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Thread: Comment Request Ophthalmic Practice Rule (Eyeglass Rule)

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    Blue Jumper Comment Request Ophthalmic Practice Rule (Eyeglass Rule)

    They received 537 comment over the last 24 days, just see for yourself.

    also
    check the links right under the main title below as 1, and 2


    FEDERAL TRADE COMMISSION

    Protecting Americas Consumer

    1. Policy »
    2. Public Comments »
    3. #624: 16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule)
    #624: 16 CFR Part 456 ; Agency Information Collection Activities: Review; Comment Request Ophthalmic Practice Rule (Eyeglass Rule)
    MATTER NUMBER:
    R511996
    RELATED FEDERAL REGISTER NOTICE:
    16 CFR Part 456: Ophthalmic Practice Rules (Eyeglass Rule); Advance Notice of Proposed Rulemaking; Request for Comment (September 3, 2015)


    COMMENTS (copied today) click on links

    1.J FRANKLIN HOWELL - Oct 19, 2015 #00554
    2.Summerville - Oct 19, 2015 #00551
    3.Harold Valentine - Oct 19, 2015 #00555
    4.Shahyan Madhani - Oct 19, 2015 #00552
    5.Andrea Kuchinski - Oct 19, 2015 #00553
    6.Maayan Shuval - Oct 18, 2015 #00550
    7.Nicholas - Oct 17, 2015 #00549
    8.MARIANNA SIMOES - Oct 16, 2015 #00546
    9.Farzam Kamel - Oct 16, 2015 #00547
    10.Hugh Cooper - Oct 16, 2015 #00548
    11.William Beck - Oct 15, 2015 #00543
    12.Suzie Betuk - Oct 15, 2015 #00544
    13.Emily Palmquist - Oct 15, 2015 #00545
    14.James Bookhamer - Oct 14, 2015 #00538
    15.Scott Schultz - Oct 14, 2015 #00542
    16.Schutz - Oct 14, 2015 #00535
    17.Andrew Orsi - Oct 14, 2015 #00539
    18.christine tranchina - Oct 14, 2015 #00536
    19.Hartley Bonisteel Schweitzer -
    Oct 14, 2015 #00540
    20.Amy Moschell - Oct 14, 2015 #00537
    21.St. Mary - Oct 14, 2015 #00541
    22.Timothy Rancourt - Oct 13, 2015 #00530
    23.Brenes - Oct 13, 2015 #00534

    24.S Pauly - Oct 13, 2015 #00531
    25.jason block - Oct 13, 2015 #00528
    26.Laurie Osmond - Oct 13, 2015 #00532
    27.Kirsten Bhattacharyya -
    Oct 13, 2015 #00529
    28.Darlene Bhattacharyya - Oct 13, 2015 #00533
    29.Vaughn Buntain - Oct 12, 2015 #00514
    30.PHILIP JAMESON - Oct 12, 2015 #00518
    31.Leatherman - Oct 12, 2015 #00522
    32.Romanoff - Oct 12, 2015 #00526
    .
    .
    .
    .
    see more up to last one at


    • 537 Debnam - Sep 2, 2015 #00003


    see all of it:
    ==========>
    https://www.ftc.gov/policy/public-co...initiative-624






    Last edited by Chris Ryser; 10-24-2015 at 05:41 AM.
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    Interesting! I read my senator's response (Chuck Schumer), and also Barry's response, and about 24 others. Many of the responses from around the country are obviously bogus, but a large number of responses seem to be from legitimate consumers. I don't think we should run screaming into the streets yelling "we're all gonna die!" Instead, it's an opportunity for the optical industry to re-invent itself.
    Lost and confused in an optical wonderland!

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    Blue Jumper opportunity for the optical industry to re-invent itself....................

    Quote Originally Posted by SharonB View Post

    Interesting! I read my senator's response (Chuck Schumer), and also Barry's response, and about 24 others. Many of the responses from around the country are obviously bogus, but a large number of responses seem to be from legitimate consumers. I don't think we should run screaming into the streets yelling "we're all gonna die!" Instead, it's an opportunity for the optical industry to re-invent itself.
    Thank you Sharon. You just about said it in your last sentence. I hope that people start slowly to wake up to discuss that re-invention and maybe even profit from a coming change.
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    You do realize that just because a bill is proposed, it doesn't automatically come to pass, right? This concept that it is inevitable is why other people have to carry the load. Don't be a bystander or a victim, be a doer, but only if you do the right thing.

