Submission Number: 560891-00029
Received: 7/22/2012 7:58:47 PM
Commenter: Cullen Dauchy
Organization: Katy Veterinary Clinic
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
To whom this may concern:
My name is Cullen Dauchy, and I graduated from the College of Veterinary Medicine at Texas A & M University in 1971. Since that time, I have practiced at the location above, having owned the practice for 31 years; I sold the practice to my associate about 3.5 years ago. We have struggled with online pharmacies for many years, and I have several comments and opinions that I would like to share.
1. Our first concern as veterinarians should always be the safety and welfare of our patients; in short, we should always do what is best for the pet.
2. In consideration of point one above, my first concern regarding online pharmacies is the handling of the products, once the products arrive at the online pharmacies' storage facilities. For example, are the products stored in climate-controlled conditions, or do the temperatures reach 120 degrees in their buildings?
3. If products are purchased from online pharmacies, any guarantee of efficacy and protection from heartworm disease (in the case of heartworm preventatives) provided by the manufacturer is null and void, since the product was not purchased from a veterinarlian.
4. In most cases, online pharmacies fax a printed form requesting a prescription signature from a veterinarian on staff at our clinic, but many times, the product is sold to the client without a prescription.
5. I have no proof that prescription products, such as heartworm preventatives, are sold to these online pharmacies directly from the manufacturer; at least, no manufacturer has ever admitted same. I must assume, then, that these online pharmacies are purchasing the products directly from veterinarians like myself. If that is the case, and it is illegal for ethical pharmaceutical companies to be selling prescription pharmaceuticals to anyone except a veterinarian or veterinary clinic, why can't this practice be stopped?
6. As a result of number 5 above, I am compelled to call online pharmacies that acquire products for resale to pet owners as "bootleg pharmacies".
7. At Katy Veterinary Clinic, we refuse to sign prescription requests from online pharmacies for products that we carry (I have consulted with Chris Copeland, executive director and attorney of the Texas Veterinary Medical Association, and he assured me that we are not required to sign these prescription requests at this time). We will, however, price-match our products with the prices offered by these online pharmacies. Our reason for price-matching refers back to numbers one through three above.
8. If at some point we are required to sign prescription requests to online pharmacies, then we will have no choice but to increase our fees to cover lost revenue from the sale of products such as heartworm preventatives, flea control medications, and NSAIDS. I can only speak for Katy Veterinary Clinic: the markup of these products is minimal, and usually is very little above the price offered by online pharmacies. As we experience more and more government intervention and control in and of our lives, it would not surprise me at all if this requirement was enforced sooner or later. I'm just thankful that I'm in the winter of my career, and will retire in about two weeks.
Thank you for your time and consideration in reviewing my statements above.
Cullen M. Dauchy, DVM