Submission Number: 560891-00018
Received: 7/19/2012 10:30:16 PM
Commenter: David Eddleman
Organization: South Anderson Veterinary Clinic and Country Critters Vet. Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
To Whom It May Concern,
The Fairness to Pets legislation is exactly the opposite of its name. This legislation is only 'fair' to the pets if you consider that an owner must pay more for the services that are rendered to that pet. The requirement of printing and telling a client that they can go to another facility to fill the medications is simply foolish. This is like an auto mechanic finding a mojor brake problem and then telling them that they should go down the street to a "Midas" shop and have them put on the brakes.
Veterinarians understand the uniqueness of how different medications are metabolized by different species of animals. I asked my local licensed pharmacist what the dose and frequency of an OTC medication (Diphenhydramine) was and he said, "Doc, I have no idea. I have never been trained on how medications affect animals". This is an example of an OTC medication. What about a more potent/serious medication not to mention potential drug interactions that they have no training on?
I have on occasion given a written prescription. On one occasion, the pharmacist told my client that, "This medication should never be used on a dog!" This statement was completely in error, improper, undermined my authority, and called into question my ability to diagnosis and treat this pet. If we are required to tell clients that they should consider having the medications filled at another location...this may very well be a daily situation.
In addition to putting a pets' life on the line there is the additional burden placed on the veterinarian individually and his/her hospital of documentation and follow up to ensure that the owner actually did get the medication and was instructed properly from the pharmacist. The logistics of calling the pharmacy, follow-up phone calls, confirmation of receipt of the medication, etc. would simply be very burdensome and significantly increase the cost of practicing veterinary medicine. With this increase in cost, fewer owners would be able to afford treatment...so you tell me...what is fair to the animal about not being able to afford the beginning of treatment...a diagnosis ?!
Please, do not pass this legislation...for the sake of the pets that I treat on a daily basis.
Dr. David A. Eddleman