September 5, 2003
The Honourable Anne McLellan, P.C., M.P.
Minister of Health
Ottawa, Ontario, K1A 0K9
Fax number: (613) 943-0044
Re: Non-corrective ("plano") contact lenses
Sold Through Unlicensed Facilities
We wish to thank you for your decision earlier this year to conduct a risk assessment of non-
corrective contact lenses and the potential for health risk when sold through unlicensed facilities.
Most plano lenses are coloured, tinted or patterned. We have been working with the consultant
and with officials in your department to ensure that the best information possible is presented
within the timeframes specified. We are writing at this time to highlight our concerns and our
positions on this important matter to the eye care professions in Canada.
1. A system for collecting injury data in Canada has not been established.
While we recognize the importance of injury data in the context of a risk assessment, we feel it is
important to point out that there is no system in Canada for the collection of specific injury data.
All our associations have initiated a call for information from the professions and some injury data
has been collected in the past few months. However, it is early days for the professions in
collecting this kind of information. Additionally, the professions are already overburdened with
patient demand and reporting responsibilities.
Related to this concern is our understanding that emergency room doctors and hospitals and
other health facilities were not consulted in the course of the investigation. It is a fact that some
eye incidences related to contact lens use will show up first in an emergency health service
setting. So it is not valid to conclude that incidence data solicited from some eye care
professionals only (operating in a non-hospital setting) represents a survey of the universe of
potential incidences related to contact lens use.
2. The evidence in the United States is clear and