16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00499

Submission Number:
00499
Commenter:
David Lupinski
State:
North Carolina
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Studies over the years have shown that wearing contact lenses increases the risk for ocular health complications. Furthermore, the wear schedule that an individual chooses can further increase that risk. When prescribing a certain brand of contact lenses, the eye care practitioner takes into account many factors, including an individual's refractive error, the health of their ocular surface, the individual's wearing and lens care habits, and satisfaction with contact lens comfort and vision. To allow a filler of a contact lens prescription the latitude to substitute a lens for the one prescribed undermines the professionalism and expertise of the prescriber. The motivation of the filler would likely be driven exclusively based on profit, while the motivation of the prescriber is in the best interest of the ocular health and well being of the patient. For a large majority of the population, contact lens prescriptions should carry a 1-year expiration date. At stated from the outset of this comment, studies over the years have shown that wearing contact lenses increases the risk for ocular health complications. Requiring a contact lens wearer to have his/her ocular health evaluated once per year is an important aspect of ensuring there are no serious threats to the delicate ocular structures that are immensely important to providing our most precious sense - vision. It has been cited over and over again that 80% of our perception of the world is attributed to vision. Why would we want to risk threatening our most vital sense by allowing people the freedom to go years between check-ups - and for what - to allow retailers the ability to sell more contact lenses and make more profits? The best interest of the patient is to be evaluated at regular intervals to ensure good ocular health. Finally, if the FCLCA is to continue in its current form, with retailers not involved in the prescribing of the contact lens filling contact lens prescriptions, then the verification step of the filling process must continue. This is the only way to have a check and balance to make sure that retailers are checking with the prescribing doctor to make sure that the contact lens Rx is still valid (and the patient's ocular health is still vouched for), and it is the only way that contact lens prescribers can be sure that their patients are wearing the lenses that were intended for the individual's optimum ocular health.