16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I have concerns with refill requests that are received by my office shortly before the "One Year Expiration Date." We, as Eye Care Providers, are required to sumbit an Expiration Date of 1 year. However, we prescribe a number of boxes that is commensurate with the patient's wearing schedule, ie One-month use of lenses would require 12 lenses per eye (2 boxes per eye). Many times we receive requests for another complete year's supply of lenses just days prior to the expiration date. This expiration should not imply an unlimited supply of lenses. Contact Lenses do have the potential to cause serious harm if not properly monitored. Many issues are not realized by the patient in the early stages. Yearly examination of the patient's eye health and Contact Lens fit are essential for successful Contact Lens wear. It should be noted that a comfortable Contact Lens does not always mean a well-fitting healthy lens, or healthy eye or that matter. I also believe that the rule requiring our response to the seller within 8 Business Hours is too narrow of a window. If our office happens to close on a given day, all Contact Lens requests that arrive, whether Valid, Invalid or Expired, are going to be filled by the seller regardless. We prescribers should be allowed at least 2 Business Days for response. Thank you for your consideration.