16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995 #00581

Submission Number:
Sheena Brown
Initiative Name:
16 CFR Part 315; Agency Information Collection Activities: Review; Comment Request; Contact Lens Rule: FTC Project No. R511995
In re: to the contact lens rule above, our office has no problem giving the patient and a third party seller a contact Rx. In compliance with the law, our staff has been trained to provide this information to third party suppliers per the pt.s request within 8 working hours of the request. Unfortunately some third party contact lens vendors fax requests after 5pm, and fill the request before the office reopens at 8:30am. (Even though the Rx expired up to 4 yrs ago.) It appears the doctors comply with the ruling, but the third party vendors do not have to comply or are not monitored. That is an issue. Now that the FTC is considering requiring the doctors to supply PD's and Seg Hts. for glasses as part of an optical Rx, poses impossibilities. Isn't this the job of the dispenser/seller of the glasses? Isn't that one of the major reasons I have to be licensed as an optician in Georgia? In order to obtain a Seg Ht for a bifocal or a multifocal, one must have the actual frame the lenses are going in AND it must be adjusted to the pt, prior to obtaining the Seg Ht. If the doctor does not have the frame then IT IS IMPOSSIBLE FOR THE DOCTOR OR HIS STAFF TO GIVE A SEG HT... To obtain a PD (Pupillary Distance) our office uses a special machine and personnel are trained to do this task. Further, PDs must be monofit for certain Rxes, which requires certain specialized equipment to provide this measurement. This requires increased costs,staff,time and training which should be provided by the seller of the glasses. By the seller of the glasses providing this service as they have always done, assures accuracy and guarantees the person is getting a product manufactured specifically for the person and their needs. Then the eye must be determined where the optical center of the frame is in relation to where the pt's eye sets in the frame, as well as the vertex distance of the frame to the eye. There is much more than a few set of numbers to get an RX that works. To get the correct numbers for PDs, Seg Hts, and optical centers, vertex distance, etc., requires an experienced person and specialized equipment and time. This service also costs additional money. What if the RX just doesn't work well in the frame the pt. selected, then whose responsibility? In my career I have had MANY patients bring in glasses they have purchased on line, that did not work. Most of the time I could identify the problems. But I cannot justify my time and energy to find the problems of glasses I did not have any control over. The truth is, I CANNOT give a seg ht., vertex distance, optical centers, etc., without the frame on the patient and adjusted on the patient. I do not, nor does anyone, have all the frames in the world, so I nor anyone else can realistically do these measurements. A simple PD may be given with the RX but it must or at the least should be verified by the dispenser/seller to assure accuracy. A monofit PD requires special equipment and extra time. Some doctor's offices that do not dispense glasses, do not have this equipment even available. NOW the dispenser/seller is responsible for these measurements. Why does that have to change? If they choose to sell glasses, shouldn't the measurements be their responsibilility. All of these measurements are unique to the individual. And all of these measurements make a difference in a person's acuities (measurement how well one sees). Shouldn't the seller take pride and responsibility for his product? Glasses are not like a pair of shoes! Glasses are not even like most contacts manufactured today. Glasses don't come standard! They are custom made, one lens at a time. Some sellers get their measurements using photography. And in noncomplicated RXes, this has worked well for some adults. But for children and especially those with moderate to high RXes, true PDs and Optical Centers must be correct. Please do not change the glasses RX FTC rules.