16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00615

Submission Number:
00615
Commenter:
Robinson
State:
Outside the United States
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Optometrists should not be obligated to include pupillary distance as part of a patient's prescription as they are not equipped to provide a monocular pupillary distance. During an eye examination, the phoropter (the piece of equipment used to determine a patient's prescription) only measures binocular pupillary distance. A binocular pupillary distance is not nearly as accurate as monocular pupillary distance for the creation of the best possible glasses for a patient. I would not use a binocular pupillary distance to make glasses for my own patient in my own office because it is not accurate enough. The few millimeters of asymmetry between a patient's pupils can result in prismatic errors in a patient's glasses, which can subsequently negatively affect their binocular vision. As the determination of monocular pupillary distances, as well as optical centers and bifocal segment heights, are all measurements specific to a patient's choice of glasses, I believe they should be taken by the dispensing professional, not the prescribing professional. It is also the dispensing professional that will have the equipment to determine monocular pupillary distances, whereas many prescribing professionals may not have this equipment. It is also important to note that it is more dangerous to the public if they are given data that could be used to create inferior (and possibly harmful) corrective eyewear. We, as optometrists, have taken an oath to do no harm to our patients and I strongly feel that providing inaccurate information (in the form of binocular pupillary distances) to a patient would constitute doing harm. It is for these reasons that I do not believe pupillary distance should be included as part of the prescription.