16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00757

Submission Number:
Richard Ahrens
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Page 1of 3 October 23,2015 FTC. Article: Eyeglass Rule, 16CFR Part 456, Project # 511996 I am a Washington State Licensed Dispensing Optician and have been involved in the eye care industry for close to 40 years. I own my own small Optical Practice and am totally against a proposed rule change that would consider mandating an Eye Doctor to attach a Pupillary Distant measurement ( PD ) to their written Eyeglass Prescription. I am also against mandating the examining office to provide a PD measurement to an individual to take to another facility for use. A Pupil Measurement has never been part of a Comprehensive exam. A Doctors exam instead, comprises a Full Eye Health Exam and Refraction. A Written Prescription contains the Basic Spectacle Lens powers and when Bifocals are prescribed, a close up Add Power for the Bifocal lens is attached. I am in total agreement with the FTC rule that requires an Eye Doctor to release a copy of a finalized copy of an eyeglass Prescription to the patient at the end of an eye exam. Eyeglass rule Title 16 Chapter 1 Part section 456.2 The Patient has the option to take that prescription to a store of their choice and the Licensed Optician there, will Measure the PD to the appropriate focal point determined by the needs that that patient requires. If a Written prescription for Bifocals or Progressives is indicated, An Optician can calculate a PD measurement designed specifically for Reading, Distance or Computer use, by utilizing the Doctors original Prescription. It has only been recently that there has been an issue that has been brought forward, asking the current Eyeglass Rule to be changed to accommodate Online sales, they are asking the ECP's to add the Pupil Measurement to the Doctors written RX. This request is likely driven by these sites attempting to cash in on the eyeglass market by asking a professional to determine this information. Page 2 of 3 October 23,2015 A Pupil Measurement is only one of several measurements that must be addressed by the Optician present, in order to determine the Best visual outcome for that particular individual and his or her eyewear. These cannot be done virtually, with any accuracy. These measurements are critical and precise. The comfort and the performance outcome will be determined by that Opticians ability to accurately set this measurement. It can only be provided and defined "in person. The Optician must consider the Prescription strength, Frame choice to facilitate the correction, Facial features, size and design type, the adjustment of the nose pads to set balance and comfort for the patient, With the Presbyopic patient ,The various multi-focal heights must be accurately measured for a particular multi-lens design as in lined Bifocals, Trifocals, Progressives, etc. In addition, the Optician has the knowledge and resources to accurately determine what lens material, design and optical parameters will be most appropriate for a given prescription. The main objective is providing the very best result for the patient. With today's technology, and pricing, the main objective that will result in a an optically precise set of glasses is taking in to consideration accuracy, the use of quality products, and having an educated professional that has the knowledge and experience to provide this service. The schooling and experience that are required to provide a safe and accurate pair of glasses can only happen (one on one) by a licensed professional. To ensure these criteria, these licensed professionals are required to be current with continuing education, follow the strict State and Federal compliance guidelines,and ethically ensure that those patients that they have provided services, are treated with care and compassion. There are no exceptions. Page 3 of 3 October 23,2015 The exploitation of Online eyeglass sales has unfortunately placed the profession of Opticianry, Optometry, and Ophthalmology, in a misrepresented category as a Commodity based enterprise, rather than a medical prescribed position. I am fine with free market enterprise "to a point. To down play a medical based profession where we must be in direct contact with the patient, we need to be held accountable for our ability to provide safe and effective eye care. The patient's safety and our ability to educate, and offer knowledge based care doesn't stop at Pupil Measurements, its all inclusive. Eye care is being simplified by our virtual counterparts and in doing so, will open the door.by signaling to the public, that medically based detail is unimportant. Please consider turning this proposition down. Thank you,