16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00728

Submission Number:
Mark Buten
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
I am vehemently opposed to the Eyeglass rule being considered by the FTC. Consumer safety is of up most importance when reviewing the Eyeglass rule and contact lens rules. A trained or licensed optician who is qualified in taking correct measurements (pd, seg height, prisms, panascopic tilt etc) and verifying the measurements and accuracy of prescribed glasses or contacts is of up most importance to the safety and well being of the consumer. I have been a licensed optician for 30 years and take very seriously that a contact lens or said glasses is properly fitted, aligned and accurate.Glasses and contact lenses are considered medical devices that correct a deficiency in vision. Unfortunately, in recent years I have seen a number of consumers, particularly the millennium generation looking to purchase on-line at various places across the world. Glasses must be fitted properly, if anyone reading this wears glasses full-time they are educated enough to understand, glasses are not ONE SIZE FITS ALL. The strength of the prescription dictates the proper size of eyeglass frames to be chosen. Every consumer has different nose sizes, shaped heads, ears etc. that requires a custom fit to properly align the glasses and most of all to ensure the glasses are comfortable enough to wear not slipping and causing irritation. I have recently noticed, at a alarming rate, the younger generation bringing there glasses purchased on-line in to our shop to fit or evaluate the glasses. In ALL cases the glasses were not even close to the right fit on their face and often time the glasses were not correct. We have tried to educate this generation that if they had gone to a trained professional optician they would not be experiencing such dissatisfaction in a pair of prescription eyeglasses. The history of the consumer/patient is also very important in choosing proper eyewear and lenses. The front curve of a pair of eye glass lenses currently worn by the consumer/patient is advocated to ensure ease of transition into a new pair of glasses. The front curve requires a tool to measure a trained optician at a reputable practice or shop would ensure the curve is matched. Our practice does not want to give out PD information where a patient/consumer could go to an on-line purchase jeopardizing the integrity of the prescription. Ultimately, where does legal blame go if PD and other measurements are miscalculated due to a 3rd party who does not take this measurement. Ultimately, the consumer comes back to the doctor who wrote the prescription which can cost time, money, and unnecessary re doing of lenses. Ultimately the FTC needs to be responsible in educating the public that prescription eyeglasses are medical devices that require proper measurements and most importantly proper frame selection from a qualified optician to ensure the frame is correct for the facial inadequacies that each individual consumer/patient has. Even if the consumer is shipped several frames to try on they are not educated in the proper fitting techniques of selecting the frame that would work best with their prescription and facial structure. ONE FRAME DOES NOT FIT ALL. It's a travesty that these young consumers are being "duped" into thinking purchasing prescription glasses on-line is an acceptable way of purchasing eye glasses only to realize the glasses they purchased don't fit and could be improperly made without verifying the prescription.