16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00456

Submission Number:
00456
Commenter:
Franz Michel
State:
California
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Hi folks- As an Ophthalmologist I always give a copy of a glasses prescription to my patients. I consider it their property. My concern is requiring a doctor to take and give optician measurements such as where to place a bifocal or the distance between the pupils. Requiring these measurements be given by the doctor puts us in an impossible position as it makes us liable for mistakes done by whoever sells the glasses. The seller should be responsible for taking those measurements! Traditionally an optician takes measurements to best position glasses on a patient, the doctor never does this. If I write a prescription for a medication it is the pharmacist's responsibility to dispense the proper medication, certainly not mine. Similarly, I certainly should not be required to take measurements that a dispensing optician is responsible for. Please keep this in consideration. Most eye docs have no qualms at all with giving a copy of a patient's prescription to them. However we have grave reservations about being required to provide measurements for optical frames which we will never see. It is critical that optician measurements such as pupillary distance be left to whoever is dispensing/selling the glasses such as an optician. Thank you!