UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

In the Matter of

PROPOSED TRADE REGULATION

RULE CONCERNING THE

ADVERTISING OF OPHTHALMIC

GOODS AND SERVICES

[Proposed 16 CFR Part 456]

Public Record No. 215-52

STATEMENT OF CHARLES E. SEGER, O.D.,

ON BEHALF OF THE AMERICAN OPTOMETRIC ASSOCIATION

I am Dr. Charles Seger, a practicing optometrist in San

Luis Obispo, California.

I graduated with honors from the School of Optometry of the University of California in 1948. I served as President of the California Optometric Association in 1960-61 and as President of the American Optometric Association in 1964-65. I served as a member of the Council on Optometric Education, which is the accrediting body for all the schools and colleges of optometry in the United States and Canada, for a period of ten years--during eight of which I served as Chairman.

I am a Fellow of the American Academy of Optometry and a Diplomate of the Contact Lens section. I served as a member of the Commission appointed by the National Commission on Accrediting concerning the study by Robert J. Havighurst entitled Optometry:

Education for the Profession.

I also acted as a consultant to the New England Board of Higher Education on the study to establish a regional health science university in which William Selden was the Executive

Director.

I appreciate the opportunity to appear before the Federal Trade Commission and 1 am available to answer your questions

I. THE IMPORTANCE OF VISION

NEXT TO LIFE ITSELF, PERHAPS MAN'S MOST PRECIOUS POSSESSION

IS SIGHT.

To imagine a world without sight is almost incomprehensible to most of us. Yet, each year many thousands of Americans suffer an irreversible loss of vision. In addition, over 100 million Americans require the use of some form of visual aid to obtain proper visual performance. Unfortunately, many Americans take

good vision for granted and, if visual problems occur, give

little thought to the importance of a comprehensive visual examination and professional diagnosis and treatment.

Vision plays a significant role in all aspects of human endeavor. For example, vision problems can and frequently do interfere with the ability to learn. Many children suffer unnecessarily from the effects of vision problems which limit their ability to perform efficiently in classroom situations. Studies have shown that one of every four school age children requires some form of vision care. * In addition, many industrial accidents and hours of lost productivity probably occur each year because of vision problems. Inadequate vision may prevent workers from

* National Society For The Prevention Of Blindness, Estimated Statistics on Blindness and Vision Problems, New York, National Society for the Prevention of Blindness, 1966.

Also,

secing well enough to do their tasks or may cause a drain on human energy, fatigue and loss of attention and alertness. the importance of good vision to safe driving cannot be overestimated. It is impossible to estimate what factor inadequate vision may play in the thousands of traffic accidents, injuries and deaths yearly. Vision also plays a key role in our ability to enjoy sports and leisure activities.

It is clear that vision plays an important part in the lives of Americans, and that it affects an individual's ability to function and perform in society. Vision is a precious sense that can be properly maintained only through good health habits and regular professional vision care. The most important aspect about eye care is not the pair of glasses that may be dispensed, but the professional service which is rendered.

Vision is a complex skill. It involves not only the eyes but the brain as well. The eye is an extension of the central nervous system, and through various examinations and evaluations of the visual pathway, approximately 3,000 different entities can

be ascertained.

Vision's function is to get meaning, whether from a job at

the work bench or the reading of the simplest or most abstract material. The evaluation of this function is a complex task which

requires professional expertise and judgment. It involves more than just a determination of the refraction* of the eye. The eyes serve not only as "windows" of the brain but also the body. Many problems affecting general body function can be detected through a thorough examination of the health of the eyes. For example, such problems as hypertension and diabetes are often first detected through an examination of the internal structure of the eye. In addition, many potentially blinding conditions, such as glaucoma, cataract and retinal detachment, can be detected only through a careful examination. The examination of the eyes and the safeguarding of vision is not something that can be done

hastily or haphazardly.

Vision problems are among the most prevalent of all health problems in the population. These problems are considered chronic

in nature since few problems are ever completely outgrown or cured. Individuals requiring vision services at any one time are likely

to require attention for the rest of their lives.

"Man has had visual defects and ocular diseases for as long

a time as he has been on earth. Formerly, at various times different occupational groups arose to provide man with vision care. In

A refraction is a determination of the eyes' focus (refractive state). This involves the determination of the presence of nearsightedness, farsightedness or astigmatism.