16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00529

Submission Number:
Joseph Santry
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I am a practicing Doctor of Optometry who examines patients and fits contact lenses. The public needs to be aware that the prescribing of contact lenses is a very important process, because an improperly fitted contact lens has the potential to devastate the eye by infection and scarring of the cornea, the clear front surface of the eye. Bacteria coat the eye, both friendly and not-so-friendly varieties. They live in balance, and the eye is healthy. When a foreign body is introduced onto the ocular surface, it interrupts this balance by reducing the oxygen available to the bacteria, and favors the growth of the not-so-friendly varieties. The doctor who prescribes contact lenses must assess the risk to the patient posed by the particular lens s/he has chosen. An incorrectly fitted contact lens breaks down the barrier that exists to keep these bacteria away from vulnerable tissue in the cornea. Contact lenses should not be seen as a casual accessory, like a pair of earrings or cufflinks, but rather as the medical devices they are. The fact that purchasers of contact lenses are referred to as "consumers" rather than "patients" puts the contact lens on the same plane as dishwashers and detergents. This should not be. There should be no interference by any entity between what a doctor has prescribed and what a patient receives when contact lenses are involved. A patient is certainly entitled to obtain his/her lenses at any place of his/her choosing, but there should be no tolerance for substitution by the contact lens provider. The contact lens provider should be denied the ability to sell more than one year's supply of lenses to any patient because to do so encourages the patient to avoid necessary yearly ocular health evaluations. The contact lens provider should not be allowed "passive verification" of a contact lens prescription if the fax prescription form is not returned by the prescriber within eight hours. Virtually every practice has received faxes sent when the office is closed for the weekend. Finally, hold the contact lens provider to the same rigorous standards as any medical professional is held, since they are purveying medical devices. Make them liable to malpractice penalties if they substitute a contact lens for the one prescribed. Thank you for your consideration.