16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00496

Submission Number:
00496
Commenter:
Eric Adams
State:
Virginia
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
As an ophthalmologist, the measurement of pupillary distance is not a test that I perform. That measurement is performed by an optician, the licensed professional who is responsible for fitting the patient with spectacles. Measuring pupillary distance is not part of a refraction and, therefore, should not be part of a spectacle prescription. I would also like to mention that pupillary distance is not always sufficient to produce a proper pair of glasses. For example, some patients have asymmetric distances from the right pupil to the nasal bridge compared to the distance between the left pupil and nasal bridge. These anomalies are not reflected in pupillary distance, they can be detected by an optician, and they have to be taken into consideration to properly fit eyeglasses.