16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Section 2.a.2.prescriber verification. With electronic means readily available, the consumer should be tasked with providing a valid Rx to the seller, not the prescriber. Section 4.d.3. If verification MUST come from a prescriber, 8 hours is insufficient due to office hours. Sixteen is required. Per my experience, passive verification has allowed for several consumers to fraudulently list any random prescriber on the websites and receive their contacts without a prescription. Due to inefficiency and fraud, I recommend passive verification be eliminated altogether. Mandatory active submission of the CL Rx should be the responsibility of the consumer. It is not a hardship for a consumer to retain their CLRx copy and fax it, or take a digital photo by phone and text message to the seller.