How to read a tanning bed exposure schedule and maximum exposure time

What an exposure schedule is, and who it binds

An exposure schedule is the manufacturer's plan for how long, and how often, a person should use one specific tanning unit. The federal sunlamp standard, 21 CFR 1040.20, requires every sunlamp product to carry a label with "a recommended exposure schedule including duration and spacing of sequential exposures and maximum exposure time(s) in minutes." FDA's device rule for sunlamp products, 21 CFR 878.4635, says the term "includes tanning beds and tanning booths." The current text of 1040.20 applies to products manufactured on or after September 8, 1986.

The label must be permanently fixed to the outside of the unit so it is "readily accessible to view by the person being exposed immediately before the use of the product." The user instructions must reproduce that label and add "instructions for determining the correct exposure time and schedule for persons according to skin type," along with how to set the timer and use protective eyewear.

The federal section governs the product: what its label, timer and manual must contain. Operating duties for the salon, such as limiting each customer to the maximum exposure time, come from state law where a state sets them. Our overview of FDA tanning bed rules covers the rest of the federal standard.

How to read the label, line by line

The rule sets what a label contains, not its layout, so labels vary. Look for these items on every unit.

The timer is tied to the same number. Under section 1040.20(c)(2), the longest setting on a unit's timer may not exceed the maximum exposure time on its label, and no timer interval may have an error greater than 10 percent of the maximum timer interval.

Why skin type changes the numbers

FDA explained the logic in an August 21, 1986 policy letter to sunlamp manufacturers. It describes the minimal erythemal dose, or MED, as the UV dose "that causes a barely discernible pink coloration." Because that dose "is not the same for different skin types, the exposure schedule for first time users will depend on the skin type of the user."

The skin types are the Fitzpatrick scale, which runs from Type I to Type VI. FDA's 2015 proposed rule describes it as a system "developed in 1975 by dermatologist Thomas Fitzpatrick to predict skin reactivity in phototherapy." FDA describes Type I as "always burns, never tans" and Type II as "always burns, then tans slightly." Our guide to Fitzpatrick skin types for tanning salons covers how to record it at the desk.

The maximum exposure time is a ceiling, not a target

Each unit's maximum is set by its manufacturer. The 1986 letter says the maximum timer interval "depends on the intensity and spectral distribution of ultraviolet (UV) radiation emission of each individual model," so two models in the same salon can have different maximums.

The letter caps it at four times the MED, and four times the minimal melanogenic dose (MMD), for untanned Type II skin. It is also plain about what that cap means: "The maximum timer interval is in no way to be considered as a safe limit; all ultraviolet radiation is potentially hazardous."

These are dose criteria for manufacturers, not minutes. FDA's formula divides a fixed dose by each unit's weighted irradiance, so the same criterion produces different minutes on different models. A time copied from another model's chart does not apply to yours.

How long should a first-time client tan?

There is no universal number of minutes. The answer is the first-session time on that unit's schedule for that client's skin type, which FDA's criteria above keep to no more than 0.75 MED.

The federal rule does not define bed "levels," so a level name tells you nothing about a unit's schedule. Read the label on the unit the client is about to use.

Spacing between sessions

Spacing is part of the schedule. Section 1040.20(d)(1)(iv) requires the label to give the "spacing of sequential exposures," but the section itself sets no fixed number of hours between sessions. Neither does FDA's device rule for sunlamps, 21 CFR 878.4635 (eCFR text of both, current to September 25, 2026).

FDA's 1986 letter notes that "suberythemogenic doses of UV radiation received at 24 hours intervals initially lead to lowering of the erythema and tanning thresholds." Its criteria set frequency as well as dose: three exposures in the first week, and biweekly or weekly exposures once the tan is only being maintained. So a schedule controls how often, not only how long.

Some states add a floor. Rhode Island limits the first three to five sessions to one per 48 hours, and later sessions to one per 24 hours, in each case "or as recommended by the sunlamp product manufacturer, whichever is less frequent." It also says the manufacturer's maximum exposure time "shall not be exceeded in any twenty-four (24)-hour period." More in the 24-hour tanning rule.

What state law adds

State rules turn the label into a duty for the salon. Two examples, from each state's own code:

Rules differ by state. Check yours on the tanning laws by state hub, including the Florida and Rhode Island pages.

A front-desk routine that follows the label

1. Keep each unit's label legible and its user instructions on file. The manual is where the manufacturer explains how to match exposure time and schedule to skin type.
2. Record the client's skin type before their first UV session, using the method in the manual and your state's training requirements.
3. Look up the time on that unit's schedule for that client's skin type and session number.
4. Set the timer at or below that time, and never above the unit's maximum exposure time. A client who asks for a few extra minutes gets the schedule's answer. In Rhode Island, timers must be controlled by properly trained staff.
5. Check spacing before you start: the label's spacing and your state's minimum. Where they differ, follow the stricter one.
6. Decide in writing how you restart a client who has been away. Check whether your manual covers a gap, and apply one house rule to everyone.
7. Log the date, minutes and unit for every session. Florida requires customer-use records for at least 4 years, and Rhode Island requires the dates and durations of exposures, kept at least 3 years.
8. Put the routine in your procedure manual. Rhode Island requires a facility-specific manual kept on site (24.6.4(F)(5)).
9. Re-check the schedule when you change lamps or replace a unit. See tanning bed lamp replacement and tanning bed timer rules.

The 2015 proposal that has not taken effect

On December 22, 2015, FDA proposed amending the sunlamp standard (80 FR 79505, docket FDA-1998-N-0880). It would have capped the maximum timer interval at a dose of 500 J/m², which FDA called "approximately equivalent" to the 624 J/m² value in the 1986 letter. Schedules would have followed IEC 60335-2-27, Ed. 5.0, Annex DD, and used the same dose for Skin Types II through IV instead of separate schedules by skin type.

The proposed label text would also have required the warning "Skin Type I individuals (always burns, never tans) should never use sunlamp products" and the statement "Maximum sessions per week = 2." Comments closed on March 21, 2016.

FDA's March 16, 2026 notice withdrawing its separate under-18 proposal says the proposed amendments to 1040.20 "are not affected by this withdrawal." A Federal Register search on September 29, 2026 found no later document under this proposal's RIN (0910-AG30) or docket.

None of the 2015 changes is in the rule today. eCFR shows section 1040.20 was last amended in April 2018. When we checked on September 29, 2026, its timer paragraph had no dose limit and its label paragraph had no weekly session cap. Work from the current text and your unit's own label.

Where software fits, and where it stops

Software cannot read your label for you, but it can stop the desk at the number you set. In TanVision, each room carries its own maximum time. For UV rooms, the exposure safety engine recommends a time from the client's Fitzpatrick type and how far into their build-up they are. It refuses any typed time above that recommendation or above the room's maximum, instead of quietly trimming it.

When a skin type is on file, that recommendation comes from TanVision's own conservative built-in schedule, capped at each room's maximum. It does not load your manufacturer's schedule, so the label stays the authority: set each room's maximum from the label, and type a shorter time whenever the label calls for one.

By default, a client who has been away for more than 14 days is stepped back: their build-up progress halves, and halves again for every further 14 days. Each salon decides whether to use skin typing and sets its own minimum gap between UV sessions. At 0 nothing is blocked, but the desk still sees a warning for a second UV session within 24 hours. Spray and red-light rooms skip skin typing and the exposure schedule. The gap is a single number, so a two-stage rule like Rhode Island's needs the stricter setting or a check at the desk. Book a demo to see it on your own rooms.