Requirements for age control systems
The following solutions are considered to be adequate:
- Staffing, or staffing combined with electronic access control when the premises are not staffed throughout opening hours.
- Video camera with document reader connected to a customer centre.
- Other type of in advance age check and registration, in combination with subsequent electronic access control.
It is up to each company/organisation to choose the solution and age control system that is most appropriate for the company/organisation, as long as it adequately controls and ensures that persons under 18 years of age are not permitted access to the sunbed.
An age control system consists of two components: a pre-check of the customer's age and a subsequent access control.
Pre-check of the customer’s age
Before indoor tanning may be offered to a customer, his/her age must be checked.
In staffed services, full time or part time during the opening hours, the staff may check the customer’s age upon arrival (valid ID: driver's license, passport or debit card with photo).
Electronic pre-check of age may also be used, for example in unstaffed sunbed studios, if the following requirements are met:
- If registration and age check of customers is carried out via the internet, login methods with the same security level as the ones used in “ID-porten” (BankID and others) must be used.
- If the customer’s ID (driver's licence, passport or debit card with photo) is to be read electronically, a document reader specifically designed for these purposes must be used. In order to ensure that the correct person is given access the document reader must be used in combination with a video camera.
- Paying with a credit or debit card is not considered a sufficient way of checking the customer’s age. Despite the fact that one must be over 18 years of age in order to have a credit card or that the debit cardholder’s age may be read from the card, there is no guarantee that the card’s actual owner is the person using it. Paying for the tanning session with a credit or debit card is acceptable but the age check must be performed with another method prior to payment.
Subsequent access control
After the age control is performed, different ways for access control may be used.
If the services are staffed during opening hours, the staff may ensure that only people above the age of 18 are given access to the sunbeds.
If electronic access control is used, for example in unstaffed or part-time staffed services, the following solutions, amongst others, are considered satisfactory:
- Combination solutions with for example an entrance card/chip and a personal pin code.
- Solutions using single-use codes received by SMS, in mobile phone app or similar in order to gain access to the sunbed.
An entrance card/chip alone or a combination lock alone (unless single-use codes are used) is not considered adequate. This is due to the risk of misuse (dispersion of codes, lending/stealing of the entrance card/chip etc.)
StrålevernInfo 3:2016 «Nye regler for solarievirksomheter» (in Norwegian only) describes examples of solutions to how the requirements for an age control system may be fulfilled.
Who must have passed the competence test “Solarieprøven”?
The following people are considered as employees in contact with customers and must therefore have passed the test (the list is not exhaustive):
- Those who perform age and/or access control or give information to the customers
- All employees working in receptions, cash desks or the like at fitness/sports centres, swimming pools, hotels, petrol stations and so on offering indoor tanning and thus having a natural possibility of communication with the customers. It is not considered satisfactory to only refer to a phone number for questions regarding sunbathing and the use of the sunbeds.
- Those listed as local contact persons in unattended sunbed studios, for example through announcements at the premises or in an electronic solution.
The person responsible for the daily operation of the sunbed, that is, who is responsible for general/minor maintenance, daily check of the sunbeds, change of lamps and the like must also have passed the test. This means that it is not sufficient that the owner of a rented sunbed has passed the test if the person renting the sunbed is actually the one who performs the daily checks and minor maintenance on the sunbed. The responsibility for daily operations can be shared between several people, and the test must then be passed by each one of these people. Who is responsible for the daily operations must be assessed regardless of how the business has organized the owner/rental relationship.
If you are in doubt whether you or your employees must have passed the test, please contact DSA for guidance.