16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
In my opinion and experience there are loopholes in the Fairness to Contact Lens Consumers Act that allow sellers and consumers to circumvent the original intention of the law. The current system of passive prescription verification allows regulated medical devices (contact lenses) to be ordered with incorrect or even falsified information. The time verification window (8 hours) is too narrow to allow offices adequate time to respond. It should be replaced with an active verification system and which also allows the prescriber to place reasonable limits on the quantity of lenses that can be ordered. Currently, unscrupulous sellers can (and do) ship unreasonable quantities of contact lenses to patients, providing them with multiple year supplies of lenses. This practice results in decreased frequency of medical supervision and the impression among "consumers" that routine examinations are unnecessary. This is contrary to the public health. Also, the proliferation of contact lens retailers based outside of the US who sell lenses to consumers within the US while totally disregarding the law needs to be addressed.