16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
I have been an Optometrist for 32 years including 4 years as a Captain in the US Army and while contact lens materials are safer to use than ever, however the patients using these lenses still require monitoring for changes in corneal health and compliance. Every week I see patients who over wear their lenses, fail to clean their lenses properly, or come in with acute redness or pain from improper lens use. Changes to the Contact Lens Fairness Act are not necessary; enforcing the current regulations would benefit the public. Contact lens prescriptions are already given to our patients once their ocular health, visual needs and safety are assured. Additional regulations requiring patients to sign a statement and maintain this in their records are superfluous, since current regulations already require the provider to give the prescription to the patent once the fitting is completed. Unfortunately those prescriptions are used to reorder contact from suppliers who do not comply with current rules and regulations. We receive requests for prescriptions from suppliers for patients who have not been seen in our office for 3 or more years and, in some cases, for patients that have never been to our office. If we don't respond to these requests due to incompatible office hours with the requestor or an office closure due to a Federal Holiday, the contacts are shipped to the patient without any thought to the patients' ocular health and compliance. Thank you for your concern in this important matter of patient safety. Sincerely, Michael Robin, O.D.