Submission Number: 560891-00117
Received: 8/6/2012 12:36:19 AM
Commenter: Kenneth May
Organization: Private Veterinarian
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
While most prescriptions are being filled by the prescribing veterinary clinic, and it does add to the income and profitability of veterinary practices, it primarily serves the safety of the pet owning public. Most medications prescribed for pets are not carried by retail pharmacies. Of the few that are available, most are not in the proper sizes for small pets. Pharmaceutical companies serving the veterinary market provide the medications in dosage sizes suitable to the wide range of weights and various species seen in veterinary practices. Even with the wide variety of sizes and forms ( tablet, liquid, flavored, chewable ) of medications produced, virtually all practices find it necessary to have some medications specifically formulated ( by compounding pharmacies ) for several of our patients.
The biggest and most important reason that this change should not be allowed is that pharmacists have NO TRAINING in how these medications are used in the many and varied species we treat! In the 25 years that I have been practicing veterinary medicine, on many occasions, when I have specifically needed to write a prescription to a human pharmacy, the pharmacist has called to question the prescription. The reason for each call was that the pharmacist was not familiar with the usage of this medication in animals,( it is common that some of the medications we prescribe are used for different and sometimes opposite conditions in an animal than the same medication is used to treat in humans! ). Some medications are used at more than 10 times the dosage for a human with the same condition. In these instances, I've been impressed that a pharmacist recognized and took the time to check the validity of my prescription, but it also reinforces the fact that they are trained in the usages, dosages, and chemistry in the human body-- not the various species that we are trained to treat. In the same manner in which human physicians are limited to practice on humans, and veterinarians are limited from practicing on humans, it makes sense that those same restrictions should follow to the prescriptions written for treatment of those respective species.
While many of the large, national retail pharmacy companies are pushing for a change in the way (place) that prescriptions are sold, this change amounts to nothing more than them looking for a way to capture a new market segment. The pharmacies would love to capture the market for the most prescribed medications, and could probably profit well from those that they can purchase in much larger quantity than any individual clinic can buy, but are they then willing and able to provide the sizes and variety of medications required to serve ALL pets in all communities? Additionally, most clients asked, prefer to have their prescription filled while at the practice, and not have to make another stop and wait for it to be filled.