16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
I disagree with any new mandatory requirements to include a PD with a glasses prescription. The PD measurement needs to be done by the optician who is filling the prescription. It is the optician's or dispensing party's responsibility to make sure that the lenses are placed appropriately within the frame and adjusted to the patient's face. The doctor who is providing the refraction has the responsibility to make sure that the power of the lens is appropriate. It is the dispensing party's responsibility (and it is they who are compensated) for making sure the lenses are appropriately mounted within the frame and are correct for that patient's facial features which includes determining the PD.