16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00506

Submission Number:
00506
Commenter:
John Saragas
State:
Massachusetts
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
The addition of pupillary distance to a prescription for spectacles adds an unfair burden of responsibility to the prescribing ophthalmologist and optometrist. The responsibility of determining the pupillary distance belongs to the individual constructing the spectacles, as it has always been. In addition, there are styles of spectacles, and eye conditions that sometimes require modification of the pupillary distance. This modification needs to be done by the individual constructing the spectacles. The prescriber can not predict the style that is to be chosen and any according modification of the pupillary distance. I do not feel it is fair to shift the responsibility and work from the individual constructing the spectacles to the prescriber. The individual constructing the spectacles must accept responsibility for their work.