FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #2888

Submission Number:
2888
Commenter:
Matthew Ritter
Organization:
State:
Ohio
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
Dear FTC Commisssioners: I am an optometrist serving the vision and eycare needs of several thousand patients in Southwest Ohio. I am commenting in regards to the proposal that targets our country's eyecare professionals, both Optometrists and Ophthalmologists alike by putting undue and unnecessary documentation requirements on contact lens prescriptions. At the same time, it is allowing open lawbreakers such as many online contact lens retailers to operate unchecked. Contact lenses are a medical device that certainly have the capability to cause undue pain and suffering if misused, and while the regulation proposals might intend to benefit our patients' eye health, in reality what it will really do is allow them to cause unknowing harm to their vision. This is due solely to the fact that our patients need our guidance to find a prescription product that best suits their own natural biology and visual needs. In my sixteen years of practice on the front lines, I have seen many times, first hand, the painful and vision-threatening consequences of patients being able to purchase their own contact lenses WITHOUT A VALID PRESCRIPTION ONLINE despite its illegal but somehow prevalent nature. In addition to the safety ramifications, these proposed changes to contact lens regulations will have the second undesired effect of increased contact lens related costs passed on to all consumers of the products. When new regulations, fees, costs, etc are passed on to the providers, we will have no choice but to raise our costs on all SERVICES, if not GOODS and SERVICES both, associated with these products. There are many voices purportedly paying consultants to voice unfounded claims and "fake news" about why you should continue with the proposed rule. I urge you to listen to the nation's eye doctors and other public health experts in recognizing contact lenses as a medical device and by joining with the Food and Drug Administration (FDA) and the Centers for Disease Control (CDC) in making quality care and patient health and safety a priority in Washington, DC. Sincerely Matthew Ritter OD