16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00081

Submission Number:
Aaron Buthod
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
The Contact Len Rule needs to be updated to protect the public from themselves. The internet has reduced contact lenses from regulated medical devices to simple commodities. There is no oversight to protect patients from harming themselves. The online contact lens industry is showing NO REGARD for the safety and health of their "customers" by renewing expired prescriptions, selling more than the prescribed amount, and not verifying prescriptions. Brick and mortar offices that sell contacts are held to laws regulating the dispensing of contact lenses. We must only fill prescriptions that specifically state the brand and shape, and size of a contact lens. There is a limit to the number of lenses prescribed by the doctor (usually a year supply), and we can not change anything without the consultation of the prescribing doctor. The onliners are not being held to the same standard as there is no oversight. Current law allows patients to skip critical annual eye evaluations by purchasing more contacts than prescribed or simply using an outdated prescription. What the public does not realize is that the very purpose of the annual evaluation is to verify that their current contact lenses are not altering the health of the front surface of the eye. I routinely have patients that I have not seen for 3-5 years that have purchased their contacts online without my authorization. Just yesterday I had a patient come in wanting to re-order contact from a prescription that expired 2 years ago. When the patient was told we legally could not fill the prescription her response was, "OK, well, I will just buy them online then". This occurs too regularly. Earlier this week, I had to take a patient out of her contacts because she had been wearing the same lens for several months and it had scratched both eyes and induced unnatural blood vessel growth into the cornea. I see this too often. It is very common for me to change the type of contact lens the following year if I see corneal changes associated with contact lens abuse such as overwear or sleeping in contacts. The majority of my patients are completely unaware of the change as they state their eyes feel fine, when in fact, the corneal evaluation proves otherwise. The online contact lens lobby has bought off our legislature and produced a law that is harmful to our patients best interest. Why are brick and mortar businesses held to a higher standard than the onliners?????????????