16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00662

Submission Number:
00662
Commenter:
cervantes
State:
California
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
More oversight of online retailers is necessary to protect the consumer. Nearly half of prescription eyeglasses sold directly to consumers online either do not meet prescription specifications or fail accepted safety standards, according to "Safety and compliance of prescription spectacles ordered by the public via the Internet," a study in the September 2011 edition of Optometry: Journal of the American Optometric Association. The study found that: --In more than one in four (28.6 percent) of the eyeglasses, one or both lenses were out of tolerance with at least one important parameter of an optical prescription. --In almost a quarter (22.7 percent), one or both lenses failed the U.S. Food and Drug Administration's (FDA) impact-resistance requirement. --About one in every 16 pairs of eyeglasses sold online failed tests for both adherence to prescription specifications and safety, and --Overall, some 44.8 percent of spectacles failed to meet either prescriptions specifications or impact-resistance requirements When the risk of error can lead to injury and blindness, every action and precaution must be taken to protect the patient and consumer. In addition, please see this information from http://njpublicsafety.com/ca/faq/optfaqsII.htm#4b In the past all spectacle lenses were made of the same index of refraction (density), same center, edge thickness and the same style. All of the patients facial anatomical measurements were taken with a millimeter ruler at the time of the eye examination. With the explosion of new frame designs, lens materials and technologies, the old measurement system is no longer remotely adequate. Proper placement of the appropriate aspect of the lens in front of the patients pupil is critically important for today's technologically more advanced spectacle lens and frame materials. Special instrumentation and devices are required to ensure the prescription lenses will function properly for the patient. The measurements must be made relative to the eyeglass frame selected. Therefore, the patient must be measured by the seller and/or the dispenser of the eyeglass frame. The optometrist cannot assume any responsibility for the proper prescription being misplaced in front of the pupil due to the configuration of the frame, the lens style or material chosen by the patient. Not all lenses are created equal and there are many technological differences. Pupillary distance, "PD", refers to the measured distance between the patients pupils, and is taken for at least far and near viewing distances. Today's lenses require precise horizontal and vertical placement of the lens selected by the patient. These measurements are effected by the lens and frame shape, size and use (driving, computer or reading) of the prescription. Therefore, the patient must be measured by the seller and/or dispenser of the eyeglass frame. Segment height, bifocal, trifocal or progressive lenses, refers to the height or placement of the near viewing (intermediate or reading portion) of the lens. Most lens manufacturers have a fitting guide to ensure the lens is positioned for maximum viewing efficiency with minimum of peripheral distortion. Therefore, the patient must be measured by the seller and the dispenser of the eyeglass frame.