16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00550

Submission Number:
Maayan Shuval
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
To whom it may concern, I am an apprentice and student Optician in the state of Washington. I would like you to take a minute to consider the following input on the proposed change to the eyeglass rule. The eyeglass rule is a beautiful and wonderful thing. Giving patients a copy of their prescription is essential. However, what is being proposed goes beyond the scope of a prescription. A pupilary distance (PD) is defined as "The distance between the center of each pupil, used in fitting eyeglass frames and lenses." This is according to Dictionary.com. By definition a pupilary distance is a measurement. Measurements are not prescribed. Both Optometrists and Ophthalmologists write prescriptions but do not take the PD measurement. What will requiring this added information do, you ask? Well requiring this information will increase the public's ability to order glasses from online retailers. That is all. Any optical shop takes a pupilary distance when ordering a patient glasses and good practice is retaking the measurement each and every time glasses are ordered. This is not a problem with any brick and mortar institutions whether privately owned or in larger corporations. I would like to emphasize that this measurement is variable depending on what eyeglasses need to be ordered, the age of the patient, and it can change. Please recognize that this proposition is asking for more than a prescription. It is asking for the public to suddenly understand how glasses are made and how different measurements can influence eye wear as well as the eye wear's success. In each lens order additional measurements are often taken (depending on what is being ordered). Optical center (or OC) heights are often essential to the success of the eyeglasses as well as segment heights and fitting heights with various types of multifocal lenses. Not to mention vertex distances which can greatly change the prescription based on the fit of the frame. This is more than a matter of a PD. If this proposition passes the legislature will be acknowledging that detail is unimportant in making eyewear. Please understand that when opticians are ordering your glasses, we take all these - and many more- measurements into account. We want you to see well when you put on your reading glasses to read this letter. This means taking these measurements accurately and in person for each job. Please consider turning this proposition down as we - as opticians and people - care about the quality of not only your vision, but each and every individual's vision. I do hope you choose to help uphold the quality of eye wear and entrust opticians around the country to take care of their patients. Sincerely, Maayan Shuval