Submission Number: 560891-00324
Received: 9/11/2012 9:26:15 PM
Commenter: Alexis Newman
Organization: BluePearl Veterinary Specialists
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 storng conviction that I oppose H.R.1406, Fairness to Pet Owners Act of 2011. This Bill would put a hardship on veterinary professionals, and in my opinion, falls in the category of trying to "fix something that is not broken".
There are several concerns with this Bill. First, most veterinarians are willing to write a written script or call in a prescription to a human pharmacy, either at the request of the pet owner, or due to availablity of medications. If a written prescription is required, even when a medication is dispensed by the veterinarian, this would increase the paperwork without having any benefit. Many clients appreciate being able to obtain medications at the veterinary hospital. In almost any situation, they would be able to obtain a script for a pharmacy if requested.
If this bill were passed, there would be a necessary burden on the pharmacist and staff to have a thorough understanding of veterinary pharmacy. There are particular medications for which the human dosing is extremely different than the veterinary dosing. Thyroid supplement and Vitamin K are two examples of medication for which the veterinary formulations are 10 times the strenght of the human dosing. Can it be guaranteed that the pharmacy would confirm this and not dispense the inappropriate medication. Can it be guaranteed that the pharmacy would even stock the veterinary formulations.
If the pet owner is given a written script as an equal alternative to obtaining the medications through their veterinarian, they should then feel that the pharmacy is trained in veterinary pharmacology, and at an equal level of knowledge of veterinary pharmacology as the veterinarian does. Will it be guaranteed that the pharmacist knows that one dose of acetaminophen can be life-threatening to a cat? This is one of numerous examples where the pharmacist can do more harm than good.
Veterinarians do not claim to have the knowledge in human pharmacology that a pharmacist does. A pharmacist cannot be expected to have the knowledge of veterinary medication that would be required to give the appropriate advice to pet owners.
It is astounding to me that a veterinarian would be obligated to give a written script for a medication to be fill by a pharmacist not trained in veterinary medicine, and at the same time not be able to have the client sign a waiver of liability. To mandate the use of a pharmacy, when a veterinarian may not feel it is in the best interest of the pet, and not be allowed to be free of liability from a mistake that same pharmacy may make, will guarantee legal problems.
Since most veterinarian are willing to provide written prescriptions for their pet owner clients, it seems that the only benefit this Bill would serve would be to transfer the financial gains of the pet medications out of the veterinarains hands. It goes against any medical training to base recommendations on financial issues.
I strongly oppose this bill, and feel it may be harmful to pets, as well as the Client-Veterinarian relationship.