16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00617

Submission Number:
00617
Commenter:
Jerome
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
The dispensing of eyewear is, like the dispensing of drugs, a regulated profession. This is for good reason. The doctor provides the info necessary about the eyes. The spectacle dispenser takes it from there. There are many features/measurements taken into account in choosing appropriate eyewear and modifying the prescription for different types of lenses and fits of frames. The process can be quite complex- the fact that consumers and others don't understand this is unfortunate but can't really be helped. It takes years of schooling in optics and ocular health to understand the relevance and veracity of our comments. As an optometrist, I always give the patient their eyeglass prescription. This does not include certain measurements which are the responsibility of the eyeglass dispenser. I do give instruction, for example, as to which PD to use ( distance, near, intermediate). This is measured by the dispenser, then may be modified depending on the fit of the frame, the incorporation of prism, the type of progressive lens ordered etc. The performance of the prescription finally dispensed hinges on these measurements and the dispenser is paid to make them and is held responsible for them. There are many patient and frame measurements other than PD made as well and they all affect outcome. I get that patients don't understand this- they can't without the training. They need to trust their doctors- the professional experts who have the patient's best interests at heart. We know what we are talking about. We spend hundred's of thousands of dollars to stock and staff dispensaries in order to have the oversight to ensure that things are chosen, measured and done correctly. In the process, we are paid for this service. Here in Canada, selling glasses online is illegal, for good reason, just as selling drugs online is illegal. I can't tell you the number of times a patient sits in my chair for a routine exam with no complaints and then is found to have drastically reduced vision in one eye or both. I find a myriad of problems including retinal detachments, cataract and macular degeneration. Subpar acuity causes reduced stereoacuity (depth perception) which increases falls, car accidents... We see it time and again- patients don't understand the ramifications of a poor decision. At this point, it really is a matter of trust in the professional's advice. We trust that the dentist is right when we are told a tooth needs work. We trust the surgeon when we are told we need surgery. We need to trust our eye doctors when we are told we need treatment whether that means referral for surgery (and we choose the most appropriate surgeon for them), vision therapy (and we provide this or refer for it) or new glasses(and we provide them with the info the next provider will need). Buying glasses online is wrong. None of the appropriate care can be taken to ensure fit, comfort and accuracy of prescription without the involvement of someone in a bricks and mortar location. Online providers are not regulated. Home base and labs are usually off-shore where all standards including safety standards are different or non-existent. When glasses are made thinner than our allowed minimum and they then shatter and injure an eye, what will the patient say and do? Who is responsible? I would say it is the body making the purchase of deficient eyewear possible... Why am I up at 4a.m. writing this? It is because I care about my patients. Please care too.