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    Redhot Jumper You want to fight them these days ................

    Quote Originally Posted by Tigerclaw View Post

    You do realize that just because a bill is proposed, it doesn't automatically come to pass, right? This concept that it is inevitable is why other people have to carry the load. Don't be a bystander or a victim, be a doer, but only if you do the right thing.
    Right........... I have never been a bystander, by actively warning that the internet online opticals were out to bury the conventional eyeglass retailer,
    just by pricing their products for close to 10 years, at the wholesale level, right here on OptiBoard.

    There is no way that anybody can restrict the sale of Rx glasses on the internet after having let them them loose in space. The largest and most successful ones are now operated and owned by the worlds largest two optical corporations in this field. They did not get to that stage by being stupid, they are now, and are well on the way on a international basis with internet based optical retail sales.

    This year they will have sold 23 to 24 million pairs of glasses combined between all online opticals, all glasses that we did not sell. The projection for 2016 is to reach 27 million pair.
    These are all sales that where not sold at the retail end.

    You want to fight them these days you would have to change your pricing to the same level, and charge for hands on service "a la carte".
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    So your position is we can't get laws passed that stop their sales, and that we must bow down to new laws that fill in the gaps in service that online sales can't fill, but that we can just magically lower prices? Seriously, how much profit do you think we make? Maybe we should start by cutting payroll. If a dummy on a computer can fit glasses then surely we can get dummies to replace the opticians for minimum wage. Why not start there?

    If the companies that sell us our parts are the ones who compete with us online, how does cutting the prices of the lenses help us? They can ALWAYS be cheaper. Frames for most lines I have dealt with are set a minimum retail price. We still have to pay rent, pay off loans, equipment, etc. That idea of yours and of a few others (who quite frankly should know better) that doctors can always just cut prices is quite frankly naive and bordering on childish.

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    Chris, I think all the negativity about this boils down to one thing: metathesiophobia.

    There are some who are too heavily invested in their profit structure to think outside the box, and they seem to be the ones who are shouting the loudest against changing the status quo. The only problem is that the status quo changed long ago. It reminds me of the old story of of King Canute.

    he commanded that his chair should be set on the shore, when the tide began to rise. And then he spoke to the rising sea saying “You are part of my dominion, and the ground that I am seated upon is mine, nor has anyone disobeyed my orders with impunity. Therefore, I order you not to rise onto my land, nor to wet the clothes or body of your Lord”. But the sea carried on rising as usual without any reverence for his person, and soaked his feet and legs. Then he moving away said: “All the inhabitants of the world should know that the power of kings is vain and trivial, and that none is worthy the name of king but He whose command the heaven, earth and sea obey by eternal laws”.

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    Sorry, if you are powerless to do anything then feel free to move your chair. Tides are inevitable; Congress is not. They can require PD's, and they can remove the Eyeglass Rule (which they SHOULD). Good to see who is conditioned to bow to the whims of a few people in charged and who is not.

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    Redhot Jumper is quite frankly naive and bordering on childish.................................

    Quote Originally Posted by Tigerclaw View Post

    We still have to pay rent, pay off loans, equipment, etc. That idea of yours and of a few others (who quite frankly should know better) that doctors can always just cut prices is quite frankly naive and bordering on childish.
    Thank you for the compliment.

    Just find a better formula than mine without counting on any government to save your extra income derived from optical sales besides being a OD doctor.

    How can you stop the Essilor online business that originates in Vancouver which is next door and not even in the USA, or others that finish the Glasses in China.

    The internet is a free for all as long as you pay the service provider. I am just trying to throw some ideas on the table that might just work, and are open for discussion.

    The consumer is also not stupid and shops for better prices, which will have to come down in nearly every field that is attacked by these newly emerging companies or there will be some professional funerals.
    Chris Ryser
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    Redhot Jumper The persistent, abnormal, and unwarranted fear of change.

