16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00571

Submission Number:
00571
Commenter:
Kathi Shelton
State:
Washington
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
I am a licensed Dispensing Optician that has been practicing in Washington state for over 30 years. In 1994 we passed the Consumer Access to Vision Care Act in our state or RCW 18.195. This has worked very well for all parties mentioned for over 20 years now. My concern for the Eyeglass Rule is the proposed modification to include pupillary distance in the definition of the prescription. Ophthalmologists and Optometrists do not take the pupillary distance measurement during an eye examination. This measurement is taken by the Optician as part of the fitting of eyeglasses. Many places where I have worked I did not work in the same area, floor or building as the doctor. Therefore to include this measurement would not be feasible. Many brick and mortar stores now use a device that takes many different measurements including the pupillary distance for the new digital lenses. This method of measuring is more time consuming but results in much clearer vision for the lenses it is used for. Why should I include this service for free if someone is not ordering glasses from me? Many online retailers have a way for the consumer to measure their own pupillary distance. In my opinion this measurement should not be included as part of the prescription because then the doctor could become liable for a measurement they do not take or provide as part of an eye exam. I feel the pupillary measurement should still be the responsibility of the person fitting the eyeglasses. Here is the link to the Consumer Access to Vision Care in Washington http://apps.leg.wa.gov/rcw/default.aspx?cite=18.195&full=true. I hope you find this information useful in your determination.