Submission Number: 560891-00076
Received: 7/30/2012 1:22:24 PM
Commenter: Beth Davidow
Organization: Animal Critical Care and Emergency Services
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
The Fairness to Pet Owners Act is not necessary and in fact will jeopardize many pets' lives. As opposed to physicians, veterinarians are educated and licensed to be the SOLE provider of pets' medical, dental, ophthalmological, and pharmacological needs. No other professionals receive training in these areas. Human pharmacists are not trained in species differences in drug metabolism and in many cases unaware of some of the drug interactions and problems that occur in cats and dogs but not in people. Pet owners already have the ability to receive a prescription from their veterinarian whenever they like, and frequently exercise this right presently. The explosive growth over the last several years of animal prescriptions filled online, speaks to the awareness and ease with which pet owners can presently obtain portable prescriptions from their veterinarian.This law is unnecessary, and will result in pet owners receiving inadequate or erroneous information from well intentioned pharmacists who have no training in the area of veterinary pharmacology. Veterinarians all receive extensive training in pharmacology, and provide invaluable information to pet owners, that cannot be provided by human pharmacists. This law will diminish the opportunities for veterinarians to properly educate pet owners about the risks, side effects and possible interactions associated with medications, thus placing their beloved pets at more risk. The more you remove veterinarians from the care of pets, the more problems which will be seen with drug reactions. This is well documented in the OTC market for parasiticals, where numerous reactions were seen in cats using OTC flea products. The inability of pets to verbalize when they are having a reaction makes the situation unique and unlike the contact lens industry. This law will hurt rather than help both pet owners and their pets. The law will also place an unfair administrative burden on veterinary practices when current policy already allows clients to receive a portable prescription, a fact that pet owners are well aware of.