Exhibit 5.1

                           Bausch & Lomb Incorporated
                             One Bausch & Lomb Place
                            Rochester, New York 14604



                                                               November 18, 2002
Bausch & Lomb Incorporated
One Bausch & Lomb Place
Rochester, New York  14604

         I am Senior Vice President and General Counsel of Bausch & Lomb
Incorporated, a New York Corporation (the "Company") and I am rendering this
opinion in connection with the Company's Registration Statement on Form S-3 No.
333-90468 (the "Registration Statement") filed on June 14, 2002 with the
Securities and Exchange Commission under the Securities Act of 1933, as amended
(the "Act") and effective on June 25, 2002 with respect to the Company's debt
securities (the "Debt Securities"), Warrants to Purchase Debt Securities,
preferred stock and common stock (the "Warrants"), Class A preferred stock, par
value $1.00 (the "Class A Preferred Stock"), and common stock, par value $.40
(the "Common Stock") and the Prospectus Supplement dated November 18, 2002, with
respect to the issuance of $150,000,000 the Company's 6.95% Senior Notes due
2007 (the "Notes").

         I, or attorneys under my supervision, have examined the form of
Indenture referred to in the Registration Statement between the Company and
Citibank, N.A. (the "Trustee"), dated as of September 1, 1991, as amended by
Supplemental Indenture No. 1; dated May 13, 1998; Supplemental Indenture No. 2,
dated July 29, 1998; and Supplemental Indenture No. 3, to be dated the closing
date of the sale of the Notes (the "Indenture") pursuant to which the Notes may
be issued, and I have examined such other documents and made such other
investigations as I have deemed necessary or advisable for purposes of this
opinion.

         Upon the basis of such examination and investigation, I am of the
opinion that:

         1.       The Company has been duly incorporated and is an existing
corporation in good standing under the laws of the State of New York.

         2. The execution and delivery of the Indenture by the Company and the
issuance and sale of the Notes have been validly authorized by all necessary
corporate action of the Company.

         3. When the Notes shall have been executed, authenticated and delivered
against payment therefore, the Notes shall constitute binding obligations of the
Company enforceable in accordance with their terms, except as enforceability may
be limited by bankruptcy, insolvency, reorganization or other laws relating to
or affecting creditors' rights generally and subject to general principles of
equity.




         I hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to me under the heading "Legal
Opinion" in the prospectus contained in the Registration Statement.


                                      Very truly yours,

                                      /s/ Robert B. Stiles
                                      ------------------------------
                                      Robert B. Stiles
                                      Senior Vice President and
                                      General Counsel