16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00511

Submission Number:
00511
Commenter:
Linn Mangano
State:
Missouri
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
I am a pediatric ophthalmologist (EyeMD) who writes "glasses" prescriptions for children every day. The lens power is determined after a complete eye examination. These glasses are medically necessary to treat strabismus and amblyopia, conditions can result in permanent vision loss if not treated at an early age. I do not sell glasses. I do not own an optical shop. My patients/families take my prescription to any optical shop (retail store that sells glasses) where an optician helps them choose an appropriate frame, takes measurements (often while the patient is wearing the chosen frame) and orders the glasses based upon the lens power I have specified in my written prescription. They then dispense the glasses, assuring that the lenses have been manufactured to my specifications and the frames adjusted to ensure an appropriate fit. Since I am not ordering the glasses it would be inappropriate for me to provide a "pupillary distance" or any other parameter that pertains the fit of the frames. My professional responsibility is to determine the therapeutic prescription/power of lenses. The optical shop and optician are responsible for the making this into spectacles that the patient can wear successfully.