16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00850

Submission Number:
00850
Commenter:
Christi Brand
Organization:
Opticians Association of Alaska, Inc
State:
Alaska
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
We fully agree with the current eyeglass rule and that consumers should be given the choice of where to purchase eyewear other than at the prescribing physicians office. We strongly disagree with the inclusion of the pupillary distance as being part of the prescription. The pupillary distance is a measurement taken by the optician filling said prescription. The phoroptor used in a physicians office is not precise enough to give an accurate monocular PD which any Optician would trust to use to make eyeglasses from. The PD is critical in higher RX prescriptions, bifocals and progressive lenses and should be taken by a qualified optician. In the case of an amblyopic child an incorrect PD could lead to further vision loss and impairment. The only reason a consumer would need this PD measurement would be to order their eyewear online which goes against many state laws and drives the independent optician out of business. Much of the eyewear made online is inferior and does not meet national tolerance standards. The opticians are the ones that the online eyewear is being taken to when the consumer finds out they've been duped into purchasing inferior materials with incorrect RX at which point we have to tell them they got what they paid for. If you want to make any changes to the eyeglass industry you should regulate online eyeglass ordering, this is where the consumer is being unfairly targeted and is fairly unprotected, when a consumer goes to a qualified optician they can with confidence know that the product they are being sold is at minimum correct, the lenses are within tolerance and the frames are suitable for their RX needs. By allowing the general public to order their RX glasses online they are uninformed as to what they need and insufficient eyeglasses are the result. By allowing anyone to order their glasses online you are saying that vision, one of the main functions used in daily life is not so critical after all and that anyone should be allowed to order anything they want online with no oversight as to if it is in fact what they want or need. In our opinion the PD measurement should be left to the qualified professionals, the opticians that have been taking these measurements with accuracy for hundreds of years and not to the Doctor who will undoubtedly take a rough estimate just to put something down on paper if it's required by law as their equipment is not designed for that precision in that area and the result will be consumers filling their already shoddy online eyewear with less than accurate measurements.