16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00548

Submission Number:
00548
Commenter:
Hugh Cooper
State:
Massachusetts
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 in practice for 18 years seeing both adult and pediatric patients, I have never been trained to accurately measure nor have ever performed the pupillary distance measurement. I do not sell glasses and simply provide my patients with their refractive (power) measurements. The optician at any local or department store optical shop who measures, orders and adjusts the patient's glasses performs this vital role. The optician is a vital part of optimizing the fit and frame adjustments that are needed in order for glasses to work the best for the patient. The only time the patient would require a pupillary distance measurement on their prescription is if he or she is buying their glasses online. By bypassing the optician, there are many areas where the glasses may not fit or be adjusted properly, including the PD. Ophthalmologists are not opticians and do not have their training and expertise in performing these measurements accurately. Performing an accurate PD is NOT part of a refraction. A patient who really wants to order glasses online may have an accurate PD performed by a local optician usually for a nominal fee of $10 or less. As an ophthalmologist who does not sell glasses, I depend on the local opticians to perform accurate measurements and glasses adjustments including the PD and would be unable to provide this accurately to my patients, particularly pediatric patients. This will result in unhappy patients. I respectfully ask that this proposal be stopped.