16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00593

Submission Number:
00593
Commenter:
Jennifer Sudama
State:
Maryland
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'' I am vehemently opposed to the Proposed Rulemaking regarding providing PD's on eyeglass prescriptions. This measurement should be performed by a licensed/trained optician who prepares an order for and fabricates eyeglasses. The success of an eyeglass prescription for a patient depends not only on the prescription, but the PD's, segment heights, base curves, and so on. If this rule goes forward, then the quality of work will not be able to be regulated properly. Services that opticians once provided as a part of the eyeglass order will now need to be charged for separately. Online purchases of eyeglasses (and endeavor that is unreliable at best) will force opticians to now charge for repairs and adjustments that once would have been built into the pricing of eyewear. After all, how can a computer, in the absence of hands and judgement, adjust a pair of glasses for pantoscopic tilt? It is also ridiculous that a rule would be proposed that provides for the dispensary of optical goods to not be held accountable for the quality of its work or the satisfaction of its customers, instead leading it back to the ECP to face the entire burden of not only trouble-shooting the problem, but also to forcing it to accept responsibility for the manufacture of goods by someone (or thing) else.