Submission Number: 560891-00215
Received: 8/30/2012 2:47:09 PM
Commenter: nolan beech
Organization: Washington County Veterinary Clinic
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
It is with great interest that I read this proposed legislation. The advent of online and brick and mortar retailers that sell pet medications have had a very negative effect on the profitability and the public image of veterinarians. Meanwhile veterinarians are still the ones who deal with animals after hours and at a sacrifice to their personal lives and their families. My practice employs a price match guarantee. I will meet any competitors price for any over the counter product that I sell and any prescription product that is marketed for mass distribution such as heartworm preventive or flea medications. I will grant written prescriptions at the clients request or if the medication the patient needs is not readily available in my pharmacy. This is a very infrequent occurrence. But it does occur and the writing of a script is dictated by the needs of the patient and not my profitability and their best interest is being served.
There are many reasons for the veterinarian to retain control of pet prescription products. Many of the drugs are not the same nor in the same strength. Furosemide, a commonly used diuretic, is dispensed at 12.5 mg and 50 mg in the animal world and at 20, 40, and 80 mg in the human world. The veterinarian is trained to know the effects of the drug on the animal and could better make a substitution as I use human label furosemide if animal label is unavailable. A pharmacist receiving a script for a 12.5 mb furosemide would probably dispense a 1/2 tablet of a 20 mg at equal time intervals and therefore not comply with the written script. I also doubt they would choose to carry both the 40 mg and 50 mg size. This is just one example but there are many drugs where humans and animals take different formulations of drugs in similar families ie humans take ciprofloxacin and animals take enrofloxacin. While there are many human drugs that animals do take, the dangers and side effects in animals are much different than in humans. The veterinarian is the one best qualified to dispense these drugs and make sure that the animal is receiving both the dose and the correct formulation since they are the only person who has training in this field.
This is also a tax issue since online pharmacies pay no sales tax and the sale of animal drugs through this channels robs the local and state economies of tax income. It would seem that it is not only in the pet's best interest for the veterinarian channel to remain open but also in the local and state government's as well. This issue is inherently unfair and costs me considerably since I match the price my customer would pay without sales tax on mass marketed products. I find it interesting that the government would consider damaging the veterinary profession even further, when we are job creators and tax payers in many local economies and are much more widely spread than online retailers and big box pharmacies.
I have always been impressed by the knowledge pharmacist have of their medications and it is often more practical and relevant than the knowledge the medical doctor has. This will not be the case if they are dispensing animal drugs. They receive no training in animal pharmacology, pathology, oncology, infectious disease or medicine. Yet, they would be considered a superior source of information and medications if the veterinarian were required to script out drugs. The pharmacist would have to call the veterinarian in many cases to know such simple things as whether or not a medication could be given with a meal. This is not a good idea and is definitely not in the patient, the clients or the veterinarians best interest.