Submission Number: 560891-00315
Received: 9/11/2012 5:18:05 PM
Commenter: William Rueger
Organization: Cherry Grove Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
To whom it may concern:
There are two comments I would like to make about this proposal.
(1) There is a fairly rapid evolution of the veterinary prescription market underway which is leading to the active promotion and marketing of veterinary pharmaceuticals, not just on-line, but, as evidenced by Kroger's in our area, at the local drug stores. Very soon, if not already, this marketing effort by retailers will make it nearly impossible for the average pet owner to be unaware that they can have their pet prescriptions filled outside the veterinary office. This will make the regulation unnecessary in my opinion.
(2) The purpose of the rule is to inform consumers of their options. I submit that the approach used is unnecessarily burdensome, and will require more time and use of paper than needed for this purpose. Would not a requirement for a posting in a prominent location informing clients that they have the option to purchase prescriptions elsewhere, be sufficient for the spirit of the rule? I, for example, do not have to include a notice to each employee with every paycheck informing them of the Federal Minimum Wage. I have a prominent posting that they can easily see, which is a much more efficient approach.
William Rueger, Jr. DVM