16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00104

Submission Number:
Jeff Simmons
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
My concern with the current FTC Contact Lens rule is that it does not have a strong enough stance on Contact Lens retailers (online and elsewhere) that sell, distribute or otherwise dispense Contact Lenses without proper verification of a valid prescription. Contact Lenses are medical devices that require specific evaluation and proper care in dispensing. Instead, the current market treats contact lenses as nothing more than a commodity that are safe and harmless to the general public. This couldn't be further from the truth. As an optometric clinic, I just saw a new patient last week who had previously obtained a spectacle prescription from their prior doctor. This patient then took it upon themselves to order contact lenses online using the powers found on their spectacle prescription via an online retailer. They subsequently never received a proper contact lens evaluation from their medical provider and had successfully obtained and had been wearing lenses for multiple years that they never had a prescription for. Worst of all, because they had obtained their lenses through inappropriate means, they were never given proper hygiene and care education and had been severely abusing the lenses. It saddened me to see this patient as I had to inform them that with the infection and damage to their corneas caused by the contact lenses, they were no longer a candidate for refractive surgery and would likely be in glasses the rest of their lives. The patient was naive to the importance of a proper evaluation and prescription of contact lenses as they have been surrounded by a culture that portrays contact lenses as simple commodities. In this culture, patients are often unaware of the inherent risks that come with inappropriate contact lens use but able to easily obtain these potentially dangerous devices. I call on the FTC to strengthen and tighten their policy against contact lens retailers that pay little to no attention to the rules and regulations already set forth regarding verification of prescriptions. These retailers are more concerned with their profits than they are the ocular health of the customers they serve. This type of behavior would not be tolerated in relation to any other prescription, and MUST not be tolerated with something that can cause such permanent, debilitating damage. Thank you for your consideration. Jeff Simmons