16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00570

Submission Number:
Deanna Born
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I would like to comment on a few things I have noticed at my practice. Many patients return for an exam many years after being prescribed contact lenses. They continue to purchase their lenses through online companies who are not verifying that the contact lens Rx is valid and not expired. Many of these patients have corneas with neovascularization, edema, scarring, and ulcers and are only returning because they have a severe eye infection. Occasionally, these patients have irreversible corneal damage that affects their eyesight permanently. Every company that sells contacts needs to follow the same law. 1800Contacts purposely faxes the contact lens verification on a Friday night so they can get around the 24-48 hour deadline to verify, which makes our verification unwarranted. Sometimes, we see a request from a patient we have not seen at all but is still purchasing the lenses through 1800contacts. I believe all contact lens prescriptions should expire after one year in order to allow optometrists to look at the ocular health and especially corneal health of each patient. The cornea can change shape over time, and may affect the way the contact lens sits on the corneal surface. An ill-fitting contact may cause corneal abrasions, hypoxia (lack of oxygen), neovascularization (blood vessel growth), and permanent scarring leading to decreased visual acuity. Once corneal scarring has occurred through the central visual axis, a corneal transplant may be warranted. We, as doctors, educate our patients about the wearing schedule and risks of contact lenses, but many patients wear the lenses as they want, regardless of the schedule we recommend. Unfortunately, it is not until the patient has had a severe infection that will prompt the patient to change their wearing modality to a safer more healthy schedule. That is why I recommend patients have a one year corneal health check so that we may prevent these infections from occurring. Every contact lens has its own parameters. Some fit too tight, loose, rotate excessively (for those with astigmatism). The material of each contact is different for a longer or shorter wearing schedule, or for those that must sleep in them (such as firefighters who must wake and go to work immediately). This is why the doctor's recommendation for each individual patient is important.