16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00215

Submission Number:
Samuel Ahn
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I recently saw a patient that has been wearing contacts for a long time without issues. He had been using an outdate Rx from a different provider and buying contacts online. He slept in his contacts up to a week for several years without issues. This past Spring, he had a slightly pink eye. He did not bother to get it looked at because he felt it would just improve on its own. A week later it started to worsen to the point he had to go to the emergency room. He was admitted that day and spent the next 3 months in the hospital. They managed to save the eye, but he is completely blind in his right eye. His scar is so bad. His right eye is completely white. He is disfigured to the point people look away from him. He is only in his 30s. I usually get contact lens Rx request from online sellers in the middle of the night and often over the weekend. These sellers know most private offices are closed. We often do not have the time to complete the request on time. Very often, the request is for someone we never seen before. Not being able to respond in time means anyone can buy the contacts. By state law, we are required to have a copy of a "valid" Rx on file. We have one for every patient we sell to, even if we never saw the patient in our office. Patients are always given a Rx when they are seen by us. However, why can't they provide a copy of their Rx to the online sellers? Putting the onus on small business is not only unfair, its dangerous. We can't always respond in 24 to 48 hours for a verification request. If a request is sent after 6pm on Friday, we don't see it until Monday morning. Someone like my patient already had the Rx filled. Online retailers sell the contacts if there is no response from the provider in time. Apparently, they don't need a copy of the Rx while doctor offices do. I saw my patient for the first time after he lost his vision. He was buying contacts without exams for many years. I was not the prescribing doctor. He couldn't even tell me when his last eye exam was before the infection. What is the point of having these laws when it's so easy for patients to buy contacts without a valid Rx. You are not looking out for the consumer, who is ultimately a patient. We sell contacts only if we get a copy of a valid Rx. If a small business with limited resources can obtain an Rx from outsider providers, why do big corporations have the option of just selling contacts without an Rx online. It's unfair, wrong, and dangerous. If you look at the people that buy contacts without a valid rx, I can almost say with certainty they get the contacts online. Discount retailers like Walmart and Costco follow the same rules as private doctors. We get the Rx ourselves. We don't just send a fax in the middle of the night and if no one response say the Rx is valid. Again, the current situation is unfair to brick and mortar businesses and dangerous to the patient. Thanks for your time!