Submission Number: 560891-00015
Received: 7/17/2012 5:13:59 PM
Commenter: Kate Zimmerman
Organization: Tri-County Veterinary Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As a long time practicing veterinarian, I have several grave concerns about the theorized "expansion" of availability and free trade issues of pet prescriptions. Pets are not a commodity to be exploited. They are living creatures and their safety and right to appropriate care MUST trump "market pressures". We are not discussing a car or similar object. Consumers certainly have the right to purchase car parts from wherever they chose - some will chose quality product and others will chose cheap product and the vehicle will run (or fail to) accordingly. However, when it comes to the care of a living creature, placing "market pressures" and "consumer price" and "competition" above the inherent responsibilities we have to its welfare is simply unacceptable. It also gives strong credence to the argument that this whole debate is based on greed, not animal welfare.
To summarize my other concerns:
1. I have repeated personal experience with human pharmacists, who know nothing about veterinary pharmacology, altering or changing prescriptions for my patients, which, in some cases, has seriously endangered my patients and in others has promoted antibiotic resistance. There is no way for a consumer to verify the safety or efficacy of medications received in this fashion. They tend to trust the pharmacist actually did as the prescription was written. This, too often, is not the case. Since we don't see these pets until days or weeks later, irrevocable harm can be done because we have no way of verifying outside prescriptions. In house prescriptions use sources verified by me and filling those scripts requires a triple crosscheck to help prevent accidents or mistakes.This doesn't happen in Internet or box chains.
2. The large chains (box store or internet) do nothing to assure that the products that they sell are not counterfeit - the FDA has even issued warnings at our national conferences about counterfeiting of pet heartworm, flea and tick medications - a highly profitable enterprise. Since it's admitted that many rely on "diversion" as a source of their product, I don't see any way to guarantee the safety of the product and therefore the safety of the pet. Furthermore, consumers have no way of identifying sources of product in these situations - I can tell a client my product came direct shipped from Novartis, Bayer, etc. The Internet and box stores don't have the same guarantees of a direct supply of product. This endangers both the pet, and in some cases (topical product) may endanger human health.
3. The prohibition of HR 1406 to permit veterinarians to charge for prescriptions seems to me to be a violation of OUR right of free trade. So many seem concerned whether the option of free market profit is allowed to the chain stores. Why do we not have the same rights to “make a profit”? Unlike the stores, we have invested significant time and education to know WHAT prescriptions to write and how to track side effects, drug interactions, etc. The chain stores do no such thing and don't even discuss potential side effects with owners, thereby jeopardizing animal health. To say we don't have the right to charge for such services seems excessively prejudicial.
In my hospital we provide prescriptions to owners at no charge upon request in an effort to assist clients with cheaper alternatives. However, some medications are risky, dangerous, have significant side effects and/or require special considerations during administration - or there is no human equivalent. I can not support release of these products unless it is under my direct control. I don't see how consumers can be protected by taking the veterinarian out of the equation in the name of better profit for big business at the real risk of inducing health issues in a living creature. Safety of our pets MUST trump profit motives and the proposed bill will only benefit corporate bottom line, not the animals we are charged with caring for.