illinois each limit sessions to the manufacturer's maximum.
5. Explain it to the client. Texas requires first-time customers to be told about the correlation between skin type and exposure time and the maximum exposure time on the facility's devices. Virginia requires staff to advise each customer of their maximum recommended exposure.
6. Keep the record as long as your state requires. Texas and Pennsylvania both set a three-year minimum. See tanning salon recordkeeping.
7. Train every operator on the scale. Pennsylvania requires operators to know the six skin types, and Illinois lists them in required operator training.

Skin typing fits naturally on the intake form, next to the warning statement and the client's signature. Our tanning consent form guide covers what else that form needs.

Type I clients, changed answers and spray tans

Neither federal sunlamp rule in force today contains a Type I warning, and the FDA's "should never use" wording is still a proposal. Some states cover it on the warning form instead. Texas (Health and Safety Code 145.005(a)(6)) and Pennsylvania (Act 41 of 2014, section 5(b)(6)) require the written warning statement each customer receives to say that "a person with skin that always burns easily and never tans should avoid a tanning device."

For a Type I client, look at the unit's label and instructions, your state's rules and your own house policy. A salon can, for example, decide to offer Type I clients a sunless service instead of UV. Whatever the policy is, write it down, train staff on it and apply it the same way every time.

Answers can change. A client who starts a new medication or returns after months away may answer the questionnaire differently, so ask again and update the record when something changes. Ohio's required questions cover both medications and recent tanning history.

Spray tanning sits outside these skin-type rules, which are written for UV equipment. Texas, for example, defines a tanning device as equipment that emits electromagnetic radiation with wavelengths between 200 and 400 nanometers and is used for tanning, which a spray booth does not do. Ohio puts its skin-type duty under its sunlamp rules, not its separate chemical tanning rules.

How TanVision handles skin type

For UV beds, TanVision recommends a session time from the client's Fitzpatrick skin type and how far into building a tan they are, and steps the time back after a long enough break. Each salon decides whether to use skin typing at all and sets the gap between UV sessions.

Staff type the minutes at check-in. TanVision refuses any typed time above the limit or above the room's own maximum, and it never quietly trims the number. The recommended times are TanVision's own defaults, not law. The exposure limits follow the salon's own settings, capped at each unit's maximum, and the unit's label stays the authority.

Spray, red-light, sauna and wellness rooms skip skin typing and the exposure schedule. See exposure safety and client records, or book a demo to watch a check-in.