16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00590

Submission Number:
00590
Commenter:
Mark Fernandez
State:
Virginia
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
The proposal to require eyeglass prescribers to include interpupillary distance on eyeglass prescriptions is entirely inappropriate. Measurement of interpupillary distance is the responsibility of the optician who makes and fits the patient's glasses. Most ophthalmologists and optometrists do not have the equipment required for accurate measurement of interpupillary distance, and furthermore have no way of taking in to account the nuances of measuring this number with respect to the eyeglass frame that the patient will choose to purchase from the optician of his or her choice. Any effort to compel ophthalmologists and optometrists to measure interpupillary distance in eyeglass prescriptions is a thinly veiled attempt by internet eyeglass vendors to shirk their own responsibility to sell properly fitted eyewear. Instead of further enabling online (and often overseas) businesses to sell ill fitted glasses, the FTC should hold internet vendors responsible to accurately fit eyeglasses with the same level of competence as that of a licensed optician. Fitting eyeglasses is an art that cannot be simplified into the measurement of interpupillary distance. Forcing prescribers to measure IPD will simply result in a proliferation of poorly fitted glasses bought online at the detriment of well trained and well intentioned local opticians. Aside from the financial harm to patients who have received an inferior product with no recourse, children in the amblyopic age group are at risk of developing refractive amblyopia (which can cause permanent vision loss if not quickly recognized and treated) by wearing a correct prescription rendered incorrect by poorly fitted eyeglasses. Compelling eyeglass prescribers to measure interpupillary distance will do nothing to lower this risk, as there is much more involved in fitting eyeglasses than IPD alone. It is the sole responsibility of the trained optician, who personally examines the patient and ensures the correct eyeglass fit, to measure interpupillary distance.