16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00525

Submission Number:
Christina Petrou Haefs
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
To whom it may concern: Contact lenses, as medical devices and written by prescription from a licensed practitioner, should be treated as any other pharmaceutical or medical device: fill only as written, no substitutions, original Rx cannot be transferred to another pharmacy and refilled in it's entirety. I am hearing daily about how clever patients can work the system and fill their CL Rx for 2 years or more by transferring their contact lens numbers from vendor to vendor. This is unprecedented in medicine and must stop. Imagine someone doing that with their high blood pressure or their diabetes medication. Ocular health from contact lens overwear is a serious danger. For one, the stem cells at the limbus when damaged. prevent corneal healing, and can lead to blindness, ulceration, and scar tissue. Another serious concern is the risk of eye infection from old. over worn lenses, improper wear (shower, pool, overnight, or when sick, to name a few). Annual eye exams are designed to catch and correct these habits which could lead to eye damage or loss of vision. What's needed are the following: 1. Limiting a contact lens prescription to number of refills at the doctors discretion. For example, if Sue has dry eyes and mild corneal compromise from past contact lens wear, her doctor may be able to allow her to continue part time contact lens wear for sports or social events, and may limit her contact lens Rx to a small supply to prevent eye damage from over wear. A follow up appointment may be needed to monitor her corneal status then approve additional contact lenses for her to purchase. 2. Once a contact lens prescription has been filled, no other vendor may re-use that prescription to refill the CL Rx in it's entirety. For example, Joe buys half of his year's supply from his eye doctor, then 6 months later requests a copy of his CL Rx and fills an entire year supply at 1-800 contacts, giving him a 1.5 year supply without an exam to verify at the one year mark that his eyes are healthy enough to continue wearing those contacts. Often the case is that a patient may need a lens that fits the eye better, or a new lens is available which would allow better long term eye health for the patient. Thank you for the opportunity to contribute knowledge of concerns. Sincerely, Christina Petrou Haefs, OD