16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00749

Submission Number:
00749
Commenter:
Andrew Bateman
State:
Nebraska
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
The measurement of the pupillary distance is part of the onus assumed by the dispenser of the eyewear. It is not part of the refraction process that provides for a spectacle prescription. It is a part of the dispensing process for fitting the patient in the correct eye wear. Getting the patient into the correct frame size and measurements are as important as the prescription itself. The aspect that has been lost in terms of spectacles is that they are a prosthetic device. They allow a person to see and function on a daily basis. They are not a retail device, you do not go get measure for a prothetic leg somewhere and then get it made elsewhere. The maker of the artificial limb takes all of the measurements. If the person that is making the glasses and dispensing them is not the person taking the measurements then who does the malfunctioning pair fall to? Each side can blame it on the other and the patient is the one left in the lurch. These are after all patients and not retail consumers. If a person wants to dispense them their glasses they should also be taking the appropriate measurements to get them fit. This issue does not even address the fact that besides the pupillary distance a proper pair of glasses has the optical center measured with the frame on their face. If the optical center is off it can cause eye strain and fatigue as well as double vision. The only way to measure this is with the glasses on the patient's face, thus needing to be done when the pupillary distance is measured.