    Quote Originally Posted by MikeAurelius View Post

    Chris, I think all the negativity about this boils down to one thing: metathesiophobia.

    There are some who are too heavily invested in their profit structure to think outside the box, and they seem to be the ones who are shouting the loudest against changing the status quo. The only problem is that the status quo changed long ago. It reminds me of the old story of of King Canute.

    You are very right Mike.
    I had to check that word because I never even heard of it it before


    Metathesiophobia (noun) - The persistent, abnormal, and unwarranted fear of change. Symptoms usually include shortness of breath, rapid breathing, sweating, nausea, irregular heartbeat, and overall feelings of dread.
    I have been around for a while and know the optical business in every angle, from the retail end to owning optical labs and manufacturing.

    However this avalanche that is threatening the professional optical retail has become irreversible and will soon fill the bottom of the valley. Anybody that is not changing the location will be buried in the snow.

    23-24 million pairs of glasses sold this year and expecting sales of 27 million for next year while more people get older and are in need for them.

    My formula might not be perfect but it makes sense to lower prices and and charge for service instead, which can also be applied for products purchased elsewhere.
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    Quote Originally Posted by Chris Ryser View Post
    Thank you for the compliment.

    Just find a better formula than mine without counting on any government to save your extra income derived from optical sales besides being a OD doctor.

    How can you stop the Essilor online business that originates in Vancouver which is next door and not even in the USA, or others that finish the Glasses in China.

    The internet is a free for all as long as you pay the service provider. I am just trying to throw some ideas on the table that might just work, and are open for discussion.

    The consumer is also not stupid and shops for better prices, which will have to come down in nearly every field that is attacked by these newly emerging companies or there will be some professional funerals.
    The FDA already regulates glasses. Imported glasses won't make it through customs without permits, which would be denied. And yes, many consumers ARE stupid. That's why we have laws, licenses, and threads dedicated to entertaining ourselves with the stupidity of consumers.

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    "Don't fight, just lay back and take it. Can't figure out why you can't cut your prices... of course, I've never run a business or given it much thought..."

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    Quote Originally Posted by Tigerclaw View Post
    Sorry, if you are powerless to do anything then feel free to move your chair. Tides are inevitable; Congress is not. They can require PD's, and they can remove the Eyeglass Rule (which they SHOULD). Good to see who is conditioned to bow to the whims of a few people in charged and who is not.
    Wait, why do you want Congress to do something about this? Haven't you been complaining that it's unconstitutional? Now you want Congress to fix something that was brought about by your own industry? Good luck with that. Congress can't even seem to pass a highway funding bill.

    In the story, replace the word sea with the word internet. You will drown if you don't move your chair.

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    Quote Originally Posted by Tigerclaw View Post
    The FDA already regulates glasses. Imported glasses won't make it through customs without permits, which would be denied. And yes, many consumers ARE stupid. That's why we have laws, licenses, and threads dedicated to entertaining ourselves with the stupidity of consumers.
    Except that they don't. The FDA doesn't have the manpower to regulate spectacle manufacturing, or didn't you read my post on that?

    I wonder how many Houstonite consumers have read your comment calling them 'stupid'.

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    Redhot Jumper Imported glasses won't make it through customs without permits

    Quote Originally Posted by Tigerclaw View Post

    The FDA already regulates glasses. Imported glasses won't make it through customs without permits, which would be denied. And yes, many consumers ARE stupid. That's why we have laws, licenses, and threads dedicated to entertaining ourselves with the stupidity of consumers.
    There are lots of finished glasses coming in now, and I have not seen the FDA blocking any of them lately.

    You saying that there are 23-24 million people that are stupid now, and the amount will grow to 27 million next year ?

    If it increases by 10% a year, you can even figure out when the whole population will turn that way, no licenses applied and whatever was stated.
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    Actually I want Congress to do what IS constitutional: remove the unconstitutional laws - problem solved. In the absence of that, they at least need to do something right. Regulating the importation of medical devices IS constitutional.

    And no, the internet is not the sea, despite all you anti-optometry sadists who think "muh internet" is going to fix your problems with us doing the right thing.

