In a few weeks, the FTC will be meeting to decide the fate of the contact lens industry, and perhaps inadvertently, the health and well-being of every contact lens wearer in the US.  Focused on consumer rights at the expense of public safety, the FTC will be considering the needless and resource-consuming new contact lens documentation requirements.  It is also expected to propose generic lens substitution regulation.  In this process the FTC will have ignored the complexity of contact lens materials, the differences between contact lens designs, and most importantly, the sometimes devastating reality that contact lenses are medical devices that, when misused or improperly fitted, can cause life threatening harm to wearers.

As a result of innovation by major manufacturers, contact lenses are far better but more distinct from each other than ever before.  A generic one-size-fits-all approach is a sellout for patient safety that disincentivize further innovation and potentially harm contact lens consumers.  There is no excuse for the FTC to put the public at even greater risk by kowtowing to entities that put profits ahead of patients.

The FTC has also misjudged eyecare practitioners who are almost universally patient-focused and compliant. The contact lens sellers who couldn’t care less about their customers and routinely game the FTC’s passive verification rules to circumvent patient protections.

We eyecare practitioners hope that the FTC will carefully consider the real-world impact of what it proposes.