The proposed certification lacks the proper training and supervision to unsure patient safety. Laser is a surgical procedure and as such the teaching and supervision need to be done with experienced physicians.  The outlined education is very inadequate to insure patient safety.   There are always 2 part to surgery:  first the understanding of the procedure, testing of knowledge and understanding the risks and complications,  second the physical skills.  The optometrists must take classes, pass a written exam and demonstrate knowledge of the contraindications, complications, and appropriate post op care. The optometrist need direct supervision of more than 50 cases.  This is significantly less that ophthalmologist are required.  I have been doing laser treatment for glaucoma and cataracts for more than 30 years and this is not a skill easily performed.