FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
I strongly oppose the proposed change to the Contact Lens Rule. Specifically, the requirement to create new paperwork in the form of an acknowledgement of release of contact lens prescriptions and to keep that document for three years - beyond the expiration of the prescription itself - is specious, unnecessary and jeopardizes the doctor/patient relationship. This is an expensive burden on doctors, small businesses and patients. This proposed change does nothing constructive to protect patient safety, as evidenced by the extremely small number of complaints made - less than 0.001%! The time and effort of the FTC would be much better spent on enforcement of the laws already in place to protect patient safety, namely the Fairness to Contact Lens Act and the Contact Lens Rule. The rampant violation of these laws, by unscrupulous online and big-box retailers, is the bigger source of jeopardy to patients. Priorities of the FTC will be better served by acknowledging that doctors are sworn to "Do No Harm" (Hippocratic Oath) whereas a retail store has no such concern for the patient. Please reconsider this action. Please allow the doctors to spend more time caring and treating our patients instead of spending unnecessary time to comply with additional paperwork.