16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00094

Submission Number:
00094
Commenter:
Wang
State:
California
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
The Contact Lens Rule fails in the area of prescription verification. Passive verification allows for too many opportunities for otherwise non-valid prescriptions to be filled. These may include doctors' offices which may be closed one day during the week, changes to fax and / or telephone numbers, incorrect keying in of a fax number by the consumer purchasing contact lenses, and even deliberate attempts to evade verification with the knowledge that a lack of verification is equivalent to a prescription being verified. An example of doing this is even outlined online as can be seen at this website: http://www.contactswithoutaprescription.com/what-does-passive-prescripti... As medical devices, the filling of contact lens prescriptions should be regulated similarly to the filling of prescriptions for medications - via active verification. The Contact Lens Rule ensures that consumers have the fair opportunity to purchase contact lenses from the reseller of their choice. Passive verification only muddles the process by allowing too much potential for accidental as well as deliberate filling of non valid prescriptions.