16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
I'd like to comment on Eyeglass Rule, 16 CFR Part 456, Project No. R511996. I've worn eyeglass for 16 years and understand the importance of having easy (and quick) access to my complete prescription information so that I can purchase glasses when and where I want. As the Rule is currently written, there is no obligation for a doctor to include my pupillary distance on my prescription and no obligation to get back to the retailer with whom I'm purchasing glasses within a reasonable time frame. It doesn't make any sense to me that contact lens prescriptions must be verified within a certain window of time, but eyeglass prescriptions don't have to be? I'd argue that the two rules should be created similarly -- and that doctors should be obligated to verify both types of prescriptions quickly. Additionally, my prescription has changed only a few times within the last 16 years, so I shouldn't be obligated to return annually for an eye exam. What if I want to purchase glasses with my existing prescription that works great, but I can't because my prescription is "expired"? Making prescriptions valid for 3 years across the board seems more reasonable, and if I need to come back more often I should be able to determine that myself. I am an employee of Warby Parker, though this comment is based on me personal views as a long-standing eyewear consumer.