16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00629

Submission Number:
00629
Commenter:
Ashley Wong
State:
Maryland
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
As an eye care provider we are at a disadvantage when competing with online vendors. There are so many rules/guidelines for us, but lax rules for online vendors. I had many encounters where online vendors sell contact lens with an expired Rx and loosely tell patients to have their eyes exam within the next months. The patients end up not scheduling an appointment until the next time they want to order lenses. Contact lenses are medical devices and have risks associated with it, the worse being blindness resulting from an eye infection. In addition, the pupillary distance (distance between a patient's eyes) is not a measurement required for us to provide a thorough comprehensive eye exam. Instead this is a measurement opticians need when making the glasses. When these measurements are incorrect it can offset the glasses and therefore I feel eye care providers do not need to provide this measurement to patients. The reason being if the glasses are made incorrectly why should we be held accountable if we did not sell the product.