Submission Number: 560891-00056
Received: 7/26/2012 2:17:20 PM
Commenter: Avi Shaprut
Organization: Kearny Mesa Veterinary Center
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
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As a veterinarian it is often frustrating to see clients misled by many online companies that sell pet meds. These companies attract consumers with lower prices. However nowhere on their sites do they educate consumers as to the fact that the way they acquire these meds is through diversion from veterinary sources. Diversion of these meds to these companies invalidates any warranty the manufacturer has on these products.
For example, the company Elanco sent a letter to veterinarians to share with their clients that states it considers any of their Comfortis or Trifexis products purchased anywhere except through a veterinarian to be "counterfeit". This information is not made available to consumers of these online pharmacies.
Furthermore often times the products are acquired from foreign countries that are not held to FDA standards. This is both illegal and dangerous to pets.
Another common problem we see in fax requests for drug prescriptions and refills is the labeling "use as directed". Many of these drugs require specific tapering schedules. Often times deviations from specific dosage instructions can result in ineffective treatment or even severe toxic overdoses. But these pharmacies are content with the convenience of "use as directed". If they are imparted with the right to fill prescriptions they should have to verify the doctor's specific dosage instructions.
Avi Shaprut, DVM