16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Thank you for considering my comments. 1) Contact Lenses are medical devices that have to be fit to the shape of the human eye. Every eye is different, just like snowflakes. Every day I see contact lens related eye problems in my practice. Sometimes the lenses are too tight, too loose, too deposited, too dry, or decreasing the oxygen getting to the cornea. Some of the conditions are mild. Some are severe. I have attached pictures of recent cases of contact lens related complications. 2) This new rule proposal does nothing to protect patients. It only adds administrative burdens to our practice. We already have too many administrative burdens. Online contact lens companies know this and take advantage of this. Online contact lens companies commonly send contact lens verification forms late on Fridays or Saturdays with the intent that the doctor can not attend to the verification within the time limit and they can fill the contact lens prescription without the doctor. 3) The rule changes should focus on unscrupulous marketing and business tactics that put patients' eye health at risk. 4) Optometrists follow--and will continue to follow-- the rules regarding the dispensing of contact lenses. Here is what happens when patient's get duped by the online retailers. 1 in 4 reported receiving a different contact lens brand than had been prescribed. 1 in 3 reported an online retailer advised them to substitute a non-prescribed lens due to supply issues. 1 in 3 reported that they purchased contact lens with an expired prescription. The proposed changes do nothing to solve these issues. These issues are what threaten the public's eye health, not doctors telling patients where they can purchase contact lenses. Thank you.