16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00654

Submission Number:
00654
Commenter:
Song
State:
Virginia
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Contact lenses are considered medical devices and should not be considered a retail product. Almost every request for contact lens Rx come after office hours or during the weekend, where doctors do not have the proper amount of time to address them. I think online vendors do this on purpose to go around the current law. There have been many times a patient's EXPIRED contact lens request has been filled by an online vendor in order to get the sale, even though the request was repeatedly denied by our office. There have also been numerous times online vendors would request to substitute the contact lens brand for something else. Online vendors are NOT doctors, they do NOT have the license to give contact lens Rx's, therefore such requests should NOT be solicited by them. NOT all lenses are the same. It should also be illegal for online vendors to fish for patient information or contact lens Rx's WITHOUT patient consent, which 1800contacts repeatedly does. Contact lenses wearers need to have yearly eye exams in order for us to make sure their ocular health is good enough for contact lens wear. Because of these online vendors focusing on sales instead of ocular health, we put our public at risk to infections and eye diseases. Online vendors should only be allowed to fill Rx's if the patient provides proof of a recent eye exam (within a year).