FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #3114

Submission Number:
Alan Wegener
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
There is no justification for targeting eye doctors-optometrists and ophthalmologists-and our patients with new paperwork and document storage requirements as your misguided Contact Lens Rule proposal would do, while the Commission allows retailers who blatantly violate the law to operate unchecked. Retailers' claims that doctors do not comply with the current rules have been clearly rebuked by your own internal data, which Members of Congress have specifically recognized in Congressional hearings with FTC officials and further affirmed on March 23rd through passage of 2018 government funding legislation (Public Law 115- 141) and the following report directive: "Contact Lenses-The [Senate Appropriations] Committee is disappointed in the FTC's decision not to include the proposed patient safety improvements related to the prescription verification process in its draft contact lens rule and instead impose new paperwork requirements on patients and doctors that are unnecessarily burdensome. The Committee directs the FTC to prioritize patient safety and consider enforcement mechanisms under its existing authority or revisions to the draft rule that address sales of excessive quantities of lenses, illegal substitutions, and communication challenges associated with prescription verification, including robo-calls. The Committee further directs the FTC to continue to confer and consult with other Federal agencies, including the Food and Drug Administration, to optimize its enforcement and consumer education activities." I urge you to reinforce to the public and to these predatory and deceptive businesses that the FTC will not sacrifice public safety and standards of medical practice for any reason. I urge you to ignore testimony of so-called 'experts' that these retailers have brought to you. Having a glaucoma specialist comment on contact lenses is as nonsensical as asking a podiatrist to perform open heart surgery. I hope our argument against these rules is clear and you will make the correct decision in this case of commerce vs public safety. Retailers have done an admittedly excellent job of making themselves seem the victim when in reality the victims are every eye care provider and their patients.