16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00171

Submission Number:
00171
Commenter:
McBride
State:
Oregon
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
There are two problems with the Contact Lens Rule from my perspective. The first is the obvious problems with the passive verification process. It seems that a number of contact lens vendors intentionally ask for verification on Saturday, when a good number of offices are closed. I don't know what the solution is but if it is between burdening the vendors of contact lenses or protecting the public, I vote for the latter. The second is less critical because it is rarely a practical problem for vendors or patients or doctors but it does come up from time to time. It is in regards to contact lenses other than produced-by-the-thousands-soft lenses. These "gas permeable" lenses are custom made and are not quite duplicable. Many of the new scleral designs are proprietary and aren't duplicable at all. Some of these lenses are computer generated based on topography with the prescription in 1's and 0's. Again, I don't know what the answer is. If I were in your shoes I'd probably ignore it if nobody complains, but including specialty lenses in the rule is not being followed because it can't be followed. Best regards, Charles McBride, OD Beaverton, OR