Submission Number: 560891-00170
Received: 8/23/2012 7:22:28 PM
Commenter: Lindsay Mathre
Organization: Ingram Park Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Very few pharmacists have training in veterinary pharmacology. There are reports of human pharmacists adjusting medications, making substitutions, modifying dose, or instructions without first checking with the prescribing veterinarian. This can have life-threatening implications depending on the medication. Many drugs are veterinary specific, however there are many that are used in both human and veterinary medicine. What many pharmacists do not realize/have training in is that different species metabolize drugs differently, so you cannot expect to dose a dog the same as a human or cat or horse etc. HR 1406 leaves the liability for incorrectly filled prescriptions on the veterinarian, not the pharmacist, and this is an unjust thing that leaves patients open to improper medications as well as veterinarians open to increased time, hassle, and potentially unnecessary litigation. Unnecessary litigation will cause the costs of professional liability insurance to increase, causing significant price increases in services rendered in order to compensate for that increased cost, which will cause more people to stop bringing their pets to the vet for important preventative care as well as illness or emergency care. Some medications that are harmless to humans and sold over the counter, such as aspirin, Tylenol, ibuprofen, naproxen, pseudoephedrine, etc. can be deadly to veterinary species. When a suitable OTC medication is available, I will tell a client to go purchase it, what to purchase, warnings, and the dosage/frequency. I am concerned about the business practices of many internet pharmacies, in that some are not reputable and there have been reports of veterinary patients receiving counterfeit medications, which again can cause undue disease, suffering, etc. to my patients. For example, if a consumer thought they were giving heartworm preventative, but they were given expired, short dated, or counterfeit medication, then their pet would be at risk for contracting a heartworm infection, which is expensive to treat and has serious deleterious health implications for the pet as well as for the consumer. Most heartworm preventatives have activity against hookworms and roundworms, which have serious public health implications (especially for children). Veterinarians have the most knowledge about the dosage, administration, and metabolization of medications in veterinary species and are uniquely qualified to educate consumers as to what to expect with pet medications. Clients already have the option to ask for a written prescription to take to the pharmacy of their choice, and although it slows down business, it is part of my ethical duty to provide it to them and advise them accordingly. I do not charge for this, nor do I feel that it should be charged for. I feel that the further regulations that have been recently proposed on dispensing of medication to veterinary species, albeit with good intentions, will only cause more problems and less regular care for veterinary species, ultimately leading to more pain, suffering, and oftentimes more cost to the consumer in the long run. It is much easier to treat most diseases when diagnosed earlier rather than when they have progressed to the point of no return.