16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00031

Submission Number:
00031
Commenter:
Kathy Chriqui
State:
California
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I am an optometrist and would like to describe many instances where my patients have been able to get their CL for 4-5 years by simply asking for a refill without any current prescription. In most of the cases, the patients eyes were compromised with neovascularization and corneal edema. Yearly exams help remind the patient proper care of their CL, as well as letting them know if there are any corneal involvement. Patients will often get used to a certain discomfort with CL, recognizing that as normal, and continue to wear their lenses without giving their eyes a break. The passive verification method for CL has profited the sellers and has been detrimental to the patients. The FTC should modify the Rule to better protect the public. 1. Prohibit sellers from sending prescription verifications after business hours and on weekends. 2. Prohibit the use of robocalls for verifying patient's prescriptions. These calls are often difficult to understand, and are disruptive to the practice. 3. Prohibit the sale of CL with an expired prescription. 4.Require that CL prescription include a maximum quantity of lenses that can be purchased prior to the prescription expiration. CL are a medical device and needs to be treated as so. An active verification system would be in the best interest for the public. With thus said, I strongly urge the FTC to strengthen the Rule to protect the public's eye health.