Submission Number: 560891-00195
Received: 8/28/2012 4:03:05 PM
Commenter: N. Joel Edwards
Organization: Retired veterinarian
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
The issue here should be patient safety, not the economics of medicating your pet. Medications should never be made available or administered to a pet without first having obtained a specific diagnosis and a treatment plan for that diagnosis from a licensed veterinarian who has examined the patient and who has a doctor-patient/client relationship.
Once those criteria have been met, where and how the client procures the recommended therapy should again be focused on patient safety, not on the cost of the product. Pharmaceutical companies and businesses supplying prescription and non prescription medications for pets should be made to comply with the same standards as if the medication was for human use.
Consumers have a right to choose were to purchase the recommended medications but it is not the responsibility of the veterinarian prescribing the medication to inform the client of all options for obtaining the prescribed medications, anymore so than one would expect their physcian to inform them of all options for purchasing their personal prescriptions.
Options for continuing treatments beyond the initial recommended treatment period should not be available to the consumer without consent by the veterinarian who made the original diagnosis and developed the treatment plan.
Pharmacies that are compounding veterinary pharmaceuticals for administration to pets should be held to the same standards as if the medication was being compounded for human use. If a prescription error is suspected the pharmacy should contact the prescribing veterinarian for verification of the medication, the strength, and the dosing interval.
Safety is the major issue here and it takes the cooperation of the veterinarian prescribing the medication, the manufacturer of the compound, and the entity dispensing the compound to insure the safety and efficacy of the product and it also requires the pet owner to follow the directions provided by the veterinarian for administration of the medication in question.