Submission Number: 560891-00185
Received: 8/28/2012 11:52:32 AM
Commenter: Helen Roberts
Organization: 5 Corners Animal Hospital
State: New York
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
1. There is no evidence to support the need for requiring written prescriptions. I offer my clients the option and often give them a script without their requesting it. We have a pharmacy that offers free antibiotics, I write a script for those every day without being prompted for clients. They appreciate the effort.
2. It is inappropriate not to offer a liability waiver to the DVM if the client has a script filled elsewhere when the written script is mandated. The DVM has no control over the competency of the pharmacist or their staff. I have seen/see numerous errors by pharmacies on a regular basis when they fill prescriptions for animal patients. Dogs, cats, rabbits, reptiles, fish, etc. are not small humans-the physiology is different, metabolism of medications is different...I have seen pharmacists change doses, change the medications, and suggest the clients break FDA policy (extra label use issues)to give generics of medicines that are less effective and come with a higher risk of adverse effects.
3. Veterinarians will spend more time in order to fulfill these requirements, incur more staff expenses, and still be held accountable if the animal has a problem with medication the DVM had no control over the dispensing of. These costs will likely be passed on to consumers. As with other professions, veterinarians should be able to charge for their time if called about a medication problem (where they did not dispense). I currently do not charge for phone consultations but if the number of them increased, I would have to just to offset any potential income I lose by discussing problems arising from medications dispensed from an outside pharmacy. New York State provides free prescription pads to health professionals…the state costs will substantially increase due to increased printing and mailing costs of the prescription pads.
4. Clients are already getting counterfeit products from supposedly reputable online pharmacies for pets. I already have had some clients' animals develop problems with medication from these sources.
5. Veterinarians are best suited to offer guidance to clients on medical decisions including the use of prescription medications.
6. The FTC should not restrict or dictate a veterinarian's ability to practice properly. Especially when the suggested guidelines offer no support to the veterinarians if animals die due to poor dispensing practices, a lack of understanding of pharmacologic interactions among various species, and ignorance by a pharmacist.
7. The US government should not bow down to large corporations who want this bill to pass so they can generate millions of $ at the expense of pets and their owners.
8. Talk to colleagues in the FDA who deal with animal medications on a regular basis. They can offer insight into problem areas.