Why the Healthcare Profession of the Physicist Does Not Apply to Opticians and Optometrists

By Giorgio Righetti

The debate on the recognition of the Optometrist has been animating our world since the establishment of the Italian Republic. Since 1991, the year in which I started working in the school for Opticians and Optometrists, the news that the Optometrist is supposedly about to be identified and placed among the regulated professions responsible for people's health and well-being periodically resurfaces. Whenever this occurs, the discussion inevitably shifts to who should be entitled to enter the proposed profession and who should not.

In the interest of full disclosure, I would like to state that the undersigned and IBZ have always supported the official recognition in Italy of the Optometrist, a profession capable of collaborating with the other healthcare and medical professions, starting with Ophthalmologists, and whose competencies are aligned with those defined by the World Council of Optometry.

In fact, in 2014, the Benigno Zaccagnini Institute partnered with Aston University to introduce the BSc in Optometry and Clinical Practice in Italy. The programme, delivered by Aston University's Department of Health and Life Sciences, was identical to the UK programme in terms of curriculum, clinical education and learning outcomes.

That being said, achieving official recognition of the Optometrist has become increasingly difficult over the years, largely because part of our own professional community has been unwilling to acknowledge what Optometry actually is, what competencies define it, and where it should be correctly positioned within the educational system.

The various attempts made over the years (all of which have ultimately failed!), which in the writer's view were fundamentally misguided, have been based on the idea of eliminating the Optician, a professional who has been supporting the Italian healthcare system free of charge since 1928, rather than on the introduction of a new professional figure who could expand the services available to citizens.

Among the many reasons for this situation, since 2018 there is Law No. 3 of 11 January 2018, commonly referred to as the “Lorenzin Reform”. Although this law did not define the professional competencies of the profession, it established the regulated Healthcare Profession of the Physicist, combining it with that of the Chemist. The legislation created Section A for holders of Master's Degrees and Section B — Junior Chemist and Junior Physicist — open to Bachelor's Degree graduates, including graduates in Optics and Optometry belonging to the Italian Bachelor's Degree Class L-30 (Physical Sciences and Technologies). More recently, Ministerial Ordinance No. 693 of 27 May 2026, issued by the Italian Ministry of University and Research, concluded the transitional phase by establishing that the State Examination is now the only route through which graduates in all Chemistry and Physics degree classes may access the Healthcare Profession.

This news has been misunderstood by many professionals within our field, including both current and former IBZ students, who interpreted it as meaning that the profession of Optometrist had been established and, at the same time, removed from Licensed Opticians who have been practicing Optometry competently and responsibly for many years. This misunderstanding stems partly from limited knowledge of the subject and partly from the way in which the information was communicated.

In reality, everything that has occurred since 2018 has changed nothing for either the Optician or the Optometrist. In fact, Optics and Optometry remain exactly where they have always been, that is, within the exclusive purview of the Licensed Optician, qualified under Article 140 of Royal Decree No. 1265 of 27 July 1934 (Consolidated Text of Healthcare Laws). The interpretation of the lawful scope of professional practice is based on the established case law of the Italian Supreme Court of Cassation.

To take stock of the issue and overcome the knowledge and information gap surrounding these developments, it is necessary to examine two key topics that are essential to understanding both the current situation and future developments:

• Healthcare Professions: Definition and Scope
• The Lorenzin Reform: Parties Affected and Its Implications

1. Healthcare Professions: Categories and Fields of Practice

When talking about 'Healthcare Professions', the majority of people think of professionals such as the doctor, who works on the patient-citizen, who prescribes and manages therapies, performs surgical procedures to cure and restore people's health.

In reality, the world of Italian healthcare professions is made up of the 31 regulated healthcare professions listed on the website of the Ministry of Health, and is far broader and more articulated. Furthermore, the Italian Ministry of Health recognizes other categories of healthcare professions, among which we find the Optician. The ones that possess autonomous diagnostic and therapeutic authority are only a few, belong to the medical area, and are namely the Physician, Dentist and Veterinarian.

