16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #03743

Submission Number:
03743
Commenter:
Amy Farrall
State:
Delaware
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Allowing this rule to be passed would be detrimental to patients' health and safety! This should take precedence over consumer convenience. Contact lenses are FDA -regulated MEDICAL devices, which require a valid prescription from a patient's doctor, and everyday in my practice now, some internet-based sellers imply tactics that sidestep federal laws that are in place to keep my patient's safe. I can't imagine what would happen if you allow this rule to pass, I have already witnessed patients receiving wrong powered contacts, wrong brands, incorrect curvatures, 4-5 years worth of refills when we distinctly reply back the prescription is expired. I have treated countless contact lens over wear patient's,those who have extended their contacts. This is because the online contact lens sellers, like 1-800Contacts' would pre-check authorization boxes used to deceptively assert the right to act as the patient's agent and failed to effectively communicate the need for physician oversight when using contact lenses. They fax the patient's expired contact prescription , we return it saying it's expired, then they say they sent contacts to the patient because they had left a message 2 hours ago; but there was absolutely NO call made to our office. They also fax/call after hours and on weekends, when they know we aren't available. I believe patient's should have access to accurate/updated information, and I always provide a contact lens prescription for my patient's. As Optometrist', there are already state rules which regulate that we provide our patient's with a contact lens prescription. As Medical Devices, infections and even blindness can, have and will occur. If you allow this rule to pass, the numbers of consumers affected by contact lens related infections, and blindness will rise. I appreciate your careful consideration in this very important matter! Sincerely, Dr. Amy M. Farrall [redacted].