16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00500

Submission Number:
Kenneth Schwartz
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Thank you in advance for opening up the Ophthalmic Practice Rule aka Eyeglass Rule for comment. I am a Licensed Certified Dispensing Optician in CA. Practicing in excess of 42 years. Please see my comments below which reflect a long overdue update to ensure the continuing rights of patients in the eyewear industry. 1. The Pupillary Distance (PD) must be included when redefining the Rule of an "Eyeglass prescription": The PD is equally as important in filling the prescription (Rx) correctly and completely, as the Refractive error portion of the Rx is. The PD measurement determines the proper placement of the Optical Center of the Rx lens in front of the patients eye. Proper placement mitigates any unwanted Prism in the eyeglasses. Unwanted prism causes Object displacement both in the distance and for near vision. Displaced objects in the distance create an "unsafe" visual situation and it is potentially very dangerous. Displaced objects at near can create double vision and/or object ghosting. Without including the PD on the written or phone stated prescription, it is absolutely "incomplete" and unfair to the patient. The Rule should be in favor of giving the "patient" a complete prescription which includes the PD. 2. Prescription sharing and Verification by Opticians, Optometrists and Ophthalmologist: The Rule should be in favor of the patient/consumer for a prompt response of 1 business day from the initial Rx request, by any Licensed Opticianry, Optometry or Ophthalmology practice, requesting a "complete" patient Eyeglass or Contact lens prescription. 3. Prescription Term: The Rule should reflect that all prescriptions should be valid for up to 3 years, unless there are medically justifiable reasons for a shorter term. 4. Neutralization: The rule should be expanded to allow for Verification and Duplication of an existing prescription eyeglass, by verifying the Rx power and PD, using the lensometer (lens power verification device). This procedure is referred to as Neutralization in the eyeglass industry. Licensed Optometrist and Opticians should be allowed to facilitate patients by Neutralizing and duplicating their existing eyewear. This "very" accurate Rx verification is done using the same procedure that is used to check the prescription at the Rx Fabrication facility and again at the point of dispensing for accuracy. The Rule should reflect a patients right to choose to use the same prescription as they have been wearing, without having to return to or requiring authorization by their Dr. 5. Duplicate written Prescription: The Rule should be in favor of giving a complete duplicate prescription to a patient as general procedure. The Rule should also be expanded that upon patient request and patient verification, a prescription should be forwarded to the patient by fax or e-mail transmission, within 1 business day from any licensed Opticanry, Optometry or Ophthalmology practice.