FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #2980

Submission Number:
2980
Commenter:
Martin Lindower
Organization:
State:
Connecticut
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
As a practicing optometrist in Connecticut, I find this proposed contact lens prescription paperwork requirement a gross waste of time, paper and money, and one which gives no benefit to the doctor or patient. After the completion of a contact lens fitting, I am already required to give my patient a copy of their contact lens prescription ("CL Rx")so they can purchase a supply of lenses wherever they want. This proposal would make me "certify" that I have done so. It makes the assumption that if I didn't certify, I probably would not give my patient a copy of their CL Rx. It assumes that I'm not following Federal law (which I am), and puts me in an automatically adversarial situation with my patients. It will do nothing to improve compliance, and will just waste my time and my patients time, waste reams of paper for no reason, all for no good reason. The public would be better served by stronger enforcement of contact lens verification rules, to ensure that online vendors adhere to lens branding and expiration requirements written on our prescriptions to ensure our patients eye health. I strongly oppose this proposed rule.