Submission Number: 560891-00020
Received: 7/20/2012 7:23:01 AM
Commenter: Carolyn Fisher
Organization: Suburban Animal Hospital
State: New York
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
My concerns with this initiative are as follows:
Veterinarians are highly trained and educated (8 or more years of education plus ongoing CE). We are best able to understand how medications affect and are best for our patients. Large stores/ pharmacies/Internet pharmacies are only interested in the sale of the product to consumers not patient health.This is currently evidenced in many ways including advertising that directs them away from their veterinarian, sending unsolicited fax requests for medications without a valid prescription, and selling diverted/counterfeit products to consumers. I also don't believe that the majority of pharmacists have adequate training or expertise in animal pharmacology and veterinary medicine to provide necessary support to consumers. I have had the experience of having pharmacists tell clients that the dosage of a medication that I prescribed was going to harm their pet when in fact it was a very appropriate dose.
There are already measures in place to allow consumers to choose where they purchase medications for their pets. In NY we are required to provide a prescription to consumers on request. This happens on a daily basis at my practice. Decision making for prescription medications comes from a collaboration between the pet owner and veterinarian who has an understanding of the health of that individual patient. It does not come from a sign in a store or an advertisement on television. Additionally, we will stand behind the products that we sell to consumers and give them the support needed should there be an adverse reaction.