16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00805

Submission Number:
00805
Commenter:
Angeline Hixson
State:
Georgia
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
It is my understanding that the FTC is considering adding the pupillary distance (pd) measurement to the required eyeglass prescription. I am a doctor of optometry and would like to comment upon why I believe this would not be beneficial to patients. Although I think that it is fine for patients to be able to take their glasses prescription to any qualified optical, the pd measurement is part of a series of measurements taken by an optician when glasses are being made, and not a measurement that is usually taken during the eye exam. The pd measurement taken during the exam is usually an estimate performed during the autorefractor measurement. This method of obtaining the pd is often highly inaccurate. An accurate measurement should be taken with a pupillometer, an instrument which is used in opticals by opticians. If the pd is measured inaccurately, glasses may result in unwanted prism. In addition to this measurement, other factors must be considered to help patients obtain a good pair of glasses. It is important to consider frame choice (size and frame shape) based on a patient's prescription. There are also other measurements of the glasses which are particularly important for accurate vision with the glasses, especially with progressive or bifocal glasses. These measurements must be obtained with the patient's chosen frames on his/her face. There are no opticals that would be able to take those measurements that would be unable to measure the pd. Since the patient must be present at an optical to obtain this set of measurements accurately, there is no need to require the pd measurement to be included on a prescription.