Submission Number: 560891-00044
Received: 7/26/2012 10:15:50 AM
Commenter: Loreen Clark
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Prescriptions dispensed from veterinary hospitals require a great amount of veterinarian and staff time in ensuring correct drug, dosage, patient, and possible contraindications. To add the additional burden of also having to provide a written prescription for every drug would be absurd; especially if the client has no intention of getting the prescriptions filled off site.
Also, what prevents the owner from filling the prescription at both the veterinary hospital and off site? The owner can then stock pile drugs without veterinarian knowledge to use for other pets or to treat for prolonged periods when not warranted.
In addition, what if the prescription filled at both locations is a controlled drug such as phenobarbital for a patient with seizures or hydrocodone for a patient with collapsing trachea? These drugs are often abused by owners and providing clients with a written prescription in addition to what is dispensed from the hospital would increase the risk of human abuse. When veterinarians dispense these drugs the quantity is always verified to correspond to the patient’s dose and not refilled prior to the expected termination of the allotment.
Next, there is an increase number of mistakes made when prescriptions are “called in” to pharmacies due to communication errors. Therefore, the current recommendation is to provide a written prescription on paper for the client to give directly to the off site pharmacy. Providing paper prescriptions for every drug that is prescribed to a patient is not only wasteful of our natural resources, but increases the risk of the prescriptions being lost and potentially filled by someone other than the owner. Electronically filing prescriptions for the client is also burdensome in that clients are often unsure which pharmacy they want to use and then often change their mind afterwards. This leads to the client having prescriptions at multiple pharmacies and the ability to get a larger quantity of drug than what was intended to be dispensed.
In conclusion, simply requiring the veterinary hospital to post a notice stating that the client has a right to a written prescription instead of the medicines being dispensed at the hospital would prevent the client from obtaining double the amount of drugs, needless waste of veterinary and staff time and decrease the risk of drug misuse and abuse by owners.