16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00569

Submission Number:
Joanne Cochrane
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Eyeglass Rule, 16 CFR part 456, Project No R511996: This modification of the eyeglass rule will mislead consumers and will have deleterious effects on pediatric patients and on ophthalmologists. The pupillary distance measurement is part of the dispensing process, NOT the prescription writing process. It is imperative to follow a dispensing process for the best outcome when the consumer is spending significant amounts of money on something necessary for everyday function. Eyeglasses are not just fashion accessories. They are medical devices which require a correct fit for best use. Everyone understands that insulin doses need to be tailored for each individual diabetic patient for the most effective treatment. The same principle holds true with eyeglasses. The consumer needs guidance in choosing a frame which can be fit correctly to their individual facial architecture and adjusted so that the lenses, whether single vision, bifocal, trifocal, or progressive, sit at the correct height for optimal vision. When the ordered glasses come in, they are further adjusted to fit the consumer. If any problems are noted with the frame or lens, these are sent back for correction before the consumer takes them home. To bypass this process is to shortchange the consumer, giving the misleading impression that he or she can buy any frame and lens combination and have a satisfactory pair of glasses. When the resulting (paid for in advance) pair of glasses is received and is found to be a poor fit, another visit to the ophthalmologist will occur, where we will have to determine and explain to our patients why the glasses don't fit. There will also be the cost of trying to rectify the poor fit. If it is impossible to properly fit the glasses--which is entirely possible--many times there will not be money in the consumer's budget for a properly fitting pair, and the consumer will have been defrauded both of money and of appropriate function. Children's eyeglasses, which I often prescribe for amblyopia and strabismus, are especially problematic, requiring the expertise of a trained optician to not only measure the pupillary distance, but also to make sure the child has an appropriate frame and that it is appropriately fitted, and to be available for frame adjustments as needed. Children's eyes are still developing, and an expiration date of one year is necessary to keep up with the consequent eyeglass prescription changes. Wearing an outdated prescription could hinder visual development in this age group. I practice in a low-income, rural community. The cost in terms of training personnel and the extra time that would have to be spent on each written prescription would be prohibitive in a small practice like mine. Please do not let the consumer be defrauded. Please do not hinder the visual development of pediatric patients, Please do not force the ophthalmologist to spend more time on glasses complaints and unnecessary government regulation, rather than on patient care. Please DO NOT modify the eyeglass rule to include these new measures--it is not good for the consumer, for pediatric patients or for the ophthalmologist.