Submission Number: 560891-00093
Received: 8/1/2012 12:14:16 PM
Commenter: Cathy Goelz
Organization: Animal Emergency Clinic
State: South Carolina
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I have been working as a veterinary technician in small animal emergency medicine for 15 years. I have also been a pet owner for most of my life. I can empathize with the viewpoints of both a veterinary practitioner and a consumer on a tight budget.
While I am in favor of free enterprise and competitive pricing for medications, I also have some very serious concerns.
First, I do not feel that a human pharmacist can provide accurate information to pet owners regarding their prescription. Humans and different species of animals do not metabolize drugs in the same way. For instance, acetaminophen (Tylenol) cannot be metabolized by cats and may be fatal. I personally have encountered more than one experience of calling in a prescription to a human pharmacy for hydrocodone and homatropine, but the client received hydrocodone and acetaminophen. If the error was not caught by our staff, it could have been fatal for the dogs. A huge part of drug dispensing is also conveying side effects and possible drug interactions. A human pharmacist is not trained in veterinary pharmacology, plain and simple. Many of the drug properties and drug interactions may be similar, but animals are not a different breed of human.
A human pharmacist will not be able to adequately answer drug dispensing questions either. As a veterinary technician, I am frequently asked the "trick" of giving an aggressive dog or fractious cat a pill. There are definite techniques that must be learned with experience. In addition, a veterinary professional knows about an animal's dietary constraints. Giving a pill wrapped in a piece of ham could result in a mild gastroenteritis or even pancreatitis.
Another potentially problematic area involves the drug itself. After dispensing a medication and reviewing the drug with the client, the client has concerns. Such concerns may involve the cost of the drug or administration of the drug. For instance, a client may realize that they will never be able to pill their outdoor cat twice daily, or that giving their dog a pill three times a day is not feasible. The size of the pill may also be a concern, as well as the cost. In these cases, the veterinarian may need to adjust the dosage so that the client can administer the drug twice daily instead of three times daily. The cat may be a better candidate for a long acting injectable antibiotic, rather than dispensing pills. An owner may feel more comfortable with liquid rather than pills. The medication may need to be changed completely to accommodate the needs of an owner.
For all of these reasons and several more, I feel very strongly that prescriptions need to be dispensed by a licensed veterinarian. Simply put, an animal is not a human;a human who lacks the necessary training in veterinary pharmacology should not be dispensing medications for an animal. Would you want a veterinarian who is not trained in human pharmacology dispensing YOUR medications?
Thank you for your consideration.