Many of these healthcare professions perform support functions in the areas of diagnosis, treatment, prevention and rehabilitation as defined by the medical professions. These include professionals who work with patients, such as Nurses, Physiotherapists, Podiatrists, Speech and Language Therapists, Orthoptists and many others, as well as professionals who perform diagnostic examinations and technical analyses with or without direct patient interaction, including Radiographers, Orthopaedic Technicians and Biomedical Laboratory Technicians (who perform laboratory analysis).

Others contribute primarily to the protection of public health and have not been defined to fill clinical and therapeutic gaps left uncovered by other professions. They do not focus on the patient and their primary professional focus is the application of their scientific and technological knowledge. Among these are Biologists, Prevention Technicians in Environmental and Workplace Health, Chemists, and, since 2018, Physicists.

2. The Lorenzin Reform (Law No. 3 of 11 January 2018)

Law No. 3 of 11 January 2018, together with the Decree of the Italian Ministry of Health of 23 March 2018 established the regulated profession of the Physicist, associating it with that of the Chemist, created the corresponding Provincial Professional Orders, defined the registration procedures for eligible professionals and established the National Federation of the Orders of Chemists and Physicists (FNCF).

Furthermore, Article 1, paragraph 3 of the aforementioned Ministerial Decree established that each Provincial Order of Chemists and Physicists must include a Professional Register comprising “Section A – Chemistry” and “Section A – Physics” for holders of Master's Degrees, and “Section B – Chemistry” and “Section B – Physics” for holders of a Bachelor's Degree.

Naturally, there are significant professional differences between Section A and Section B of the two recognized professions. The main ones lie in the fact that professionals registered in Section B – Junior do not have a full professional level, do not have full responsibility, planning and decision-making autonomy, and often work in support of those registered in Section A.

Narrowing our focus to the field of Physics, professionals enrolled in Section A are entitled to use the professional title Physicist, whereas those enrolled in Section B are entitled to the title Junior Physicist.

Section A – Physicist

Eligibility for registration in Section A is open to holders of Master's Degrees belonging to the Italian degree classes LM-17 Physics, LM-58 Sciences of the Universe, LM-44 Mathematical-Physical Modelling for Engineering, together with equivalent qualifications awarded under previous university regulations. Each Italian university offers different Master's Degree programmes belonging to these degree classes, under different programme titles.

Section B – Junior Physicist           
          
All Bachelor's Degrees, not only the one in Optics and Optometry, belonging to the Italian L-30 Degree Class, other than the ex-L-25 together with former equivalent degree classes and recognised University Diplomas, provide access—subject to passing the National State Examination—to Section B – Junior Physicist.

Consequently, all graduates from Italian universities holding Bachelor's Degrees in Physics, Applied Physics, Physics and Astronomy, Complex Systems Physics, Materials Science, and many other programmes within the same degree class, are eligible for registration, and are entitled by law, to the same professional prerogatives in terms of competencies, activities, responsibilities and decision-making autonomy.

From this alone, one can understand the impossibility of a scenario in which, to give an example, an Astrophysicist or a Nuclear Physicist registered in the Order of Physicists could also practise as an Optometrist, taking that role away from the Licensed Optician!

Professional Competencies

Since 2018, although the transitional period has now ended and the Ministerial Ordinance of 27 May 2026 has established the dates and procedures for the National State Examination, the professional competencies of both Section A Physicists and Section B Junior Physicists have not been defined by law. Consequently, the National State Examination for Physicists will focus on broad disciplinary subjects which we will examine further in this article.

To date, the competencies have only been proposed by the FNCF (National Federation of the Orders of Chemists and Physicists) and by the Italian Ministry of Health to the Ministry of University and Research (formerly MIUR, now MUR), first in 2019 (the proposal is available on the FNCF website) and again in March 2026. The complete text of the most recent proposal has not yet been published, although it is certain that amendments have been made.

The competencies, listed below, if approved, would apply, as previously stated, to all professionals registered in Section B – Junior Physicist, not only to graduates in Optics and Optometry.