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    Quote Originally Posted by Chris Ryser View Post
    There are lots of finished glasses coming in now, and I have not seen the FDA blocking any of them lately.

    You saying that there are 23-24 million people that are stupid now, and the amount will grow to 27 million next year ?

    If it increases by 10% a year, you can even figure out when the whole population will turn that way, no licenses applied and whatever was stated.
    The people exporting frames/finished spectacles into the US have permission. If we made online sales illegal, then the permits would be denied.

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    Quote Originally Posted by Tigerclaw View Post
    Actually I want Congress to do what IS constitutional: remove the unconstitutional laws - problem solved. In the absence of that, they at least need to do something right. Regulating the importation of medical devices IS constitutional.

    And no, the internet is not the sea, despite all you anti-optometry sadists who think "muh internet" is going to fix your problems with us doing the right thing.
    As I wrote when you started this whole business, the FTC rules are consistent with its constitutional mission, and its *RULES* (not laws, btw), are completely constitutional, despite your claims to the contrary.

    Oh, yeah, no matter how much you scream and shout, the tide of the internet rolls inexorably on and upwards, drowning those who refuse to build a boat.

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    Quote Originally Posted by Tigerclaw View Post
    The people exporting frames/finished spectacles into the US have permission. If we made online sales illegal, then the permits would be denied.
    Yeah, good luck with that. It will *NEVER* happen. What's next? Banning internet sales of books that don't meet the Texas Educational Book decrees? Once you start down the slippery slope of banning, you can never stop, you just slide deeper and deeper, banning more and more things you don't agree with.

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    Quote Originally Posted by MikeAurelius View Post
    As I wrote when you started this whole business, the FTC rules are consistent with its constitutional mission, and its *RULES* (not laws, btw), are completely constitutional, despite your claims to the contrary.

    Oh, yeah, no matter how much you scream and shout, the tide of the internet rolls inexorably on and upwards, drowning those who refuse to build a boat.
    Actually, they aren't constitutional. I didn't realize you were a constitutional scholar and that your best guess had the effect of law, but I spoke with a couple of lawyer friends and the consensus was no, it's no constitutional, but good luck fighting it alone, you should get your association to pursue it unless you have really deep pockets. Guess it goes to show that you feeling strongly about something doesn't make it true. Hate to be the one to break it to you.

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    Quote Originally Posted by MikeAurelius View Post
    Yeah, good luck with that. It will *NEVER* happen. What's next? Banning internet sales of books that don't meet the Texas Educational Book decrees? Once you start down the slippery slope of banning, you can never stop, you just slide deeper and deeper, banning more and more things you don't agree with.
    Banning medical device sales online is nothing new, and hardly in the "slippery slope" realm of censorship. Geez, give it a rest...

    You can't even sell medical devices on eBay without FDA approval.

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    **rolling on the floor with laughter**

    Thanks for today's laugh. It's been fun.

    Ok, let's just say that the constitutionality of the rules have never been tested. However, based on the literally hundreds of rules that the FTC has issued over the many years it has been in existence, it is highly doubtful this particular rule would be found unconstitutional, given the large number of consumer complaints on the subject the FTC has received. That's EXACTLY the reason the rule was put into place in the first place over 20+ years ago.

    Consumers already don't trust the OD/MD to give them a fair shake on eyewear prices, and you want to roll back the freedom of purchase they've had for 20+ years? It will never happen. Even if, by some wild crazy insane case where a Republican is elected President along with a majority in both houses of Congress. And I would bet $20 and a case of really good beer on it.

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    Guess you know about as much about the 2016 polls as you do about what's good for the patients. ;-)

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    Quote Originally Posted by Tigerclaw View Post
    Banning medical device sales online is nothing new, and hardly in the "slippery slope" realm of censorship. Geez, give it a rest...

    You can't even sell medical devices on eBay without FDA approval.
    Who says? Oxygen concentrators, for sale on eBay. Eyeglass frames, for sale on eBay. I could go on, but on the very face of it, that's an incorrect statement.

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    Quote Originally Posted by Tigerclaw View Post
    Guess you know about as much about the 2016 polls as you do about what's good for the patients. ;-)
    I read Nate Silverman at fivethiryeight.com, that alone should tell you how much I know about polling.

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