Submission Number: 560891-00295
Received: 9/10/2012 1:52:23 PM
Commenter: Karen Rosenthal
State: Outside the United States
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I have been an exotic pet veterinarian for over 20 years. I am intern and resident trained and I have taught students, interns and residents for almost two decades. When prescribing medications for exotic pets, there are many considerations that pharmacists that work with people may easily overlook or not understand, putting both the pet and the owner in harm’s way. There are safety risks, both to the patient and owner, and the risk of inadequate medication administration leading to treatment failure if owners are led to believe that prescription portability is an endorsement of the ability of outside pharmacies as to having the same specialized knowledge base as veterinarians. It is common for veterinarians that treat non-dog and cat companion animals (ie, birds, reptiles, small mammals) to resort to compounding to produce medications of appropriate strength and form. For instance, will human pharmacists realize that avian patients cannot be administered medication in pill form but require medications to be compounded into liquid form? If an owner of a pet bird is given pills, the avian patient may not be treated. In the worst case scenario, the pet bird may be harboring the zoonotic disease, psittacosis, and left untreated due to inappropriate formulation by a untrained pharmacist, psittacosis could cause severe and even fatal disease in immune compromised people. Do human pharmacists understand that pet rabbits and many pet rodents are subject to severe gastrointestinal disease that can be fatal due to inappropriate choices of antibiotics? If a human pharmacist does not have the specific antibiotic requested by a veterinarian and the pharmacist substitutes what they consider a “safe” antibiotic, do they have the knowledge to know if the choice they have made is a risk to the pet’s safety? Finally, reptile patients, due to their metabolism, are routinely treated with injectable medications. Veterinarians who see reptiles carry a wide array of sizes of needles and syringes as patient size can vary from a 5 gram anole to a 200 kg tortoise. Will human pharmacists be able to fill these prescriptions with the appropriate sized needles and syringes for these pets? Finally, medicating a reptile patient, if not done properly with proper instruction, could put an owner at risk of being bitten, especially by larger snakes and lizards. Medicating a rabbit patient, if not done properly, can cause the rabbit to violently react leading to fracture of one or more vertebra. Will human pharmacists have this knowledge? To properly show the owner how to medicate these patients, the pharmacist, like the veterinarian, will need to medicate the pet in front of the owner so they owner understands how to properly administer the medication. Will these pets be allowed in the human pharmacy?
I have witness errors of substitution when pharmacists are not aware of the diseases and needs of exotic pets. One of the most common errors that I have seen are mistakes human pharmacists make when filing a prescription for a ferret with insulinoma disease. Insulinoma is a common disease in ferrets and is treated with prednisone. Ferrets cannot be pilled but I have seen pharmacists give pills to owners with the result that the pet ferret is not treated. Furthermore, the pill strength is much higher than a 1kg ferret requires and the owner is asked to split the pill into 1/8 per dose. This is impossible leading to treatment failure. I have also seen pharmacists dispense the wrong formulation of liquid prednisone to owners of ferrets with insulinoma. They dispense prednisone that contains alcohol and sugar- both items can lead to the death of the ferret.