16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00543

Submission Number:
00543
Commenter:
William Beck
State:
Kansas
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
This proposed rule change proposed by Senator Charles Schumer is purely at the behest of on-line retailers of eyeglasses. They are finding it difficult to forward their business model because most prescribers do not measure the inter pupillary distance as a routine part of writing the prescription. This is usually done by the optician when glasses are being fitted. The cost of performing this service, usually done by specialized equipment, is recouped at the sale of the glasses. Now the big retailers are trying to get this information about inter pupillary distance for free and then also take the profit from the smaller and usually individual glasses provider. Of course when there is a problem with the online glasses, the online retailer will be no where to be found. Thus, problem solving will fall to the prescriber. The patient will assume that the mistake is in the prescription and demand that the writer of the RX fix the problem for free. Finally if an individual is being encouraged to go online to buy a bifocal that is a progressive, that is fraught with potential problems. There are SO many variables about fitting and adjusting glasses to make a patient happy that there is no way this can be done properly online. So if you mandate this you will likely make some people very unhappy because they will not be fit properly. I, for one, will tell them that, unlike if they buy the glasses from me, they will have no recourse for fixing their problem. I will not let Big Online Retialers steal my profits and then solve their problems too.