Submission Number: 560891-00139
Received: 8/15/2012 1:58:13 PM
Commenter: Krissy Bussmann
Organization: Mt. Tabor Veterinary Care
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
My biggest concern about forcing this legislation upon veterinarians is that human pharmacists are not educated or prepared to discuss medications about veterinary patients. Animals have very different physiologic needs than humans, and it is dangerous to assume that human pharmacists are qualified to discuss these medications, doses, and potential interactions. There have been numerous anecdotal and documented instances of pharmacists taking it upon themselves to change dosages or even medication types because, based on their knowledge of human pharmacology, they thought the veterinarian must have made an error - all without contacting the veterinarian, and sometimes without even informing the client! Unless it becomes a requirement that pharmacists undergo ADEQUATE education about veterinary pharmacophysiology, then it is completely inappropriate, unethical, and medically dangerous to demand that veterinarians send all prescriptions to human pharmacies. Furthermore, it is my understanding that veterinary pharmaceutical companies do not directly sell their products to human chain pharmacies (anti-inflammatories and heartworm preventatives being the main price-shopped items). Therefore, any of these medications dispensed by an unauthorized source are considered illegitimate and forfeit the product safety/efficacy guarantees - and the client doesn't know this!! Please consider that the reason it's important to keep veterinary medications dispensed by the private clinic is NOT a financially motivated decision. It is for the safety of our patients!