16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00862

Submission Number:
00862
Commenter:
Jenifer Ambler
State:
Vermont
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
I am concerned about three things in particular with respect to the Eyeglass Rule. One is prescription expiration dates. I believe that this should be at the discretion of the prescribing doctor, because there are many variables that could lead to valid reasons for certain expiration dates. For example, diabetics need to be examined at least once a year for vision and eye health changes, and severe or poorly controlled diabetics may need to be monitored even more often. At the very least, I feel eyeglass prescriptions should have expiration dates no longer than 2 years. Another issue is the PD (pupillary distance). This part of the proposed change in the rule is at the request of online eyeglass retailers. However, one simple PD measurement is only one component of multiple variables that can affect the fit and visual quality of a pair of eyeglasses. There are many other measurements, especially when fitting bifocals or progressive multifocal glasses, that also can not be accurately measured remotely. Mandating a PD on an eyeglass prescription is almost useless in the absence of a host of other information and measurements, all of which should be the responsibility of the seller of the materials, not the performer of the eye exam. The third is the almost nonexistent regulation of the online eyeglass sellers with regards to various state laws and ANSI standards. This especially applies to the sellers outside the U.S. I have seen children wearing eyeglasses purchased online that definitely did not meet impact resistance standards, for example. Some day, I fear a patient child's eye will be injured because a pair of glasses failed to protect sufficiently, and I certainly do not want to involved in the liability case that ensues.