16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00744

Submission Number:
00744
Commenter:
Aeyoung Sim
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 PD, pupillary distance, should not included in the prescription because in order to make right eyeglasses for the patient, the optician need to consider which lens would be the best for the patient first and then decide which PD to take. 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. The determination of the interpupillary distance is not routinely performed as part of a refraction. That determination is and always has been the responsibility of the dispensing entity and the dispenser should be responsible for the accuracy of the fitting parameters. The PD has nothing to do with obtaining the refraction parameters.