16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #03889

Submission Number:
03889
Commenter:
Nathan Orr
State:
California
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
Dear Chairwoman Ramirez, I am a practicing doctor of optometry who cares for several thousand contact lens wearing patients each year. I am writing to voice my strong opposition to the proposed rule change which requires a signed acknowledgement of receipt at the end of the contact lens fitting process. I would like to emphasize that I practice and comply with the existing regulations, and that this legislation misses the mark in whom it is targeting. I see contact lens wearing patients several times a week who freely admit they have not had an eye examination in several years, sometimes into double digits. They have had no problem getting contact lenses with no prescription whatsoever through online retailers. I am confused and surprised by the seeming presumption by the FTC that the prescribing optometrists and ophthalmologists are refusing to provide their patients with a contact lens prescription as directed. I think that any reasonable assessment of the volume of business being done by online contact lens retailers and big box stores shows that there is a massive marketplace available to contact lens wearers that they actively using. To interpret the current state of todays contact lens market and come away with the conclusion that the prescribing doctors are the ones not playing by the rules seems unbelievable to me. I would like to emphasize that I practice with the highest levels of ethics and I follow the existing rules. This new requirement will be time consuming, costly, and will have minimal benefit to the consumer. I urge you to not implement this burdensome proposal. Thank you, Nathan Orr, O.D.