All I know is that vitamin A is one of, if not, the main ingredient in Accutane, and that can have some pretty serious side effects. Sorry I'm not all that knowledgeable on the topic, but if you are concerned about safety maybe its best to check with a doctor.
You are right at the boundary of what is considered *possibly* safe. Better to stay at 10,000 IUs max unless you are under the direction of a physician. You probably are aware of the side effects; the worst being liver complications. Be careful.