Submission Number: 560891-00206
Received: 8/29/2012 8:23:06 PM
Commenter: Sheri Morris
Organization: Oregon Veterinary Medical Association
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As President of the Oregon Veterinary Medical Association, I would like to comment on the issue of prescription pet medications taken up by the FTC workshop.
The American Veterinary Medical Association currently recommends that veterinarians provide portable prescriptions to consumers upon request. Since a large majority of veterinarians already meet a client’s request, we believe it is redundant and arduous to mandate it in new legislation such as HR1406.
As veterinarians, we feel it is important that consumers get safe and efficacious products that can be verified. This is not necessarily the case with diverted products.
As an example, recent prescriptions of our members in Oregon at local “Costco” retailers have been re-packaged out of FDA labeled packaging by Costco pharmacists, therefore losing all package information, lots, and serial numbers. We can only conclude this has been done to avoid having the “track and trace” packaging monitored by the manufacturer. When Oregon veterinarians have asked for the pedigree or “chain of custody”, the pharmacists have refused to provide it to either the consumer or the veterinarian.
We worry about counterfeit drug entry into the market. When this occurs, there is no way to verify that the drug is a true FDA-approved product. According to HR 1406, the veterinarian cannot have her client sign a waiver of liability, yet the veterinarian in these cases cannot vouch for efficacy or safe handling of the drug.
In another case in Oregon, a farmer who bought a cattle de-wormer “on-line” had huge efficacy problems and rampant worms in his herd. The counterfeit product looked identical to the FDA-approved product. It later was checked by the manufacturer and was found to have had zero parasiticide in the product. NO activity. The drug was a proven fraudulent product bought through alternative channels.
While our clients have the option of getting veterinary prescription drugs at retail pharmacies, what has been occurring in Oregon has raised alarms.
We don’t need to add legislation for this issue. We in Oregon have documented many cases with the Oregon Board of Pharmacy where pharmacists have given erroneous advice to pet owners, have changed prescriptions, and even have changed medications on prescriptions. And while there are rules that require pharmacists to counsel our veterinary clients, they have no training with veterinary patients. As a consequence, we have documented cases of harm to pets because of inaccurate or just completely wrong advice by pharmacists for pet medications.
Veterinarians spend their lives helping pets – that is our mission. Let us – those who are trained about animal metabolism and drugs – prescribe, counsel and dispense medications to our clients for their pets. While there are those who bring up the issue of free competition, let us not forget the overriding issue of pet health and safety. Those who complain about the restriction of trade issues are doing so squarely because of a profit motivation, not what is best for pets.
Veterinarians have been entrusted to always have the best interest of their client and their patient as paramount. We take an oath to that effect in our careers. Trust us, then, to be fair and have the pet’s best interest at heart as we oppose HR1406, and support the choice of a veterinary manufacturer to restrict the sale of veterinary products through veterinarians.
Our guidance to pet owners on pet health and prescriptions is a critical value-added service that the pharmacist in a human pharmacy cannot match.
Sheri Morris DVM, DABVP
President – Oregon Veterinary Medical Association