16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00573

Submission Number:
00573
Commenter:
David Hoffman
State:
New Jersey
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Ophthalmologists such as myself are trained to refract the patient but we do not perform PD (pupil distance) measurements or other measurements relating to how the lens and frame fits on the patient's face. We only obtain the strength that goes into the lens for each eye called the refraction. PD measurements are not something we are trained to do nor does it have any health or medical importance. It is of value only for the actual fitting of the glasses. The optician or another professional who makes and dispenses the glasses obtains the PD and other glasses measurements that is unique to their training and involves time and skill and special instrumentation. It should be the optician's choice whether he or she wishes to perform this service for someone independent of the purchase of glasses. If a person other than the one who fills the glasses prescription specifies the PD (or similar specicifications) and it is different than that obtained by the optician then whose measurement should prevail? The optician who ultimately sells the glasses (and will have to refund if the consumer has complaints related to the PD) should be the one who obtains the measurement and not the prescribing ophthalmologist who is not trained nor typically possess the instruments needed. If a business chooses to sell glasses through the mail or internet without actually measuring the purchaser directly that is a choice that the consumer makes with the expectation of lower prices. Asking an optician or other eye care professional to obtain these measurements involuntarily or without compensation for time and equipment is not about consumer choice as much as subsidizing the online merchant's business. The consumer has the choice of obtaining glasses "face to face" with the optician or taking their chances online.