16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
I am writing in regard to the proposed "eyeglass rule" requiring eye care doctors to provide "inter pupillary distance". There are several issues with this proposed rule which makes this proposed rule a bad idea. First , I have practiced eye care for 27 years as an Ophthalmologist and I have prescribed glasses for this entire time. I have NEVER measured an inter pupillary distance for a glasses prescription in all my 27 years. This is a measurement perfumed at the optical shop of the patient's choice. If the eye doctor is not making the glasses, the patient's optical shop choice is responsible for taking this measurement and eventually ensuring that the glasses are made correctly according to the inter pupillary distance measurement. Problems arising from glasses usually are in the making of the glasses and the optical shop assumes the problem with making the glasses correctly NOT the eye doctor writing the glasses prescription which does NOT include inter pupillary distance (just like it does not include bifocal segment height, lens base curve,type of lens material,lens coatings, tinting choices, or frame style). The inter pupillary distance is a test done by the optical shop making the glasses. This proposed rule is probably wanted by the internet optical shop glasses companies. When there is a patient problem with a pair of glasses made by an internet glasses company, the patient will go back to the eye doctor since they don't have a physical place to go when dealing with an on-line internet glasses manufacturing company. Patients think they are saving money, but patients turn to the eye doctor and in the end the consumer is the victim. I am opposed to the proposed "eyeglasses rule" and ask you not to approve this rule.