16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #03950

Submission Number:
03950
Commenter:
Don Blackburn
State:
Delaware
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
The FTC needs to make sure that they are upholding the law against the internet contact lens companies as well. These companies are notorious for faxing/ leaving voice messages at the end of the business day or on Friday evenings, making it impossible to verify the information in a timely manner. They tend to allow patients to fill their prescriptions beyond the expiration date or allow a patient to order a year's supply just before the prescription expires. The new proposed law will require us to have patients sign an acknowledgement that they received a copy of their Rx and that they understand that they can purchase lenses from the seller of their choice. We would not only have to have patients sign what should already be a self-evident acknowledgement, but also maintain a copy for three years, which is going to burden our staff at the end of an examination, causing delay in patient care on the next patient waiting for the doctor. In other words, it is going to impose a burden on our staff and practice sytems in order to accommodate this busy form work. The FTC must weigh consumer interests against patient safety. Ultimately, the question will be: Is it really moral in light of slight consumer benefit, for the unwanted outcome of a rare but devastating loss of an individual's sight? In the end, we the eye care practitioners, will be left to deal with the misery of the patient who suffers a large, visually debilitating corneal ulcer. Requiring the eye care provider to inform the patient of their right to buy their contacts from anyone and releasing their prescription, is already enforced by FDA regulations. The FTC must be aware of the internet contact lens company's tactics to be lax in their verification in a thorough and comprehensive manner. We, the eye care practitioners, are held to fact that we must provide a thorough and comprehensive examination to update a contact lens prescription. The internet companies ought to be held to a similar standard in providing proof to the consumer that they properly and comprehensively verified their contact lens prescription prior to the order.