The following activities and the assumption of the related responsibilities fall within the scope of professional practice of professionals registered in Section B – Physics sector:

1. carrying out expert reports and professional assignments in pure and applied physics using standardised methods and procedures;
2. performing physical analyses of substances or materials of any origin using standardised methods and procedures for the qualitative or quantitative determination of the physical properties of matter and radiation, including the related validation, certification, expert opinions and classifications;
3. conducting physical analyses, assessments, studies and investigations relating to the conservation of artistic, cultural and environmental heritage using standardised methods and procedures;
4. directing laboratories carrying out the activities referred to in points b), c) and i);
5. providing consultancy services in the field of fire prevention;
6. providing consultancy and training in occupational health and safety concerning physical agents; acting as Health and Safety Officer (RSPP); and serving as Safety Coordinator during both the design and execution phases of projects;
7. carrying out measurements and analyses relating to noise, vibration, acoustic pollution, electric, magnetic and electromagnetic fields, light pollution, irradiation, lighting geometry, microclimate, hyperbaric environments and radionuclides;
8. programming and implementing software for measuring instruments and scientific equipment; managing computer networks for physical measurements and applied purposes;
9. designing, developing and using optical and optometric equipment, instrumentation and devices applied to vision science; carrying out optical and optometric analyses and investigations; identifying and designing optical aids to compensate for visual function deficits, aimed at the prevention and improvement of visual balance, including optical design;
10. designing, developing and implementing quality management systems and product quality analyses related to physical aspects of quality;
11. carrying out measurements, analyses, inspections and expert assessments relating to energy efficiency in buildings and industrial installations, including the relevant certifications;
12. preparing inventories and technical documentation relating to the physical aspects of industrial plants, pilot facilities and laboratories, particularly concerning finished products, semi-finished products and goods;
13. carrying out physical observations, measurements and simulations within forensic science using standardised methods and procedures;
14. providing radiation protection services relating to both ionising and non-ionising radiation, in compliance with current legislation governing professional authorisations.

The only competence directly connected to the Bachelor's Degree in Optics and Optometry, but that would apply equally to every Physicist registered in either Section A or Section B, is point 'i', highlighted in bold. It is evident that this competency does not define the profession of Optometrist (World Council of Optometry) or the Optician, nor is it attributed exclusively, nor does it include the possibility of manufacturing, supplying and selling ophthalmic medical devices to the public under the current Italian legal framework.

The National State Examination for Registration in the Order of Physicists, Section B

The State Examination for access to Section B – Junior Physicist is defined by Interministerial Decree No. 609 of 11 August 2025, which consists of an oral examination. Said Decree, at Article 4, point a), reads as follows:

4. The object of the examination, and of its assessment, is an oral discussion covering the following subject areas:
a) for Section B:

• professional legislation and professional ethics;
• measurement of physical quantities and related instruments and equipment;
• analysis and processing of experimental data;
• propagation of mechanical and acoustic waves;
• propagation of light and optical instrumentation;
• observation, analysis and simulation of mechanical, thermal and electromagnetic physical phenomena;
• energy efficiency.

Readers may judge for themselves whether these examination subjects are consistent with the knowledge and competencies required to practise as an Optician or an Optometrist.

Summary

The Lorenzin Reform, the establishment of the regulated Healthcare Profession of the Physicist, and the subsequent implementing decrees have made no contribution whatsoever to either the official recognition of the Optometrist or the consolidation of the Optician's professional role in Italy.

Graduates in Optics and Optometry who, after passing a National State Examination covering subjects that are not part of their university curriculum, become Junior Physicists, will benefit from the advantages typically associated with membership of a regulated professional order, beginning with access to the corresponding professional social security and pension system.

More than twenty-five years later – a quarter of a century – after the launch of the first Italian Bachelor's Degree in Optics and Optometry in Milan, our sector continues to rest invariably upon the figure of the Licensed Optician, educated and qualified through the Italian national and regional education systems. The professional qualification of Licensed Optician, awarded pursuant to Article 140 of Royal Decree No. 1265 of 27 July 1934, remains the only legally recognised qualification authorising the practice of the profession in Italy. Anyone wishing to practise must first obtain this qualification.