Submission Number: 560891-00111
Received: 8/2/2012 10:28:24 PM
Commenter: Jeffrey Wittman
Organization: Sierra Veterinary Care
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I think the most concerning issue here is patient safety. As a veterinarian I was concerned when local pharmacists came to me explaining their concern about having to dispense veterinary products. One worked for WalMart and the other SaveMart. These pharmacists stated that they were being forced to prescribe medication and the one who worked for Walmart stated he had mandatory "quotos" of veterinary prescriptions he had to fill each month.
Both stated that they have NO training in veterinary pharmacology and that they are HUMAN pharmacists. They felt that they were being forced into an ethical compromise because of the potential profit that corporate sees. The whole purpose of pharmacists is to have someone who is trained in human pharmacology to safely prescribe medications to a human patient and to minimize pharmaceutical contraindications, adverse reactions and drug interactions. Having a human pharmacist dispense veterinary pharmaceuticals is akin to having the local M.D. do surgery on the family dog. He/She does not know the anatomy, recognize species specific medical differences, and most importantly how drugs are metabolized differently in EVERY species (i.e. why Tylenol kills cats!). I have no problem writing a prescription to have medication filled elsewhere for my patient. My only concern is how the human pharmacist can honestly compare to my knowledge and expertise on animal pharmacology. I believe human pharmacies should be banned from prescribing veterinary pharmaceuticals unless they have a veterinary pharmocologist or veterinary pharmacist on staff.
I have asked my clients routinely about the prescription issue and have offered to clients where they would like the prescription filled. The overwhelming majority (greater than 98%) want me to fill the prescription. When I ask my clients why, the overwhelming majority again state convenience, followed by the concern of accuracy and safety. Price is of very little concern. I personally believe this issue is before the FTC because WalMart, not the consumer, is concerned about this issue. Their concern is not for the patient nor for my client.......it is for their corporate profits and greed. To accuse our profession of protecting profits shows the ignorance of who the overwhelming majority of veterinarians are. There is a reason my profession is consistently ranked my consumers as the MOST respected profession. It is because none of us went into veterinary practice to get wealthy, look at our compensation compared to other doctors. Veterinarians do the work we do because we love our profession and our patients first! We did not chose this profession based on compensation, we chose it based on love. As always there are some exceptions, however, I will state they are extremely rare in my profession. If the FTC cares about the consumer they will put patient safety over "potential" savings. The FTC should also recommend that human pharmacists obtain veterinary certification to dispense veterinary pharmaceuticals. It is the correct ethical decision to make.
Dr. Jeff Wittman