16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I have a few notes that should be considered as this act goes under review 1.No contact lens rx should be filled past the date of expiration. I know patients who wait until the day before the prescription expires and fill another years worth of contacts to avoid going back to the doctors office to have it renewed. This can lead to many harmful things such as a) unsafe drivers from wrong correction of contacts (if an online retailer sold these contacts with knowing the expiration date anyways they should be held liable) b)over wear "stretching" out lens supply beyond the FDA recommended guidelines which can lead to infection, neovascularization of the cornea, and keratitis that all need medical care and attention and puts stress on the medical system. If patients are required to have regular follow ups and we as doctors can educate them on proper wear and care of contact lens this should save our already burdened medical system cost in the long run. *Just those patients with annual medical care are less likely to go to the ER for emergencies* 2) Not all contact lenses fit the same and feel the same. There should be no substitution of rx. Contact lens production is a complex process and some are more oxygen permeable than others. Patients that wear contacts for 10+ hours per day should be in certain brands that allows for good health of the cornea and should not be duped into switching brands for lower cost by an online retailer. Also dry eye patients need different materials and coatings on their lenses to keep them moist and comfortable throughout the day. 3)Please reconsider the verification process for contacts lens prescriptions filled online. It should be the consumers responsibility to provide to the seller a full, unexpired contact lens prescription and the doctor prescribing should not have to be involved in this process. It puts undue stress on small local businesses to have to respond to faxes. Thank you for your dedication to this matter.