16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00265

Submission Number:
00265
Commenter:
Jennifer Alverson
State:
Alabama
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Contact lenses are a medical device not a commodity. This distinction has been lost due to the commercialization of the contact lens by large retailers and online distribution. Optometrists, such as myself endeavor to protect the eye health and vision of their patients. We hold ourselves to the standard of care of our profession and the laws of our states. Large contact lens retailers have no such standards or even laws to fear. Contact lens orders are completed by these retailers without verification of an active prescription, oftentimes for many years after the prescription has expired. After all, who is there to police them? How have these large contact lens retailers been allowed to do business as if filling the perceived need of the consumer takes priority over their eye health? To their Optometrist, that consumer is a patient in need of eye care. Honestly, the patient doesn't know what they don't know about their eye health. In my state of Alabama the contact lens prescription expires in one year. An eye examination that includes evaluation of the ocular surface and the fit and function of the contact lens is required to renew the prescription. It is our job to advise the patient of any adverse effects of continued contact lens wear. Contact lens retailers are allowed to circumvent this system allowing patients to skip regular eye examinations. Many patients mistake good vision for good eye health so without regular eye examinations, not only do contact lens complications go undetected but silent diseases such as glaucoma, diabetic and hypertensive retinopathy or corneal dystrophy can also go undetected until it's too late. When prescribed and used properly contact lenses can improve vision and safely provide freedom from wearing eyeglasses. When abused, contact lenses can cause a myriad of eye health issues: some as simple as irritation, some as sight threatening as penetrating corneal ulcers. Contact lenses are correctly classified as Medical Devices and should be regulated as such. All entities that sell contact lenses should adhere to strict regulations for the distribution of these Medical Devices and this should include refusing to fill the order without verification of an active prescription.