16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00739

Submission Number:
00739
Commenter:
Daniel Koch
State:
Ohio
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Heard from Senator Schumer that he was going to try to have doctors required to give measurements for glasses included with the precription for eyeglasses. Could this be a result of influence from Warby Parker in his state of New York? Political sellout to the highest bidder! In Ohio and most states, once a frame is selected measurements are carefully taken by licensed opticians to place the optic centers of prescription lenses directly in front of the pupils of patients. This includes a PD and OC height for single vision eyewear. Optic Center heights are dependent on the fit and shape of the frame selected. Bifocal heights, trifocal heights, and progressive heights are also all dependent on the fit and shape of the frame. Neil Blumenthal, a co-founder of Warby Parker, was quoted in the New York Times as stating, "We've produced algoriths that are more reliable than measurements taken in-person." This is a bold-faced lie that an algorithm could ever be more accurate than a properly trained individual with the proper equipment taking measurements with frame and patient in front of them! What's next? In addition to potentially requiring doctors and their staff to not only provide free measurements for glasses that have traditionally been included as part of the purchase price for eyewear, are we also going to mandate free adjustments and trouble-shooting of poorly crafted eyewear purchased online? Maybe free repairs for small parts or screws? We already are routinely trouble shooting problems by online retailers. Patients are told by these online companies there is a problem with their prescription. When I trial frame their actual prescription for them, the problem magically disappears! The lenses are made wrong or incorrectly placed in the frames. Patients, of course, should be able to purchase their eyewear where they like within law. ALL sellers of eyewear should be held to high ethical standards, not just the brick and morter locations subject to state law. To do otherwise, creates an inherently unequal playing field. I have to hire trained and licensed people, they don't because they are out of state and beyond the reach of State Boards. Not fair! If the FTC moves to change the existing rules, you too have sold yourselves to the highest bidder!