16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00564

Submission Number:
00564
Commenter:
Rachna Narula
State:
Washington
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
The definition of "prescription" should NOT be modified to include pupillary distance. I am a licensed optometrist in the state of Washington. Pupillary distance does not impact the health of the eyes. As a optometrist, I do not sell glasses and I am not trained to measure pupillary distance. I do not have the equipment to measure pupillary distance. The equipment would cost me approximately $400. When someone is ordering glasses, an optician is trained to measure pupillary distance. Furthermore, pupillary distance is dependent on whether the glasses are used for distance, near or intermediate vision.