FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule #3327

Submission Number:
3327
Commenter:
Edward Montwill
Organization:
State:
Illinois
Initiative Name:
FTC 16 CFR Part 315 Public Workshop Examining Contact Lens Marketplace And Analyzing Proposed Changes To The Contact Lens Rule
This is a response in opposition to the proposed changes to The contact lens rule changes considered by the FTC. As an Optometrist in private practice for 28 years I have seen many changes in the technology, manufacture and distribution of contact lenses. Some have been to improve modality and range in fitting for refractive error,and some to improve health of the wearers eyes. Unfortunately although some impact has been made over these years, still none have improved the fact that patients abuse how they wear, and care for there contact lenses. Your proposed changes only make it easier for patients to further this abuse and cause, at times, irreversible damage to their ocular health by making it easier for non-involved and liability free contact lens distributors to solely make more profits. These distributors are not involved in the proper fitting, training, and resolution of contact lens problem management. They are not involved in treatment and education of a patient who has abused there contact lens wear and NOW relies on the eye care provider to reverse the damage caused by their own abuse. The distributors accept none of the liability when a patient abuses the prescription parameters and more importantly expiration dates. I have a patient whose on line distributor is consistently trying to refill a prescription that has been expired and the patient has not seen an eye care professional for TEN years! FTC needs to concentrate and put more pressure on the distributors to comply with current laws and make them assume more legal liability when they allow patients to abuse their prescription for a medical device. This is not a pair of shoes! These are medical devices that correct vision problems, and can cause serious issues when they are abused, mishandled, and can be obtained with less and less regulations on their distribution.