16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
The FCLCA continues to be an important and necessary rule for public safety. It helps to ensure that patients are less likely to abuse their contact lenses by keeping the consumer from over filling their FDA regulated contact lens prescription. it also provides for fairness to the consumer by insuring that they have the freedom of choice for where they chose to purchase their product, just the same as glasses. I have seen fewer contact lens related "red-eyes" over the last several years as patients have become more compliant with the rule. However, I continue to still see some abuses of the rule as I still have patients that are able to fill up to a year supply on their prescription despite it expiration date of only being a month from expiring. We also continue to see on-line suppliers "skirt" around the intention of the law by sending out verification requests for patients to incorrect offices or only sending verification requests late in an evening on a day proceeding a "normal" business day, but not a day that the providers office is actually open due to doctor schedule. These are the activities that, while not actually violating the rule, continue to violate the intent of the rule to protect the safety of the consumer. I hope that the FTC will look at these known violations closer and consider more stringent enforcement of these violations. Sincerely, Dana L. Day, O.D.