16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00554

Submission Number:
Dawn Bearden
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
The number ONE reason that patients present to my office with red, irritated and often painful eyes is from improper contact lens wear. Often these issues are from improper care of the lens, improper wear schedule, not discarding the lens at the appropriate time, ill fitting contact lenses, allergic reactions to lens care solutions, allergy to the lens material itself etc. Many of these issues could be vision threatening. Contact lens patients MUST be seen yearly so the Doctor can look at the lens on the eye and determine if there are any problems brewing that the patient is not yet aware of. Often by the time the patient presents to the Doctors office with a red, painful, teary eye - it is too late. Often this can be a corneal ulcer- which can cause permanent scarring on the front of the eye (the cornea). If this scar is in the way of the patients central vision- then clear vision will never be possible again due to the scar on the cornea. To allow these medical devices to go unchecked by an eye Doctor for 5 years is dangerous and will most likely result in a surge of patients with eye emergencies, corneal ulcers and permenant vision loss. Contact lens prescriptions should include EXACT lens type along with base curve and power. They should also expire every year. All contact lenses are not the same - even if they have the SAME base curve and prescription power. I can give a patient 3 different lenses with the same base curve and power and the patient will probably immediately notice a comfort difference in each lens and maybe even a vision difference. Different lenses are made from different materials and all act differently once on a patients eyes. An eye Doctor may choose a specific lens for more clarity of vision, better comfort, better fit or better eye health. It is ludicrous to assume that all that is needed is a base curve and prescription power and have some non licensed entity sell a patient ANY lens with only those 2 measurements. The specific lens type is ESSENTIAL to the proper fit of the lens - not just base curve and power. I worked alongside a commercial entity for almost 15 years. They sold the glasses and the contact lenses. I only performed the eye exams. I made no financial gain whatsoever from contact lens sales. In this situation I would insist on a particular brand, size, base curve and power be filled. No other lens could be substituted. This was not so I could gain financially by the sale of any contacts but, more importantly that the lens that I fit onto that patients eyes- the one that I checked for proper fit, good ocular health and clear vision - would be what was dispensed. This had nothing to do with financial gain on my end but, on what was best for my patients eye health and visual clarity. Many eye health issues like glaucoma and eye cancer do not have any symptoms. Therefore patients often do not know they have these underlying issues until it's too late. It's important for people to have routine annual eye care to detect these issues as well as systemic issues like diabetes, high blood pressure, high cholesterol, ms, brain tumors etc. Many times the ONLY reason a patient goes to the eye doctor is to get new glasses. Many want to just skip the exam and just get a new pair of glasses with their same old prescription. Many times the pair of glasses that they are wearing is no longer delivering clear vision but the change is so slow they think their vision is "fine". Many times these people with "fine" vision are no longer legal to drive with this old prescription yet, they are unaware. By having glasses prescriptions expire in 1-2 years allows the Doctor to not only update their vision but also to Check their eyes for underlying ocular or systemic problems that could be vision threatening or life threatening. An eye exam is much more than just "a glasses prescription" even though this is the perception of most people. Thank you Dr Dawn Bearden