16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00780

Submission Number:
00780
Commenter:
Marilyn Stevens
State:
Ohio
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Once a vision prescription is written, a qualified optician then determines the placement of spectacles in a fitting process that includes calculating a Pupillary Distance Measurement (PD) and a Segment Height Measurement (Seg Height) to ensure a proper fit and proper vision for a patient. These are two very distinct processes with different tools and expertise needed. Requiring the addition of a PD Measurement to the vision prescription would force an optician by law to use that measurement even if the measurement provided is incorrect. It is essential to the health of the patient that a trained optician evaluate the vision prescription and a patient's vision history in order to ensure that the proper measurements are taken. This also leads to the question as to who would be legally responsible for the spectacles that were dispensed. Would it be the person who wrote the vision prescription with the PD Measurement or the optician who filled the prescription based on the measurement of a third party when it was incorrect? In addition, responsibility for remaking spectacles normally falls on the dispenser (Optician) and the lens supplier. Using third party measurements would put an unfair financial burden on the actual dispensers of the spectacles to correct a third party's error in measurement, which could be passed along to the patient.