16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00630

Submission Number:
Joanne Gronquist
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I find it interesting that the 2003 Contact Lens Law was named "The Fairness to Contact Lens Consumers Act. The reason I find it interesting is because, in my understanding, laws are to be created for the protection of our citizens, not so that life can be "fair". Unfortunately, contact lenses, which are medical devices, have been treated as a commodity. Because of this, contact lens patients have become "consumers" instead of patients and we have found it necessary to come up with a law entitled "The Fairness to Contact Lens Consumers Act". I am an optometrist who has been in practice for over 18 years. I am thinking all day long of the protection of my patients' vision and eye health. However, in my experience, this law undermines my patients', as well as countless others', potential well being. If we are truly thinking about what is best for the protection of our citizens, the law should be renamed to reflect what our law makers' goals should be: to protect the citizens while utilizing educated judgment. The name should be something along the lines of "Protection for Contact Lens Patients Act". It is a misconception that contact lens patients are treated unfairly by requiring an expiration date for their prescriptions. I suspect that is the reason for the original name. It is a misconception that doctors hold patients' prescription "hostage" so that the patient cannot buy their contacts elsewhere. Just like all other medical devices and medications, contact lenses are held to the same standard and require a valid, unexpired prescription in order to protect public health. Through years of medical training and practice, we as their eye doctors should be trusted to do what is best for the health of our patients. Improper wear of contact lenses can cause irreversible vision loss. Annual eye exams, which evaluate the contact lens patient's eye health in relation to the contact lenses as well as the overall health of the eyes, are essential to protecting the health and vision of the patient. I personally have had countless patients who have been able to fill their contact lens prescriptions online for years without an exam, only to come in for the first time as an emergency patient with a red and painful eye due to improper contact lens wear. These instances could have been avoided with regular examinations and review of proper wear and care for their contacts. I have also had countless existing patients who come in for their contact lens exams, saying they got their contacts online, but with no verification on file. Obviously, the passive verification system fails to protect our patients. Sadly, because of the online retailers practices, many contact lens patients don't understand to potential dangers they could experience by skipping their annual exams. They feel as if they are safe if they see well and their contacts are comfortable. This is a fallacy. I can't tell you how many patients I have seen with dirty contacts who say they feel comfortable and they have no problems. I have had numerous completely asymptomatic contact lens patients come in for an exam who were on the verge of a raging eye infection. In some instances, the only way to discover an eye problem is through a comprehensive eye exam. Please protect our patients by changing the intent of this law. Please think of the safety of our patients' most precious sense, which is the sense of sight.