16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
As a practicing ophthalmologist, I am deeply concerned about proposals included in the Federal Trade Commission's proposed amendments to the Contact Lens Rule. While I would welcome changes to the Contact Lens Rule that prioritize patient safety, these proposals would create significant burdens on my practice and do nothing to address the fact that some sellers of contact lenses have engaged in business practices that jeopardize the safety of my patients. Such a burden should not be placed on small businesses that are already going to great lengths to comply with the Contact Lens Rule and do so despite serious concerns with the current prescription-verification system that we believe puts our patients at risk. Since 2004, the Contact Lens Rule has focused on making the sale of contact lenses as easy as possible. However, contact lenses are medical devices; this solitary focus puts patient safety at risk and places an unfair burden on small businesses, like my practice. I strongly urge the FTC to withdraw this proposal and re-approach the Contact Lens Rule with patient safety as its number one priority.