Submission Number: 560891-00201
Received: 8/29/2012 2:07:21 PM
Commenter: Robin Sturtz
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
This proposed legislation, while on the surface seeming to protect the consumer, actually will lead to diminished care of veterinary patients and unnecessary distress for their human family.
In no other field does one professional have the right to supersede the professional judgement of another. With the requirements pharmacists have to make clients aware of generic or brand medications, the client will be faced with recommendations from someone who has little or no training in veterinary pharmaceuticals. A client who is made to sign a form saying that they know they can go elsewhere is naturally going to feel that they should.
Companion animals are not little furry people. Their medications, doses, and methods of giving the drug are far different from those of humans. There have already been cases where a pharmacist has informed a person that the dosage for a veterinary medication is "too high." Some medications must be given in liquid or transdermal form, unlike their use in humans.
Why does this matter? When veterinarians are required to tell a client that they MUST accept a prescription, and that they could get the drug elsewhere, the implication is that it would be preferable (i.e., cheaper) to go elsewhere. Once this happens, the client goes out of our control, to a professional who is trained only in human medicine. Some states have proposed an "add-on" training session of several weeks' duration. As opposed to the years of training they get in human medicine, this is unfair to veterinary patients.
The other problem involves recognition of side-effects and drug usages, with which pharmacists are unfamiliar. Unlike in human medicine, many veterinary drugs are permitted to be used off-label. We do not want to face the specter of the client returning to us telling us that the pharmacist was unwilling to dispense the medication because it did not fit the labelled usage. Or worse, the client calling the pharmacist regarding unexpected patient reactions, and having them be given wrong advice.
The liability risk is considerable. While the medication is dispensed by someone else, it is the veterinarian who will be held liable for any errors or unfortunate effects. This is true in human medicine, but in human medicine the doctor is working with a trained pharmacy professional; veterinarians would not have that luxury.
A related issue is that of compounding. The rules for compounding medications are quite different in veterinary and human medicine. In addition, a pharmacist may use a compounding corporation that does not have experience sufficient to produce a veterinary-quality grade of medication.
There have already been incidents where a pharmacist has made changes or commented on the quality of prescriptions written by veterinarians without checking with the veterinarian. There are still individuals, professionally trained, who do not recognize that veterinary medicine is as much a medical science as human medicine.
This comment is not meant to disparage pharmacists. It is meant to point out the potential complications of having clients who are led to believe that they would be getting better service outside of the veterinarian's office. This is not an economic issue; medications have been dispensed in both human and veterinary practices for years. However, taking the special case of veterinary patients, who differ in species and medical needs unlike those of humans, and treating them as if they were all the same, is bound to have negative consequences.