16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00168

Submission Number:
00168
Commenter:
Andrew Hans
State:
New York
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I have been a Doctor of Optometry for over 29 years. I believe there are too many loopholes in the FCLCA that are inconsistent to the medical interests of my patients. There have been dozens of times where I see a patient and they show me the boxes of the CL's they are using and they are different from what I Rx'd. Sometimes I get a verification with a few days to go before the Rx expires and the patient is obviously re ordering another years worth of lenses and bypassing the exam needed to check eye health. Or my favorite--the fax comes in for a CL verification late on a Saturday night when we are closed and we see it Monday morning more than the 8 hour limit to reply so the lenses are sold to them for another year. I think the verification part should be lengthened to 24 hours, and you might put more penalty into these 1-800 places and internet sites that continually refill my Rx when it is expired, or decide to change the lenses my patients use without tell me before they do so. Contact lenses are a medical device that should be in the control of the doctor not a disinterested online retailer whose only bottom line is the money going into their cash register. At the very least strengthen this law. Dr. Andrew Hans