16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00063

Submission Number:
00063
Commenter:
Darren Jones
State:
Colorado
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I understand the need for patient to have access the their prescriptions but there are a few unintended consequences from the FCLCA that need to be addressed. 1) Some companies are filling expired or unconfirmed prescriptions for years at a time without an consequences on their part. I find out when a patient comes into my office with damage to their eyes from contact lens abuse. I will ask where they are getting their lenses because the prescription has been expired for a long time. They always say "online" and that no one ever checked the Rx. Many companies don't care for patient safety and continue to fill these invalid Rx's. They look for loopholes in the Rx verification system and purposely exploit them to insure no interruption to their sale. I am sure the FCLCA never intended for this type of action. This carelessness would never be tolerated with a drug Rx but somehow a patients vision seems to be less important. 2) Some companies are trying to change the Rx to substitute another contact lens in place of the one written. This can be very dangerous. A contact lens Rx signifies a lens that has been fit and deemed safe for the patient to wear. Each lens has a different sizing, curves and materials that could make it a very bad choice for certain patients. There is no such thing as a "generic" contact lens as each lens will fit each eye differently. This type of action is very dangerous to the general public and shouldn't be tolerated. Please consider these points as you review the FCLCA. Vision is precious and it is our responsibility to protect it. Darren Jones OD