16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I would like to voice my strong opposition to removing the safety barriers placed on the sale of contact lenses to the public on the basis of patient safety concerns above any other consideration. In my nearly 18 years of practice, I've had to treat (many times simply salvage what quality vision remains) patients who abused their contact lenses simply because they see them as a commodity. When the "businesses" who sell contact lenses do not see the patient, the end user, they start to make decisions that are good for the bottom line and for investors but not the patients who they see as "customers". We, as doctors, have done a poor job of communicating these battles with these businesses simply because there has been no good avenue for having these discussions. Ultimately, the right lens for the patient is NOT as black and white as selling the right brand or curvature (like some type of electronic consumer good), it has to do with the individual patient's tear chemistry, nerve sensations, lid to globe congruity, corneal eccentricity/individuality, years of wear, allergies, movement of the lens NOT based on curvature but based on the surface friction factor of the material, the way the patient treats the lenses, the environment they work in, the water content of the lens, the amount of oxygen that is transmitted through the lens, and many more variables. The business world wants to make it about the prescription and curvature (and maybe diameter) but these are the lowest common bonds between lenses...not the way doctors fit and judge lens match to the patients eyes and ultimate health. I URGE you not to let the businesses influence patient health safety laws in order to impact their bottom line. Please keep Rx verification, brand of lens, need for comprehensive yearly eye exam, and other safety protocols in place. This is about patient safety and not business interest on either side. Thank you for your consideration.