16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00461

Submission Number:
00461
Commenter:
David Shepherd
State:
Michigan
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Forcing all eye doctors to include the pupillary distance on all prescriptions would not be in the interest of patients. There is new and exacting technology (the Zeiss iTerminal for example) that ingeniously measures pupillary distance plus several other significant glasses fitting measurements AFTER the patient has selected their eyeglass frames. This instument virtually eliminates the number of poorly fit glasses especially with progressive lenses. This technology can only be found in an optical dispensary, requires the frames to be already selected, requires an optician trained in its use, and requires a high glasses volume to justify its expense. Forcing eye doctors to use old technology to write the pupillary distance on a prescription would be legislating old and outdated technology and not in the interest of patients. Also, in my 40 plus year career it has always been the job of the optician to measure the pupillary distance. I have never had a call from an optician to give them the pupillary distance.