16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00246

Submission Number:
00246
Commenter:
Kimberly Boyer
State:
Pennsylvania
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Currently, CL suppliers are not required to actively verify (i.e. obtain an actual Rx), they need only passively verify, meaning that if a fax is sent on a weekend or during an absence of office hours, the supplier "assumes" the Rx is valid. In the event that our office is closed or we are unable to submit our communication within 48 hours, an expired or incorrect prescription may be filled. Many, many patients have admitted to filling their CL Rx online for multiple years, and only returning for follow-up care when they felt it was necessary, meanwhile, poorly fitted contact lenses can result in ocular harm and/or poor visual acuity. I have personally witnessed patients who were not seeing well due to a needed change in power, and many more patients who have developed corneal irritation and inflammation due to lenses which no longer met their ocular health needs. Requiring proof of annual examination and a "hard copy" of the contact lens Rx would eliminate these issues. Contact lens prescriptions should be treated just like medication prescriptions, as they truly are a "medical device", capable of causing permanent harm if used incorrectly.