FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #3190

Submission Number:
Kevin Huff
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
I would like to offer my opinion about these proposed changes. I work in an ophthalmology office. I practice with 3 ophthalmologists, one of which is a cornea specialist. Our business model does not rely on contact lens sales to increase profits. I do not personally benefit from sales of contact lenses and I do not care where patients purchase them. However, I do care very strongly about which material the patient is using, how often the lenses are disposed of, and how often they need to see me to renew an RX. In our office, I often am asked to consult on cases in which patients have had adverse events due to improper contact lens use. In the last six months, I can tell you I have worked with many patients who have permanently lost vision from over wearing or sleeping in contact lenses. The truth is every one of these patients had a prescription for the lenses they were wearing. I believe their adverse events were due to their own negligence in following the rules they were told by their prescribing doctor. Some may read what I just said and conclude that this is evidence that the act of having to go see the doctor for a yearly RX is not necessary because even under this system these things happen. They would be wrong! I have this conversation with patients daily. As effective as think we are as communicators, patients often hear what they want to hear. I have had patients that I know I have told not to sleep in their lenses tell me no one had ever told them not to. By getting a chance to reinforce these rules each year at the annual exam, we are often able to catch these patients who have fallen into bad habits before they have an adverse event. I have heard it said that about 80% of all contact lens evaluations result in no change to the RX (I personally believe that number is high). Some would say that shows that a yearly exam is not necessary. However, this statistic shows that 1 in 5 people need to be updated to see more clearly. I would ask you to look at the cars around you on your way home tonight and ask yourself if you would feel safe knowing that every fifth car may be driven by someone who is not seeing with their correct prescription? Also, the 4 out of 5 people that are receiving the same RX are getting face to face with a doctor who is getting a chance to reinforce safe contact lens use practices. Every chance we get helps prevent further cases like what we deal with here in our office with our corneal specialist. If patients are able to renew RX's without having to see their doctor yearly, I am afraid that our cornea practice is going to have to expand dramatically. When you are considering your position on this matter, please consider your decision could lead to protecting patients from losing their vision permanently. I wish every person who has the authority to make these decisions could have the experience of having to sit across from a perfectly healthy 30 year old and tell them they will never see out of one of their eyes again knowing that it could have been completely preventable. There is no way you could go through that experience and consider what these changes are considering knowing that this will lead to more people going through these completely preventable tragedies.