Submission Number: 560891-00013
Received: 7/17/2012 12:11:57 PM
Commenter: Mark Brown
Organization: Central Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Restriction of free trade laws in the US are some of the most aggressive and restrictive in the world. Even in Canada similar laws are much less restrictive.
It is my opinion and the opinion of a growing number of people in our country that our federal government is entirely too intrusive into our personal lives as well as our businesses. Saying that let me comment on the FTC's engagement of veterinary client access to animal pharmaceuticals. Florida has a fair policy in place. It states that a veterinarian MUST provide a client with a prescription WHEN REQUESTED by the client. It doesn't require me to write a prescription for every animal medication I dispense or administer. I can think of several reasons why having to give a client a prescription is not a good idea. First, the pharmacies want to sell only the popular and profitable products and don't want to carry the less profitable items. Second, pharmacists are given no formal training on veterinary specific medications in pharmacy school and therefore could put our patients at risk when formulating prescriptions that they are unfamiliar with. Third, a patient may need immediate medication administered in a time sensitive situation that could be delayed by days or weeks when a client attempts to buy in an alternative setting. Walmart should not be dictating patient care. This should be patient care driven. Does the FTC regulate patient care?
Last, and possibly the most important with regard to cost incurred by the public when bringing their pets to a veterinary hospital. Dollars will have to continue to come in the business to pay for the cost of doing business. Aproximately 30%-35% of a typical veterinary hospitals gross income in derrived from inventory sales. If this drops to 10-15% than you will see a rise in service fees to make up for this change since the costs of business will remain the same. The FTC will be directly responsible for additional costs to clients to make up this loss. The public has only so much expendible income in general. You will have just added another layer of costs rather than doing what you think you are doing.
TRUE FREE MARKET SOCIETIES LET COMPETITION WORK THESE THINGS OUT ON THEIR OWN. WE HAVE LOST OUR WAY FROM THE 1780S.