16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00483

Submission Number:
00483
Commenter:
Daldine
State:
Pennsylvania
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
As a newly practicing optometrist in the past few years it is pretty incredible what the Internet, when it relates to medical devices, is allowed to let patients access. Some are for lifesaving, some are for consueling, and some are for profit at the risk of a individual. In my opinion and many other professionals opinions contacts need to be regulated just as strongly as other medications. We are a society of backing up what we say and proving things right or wrong with scientific studies, and this is no exception. It is proven time and time again that these online contact lens companies are indirectly allowing patients to overwear and make it easy to cause harm to their bodies. Most practices would not have a problem with the online ordering system as many of us participate in online orderi of goods or prescription delivery systems, but the sneakiness of how the online companies "try" to verify a patients Rx is a joke. Moving into another topic I applaud Johnson and Johnsons decision to enact UPP for contact lens procing. I have absolutely no revenue coming from contact lenses since I am employees by a chain, but this has ensured patients get the best price they can and an added benefit is that if there is a problem with the lensed the are taken care of by an actual person who has experience in eye are, not an online chat room. The fact that a patient needs to buy what the practiced prescribes should stay. Around 50% of optometrist are employed by a organization that has not control over what the dr prescribes so those said Drs prescribe solely based on what is healthy for the patient since they have absolutely no financial gain from the type of contact lens brand. All private practice owners may make a greater profit on certain contact brands, however the fact that they want to see their patients as repeat patients it is in the optometrist best interest to keep the patients eyes healthy and comfortable. Finally, some professionals support and enact a 1 year contact lens expiration. In my opinion, and many scientific papers this is a smart and needed law to protect patients from harms they may not realize no matter how much education we may try and give them on the importance of proper contact lens wear to keep the eye healthy.