16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00839

Submission Number:
Wesley Stuart
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
1. There is a continued need for the Eyeglass Rule to benefit consumers, so I believe the Eyeglass Rule should remain in effect. 2. I believe the rule should be extended to require prescribers to provide ONE duplicate copy of an eyeglasses prescription to the consumer at no cost for those who may not currently have access to the original. For example, if a consumer loses the original eyeglasses prescription given to him/her by a prescriber and wants to have it filled, the prescriber should not charge the consumer an additional fee to receive ONE additional copy of the eyeglasses prescription. Providing ONE additional copy to the consumer or to the optical establishment where it is to be filled would not be a burden on current operations for ophthalmic businesses. Providing additional copies to the consumer (beyond ONE duplicate copy) of the prescription would be excessive and the consumer should be charged accordingly. 3. The definition of a prescription should NOT be modified to include the pupillary distance (PD) measurement for consumers. This measurement is typically taken by an Optician or other ophthalmic dispenser and is task-specific. This measurement is NOT generally taken as part of an eye examination and requiring it would cause an undue hardship on prescribers and their staff members performing eye examinations. The PD measurement can also vary depending on the type of eyeglasses being made and for what purpose, and the measurement can change over time. Therefore, providing the consumer with the correct pupillary distance (PD) is dependent on many factors that are out of the control of the prescriber and the Eyeglass Rule should NOT be changed to require it as part of an eyeglasses prescription. 4. A consumer's best corrected visual acuity (BCVA) for distance and near vision should be required as part of an eyeglasses prescription. These measurements are critical for Opticians and other ophthalmic dispensers that fill eyeglasses prescriptions. The visual acuity of a consumer is a critical measurement that allows the person filling the eyeglasses prescription to know what line of letters a consumer should be able to see on the eye chart with that prescription. Without the visual acuity measurement, those filling the eyeglasses prescription have no idea what type of visual result to expect when a consumer is ordering his/her eyeglasses. The visual acuity affects what type of eyeglasses may be needed by the consumer and so, it should be required to be included as part of an eyeglasses prescription.