16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00621

Submission Number:
00621
Commenter:
Erin Loewen
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
As an optometrist in Canada, I do not object to requiring the optometrist or ophthalmologist the provide a copy of the prescription to the patient, in the interest of the patient. I have concerns about the prohibition of providing the patient with a notice waiving the liability or responsibility of the provider for the accuracy of the exam or the ophthalmic goods and services dispensed by another seller. There has been documented evidence of spectacles made incorrectly by various online vendors (ref: Citek et al.). The conclusion of the attached study was that nearly 50% of the spectacles ordered online did not meet the physical requirements of safety or the optical needs of the patients. As eye care professionals, we can put in place quality control measures for products that we dispense, however we can not put in place the same measures for goods and services obtained elsewhere. Therefore it is unreasonable to prohibit such a waiver of liability.