16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996 #00863

Submission Number:
00863
Commenter:
Rich Hoffman
State:
North Carolina
Initiative Name:
16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule): FTC Project No. R511996
Issued in 1978, the Rule helps promote competition in the eyeglass market by requiring optometrists and ophthalmologists to provide an eyeglass prescription to patients, at no extra cost, immediately after an eye examination is completed. This makes sense since the patient (Customer) should be able to purchase glasses where they chose and not feel compelled to purchase where they got examined. The issue arises when a requirement to provide measurements (PD's, etc.) for the eyewear. The eye exam (refraction) numbers are not part of the eyeglass manufacturing process and therefore are not needed during the exam. Actually, to include eyeglass manufacturing information (numbers) can lead to problems. PD's are only one part of the number needed to manufacture glasses. Allowing the patient to go where they want for glasses does not mean going on-line and expecting accuracy. Going where they want is to go to a brick and mortar optician and let the optician take ALL of the measurements needed to make their eyeglasses. You may ask then why can't the optician still provide all the measurements for the on line purchase? Aside from being unprofitable, it puts the optician in the loop of manufacturing and creates liability for the optician. In addition, without having the frame in hand, the optician will be unable to provide all the measurements needed to manufacture the glasses. So by assuming a PD is all that is needed to make eyeglasses is presumptuous, and in actuality, it is just enough information to get a pair of glasses made that may or may not be correct.