Submission Number: 560891-00325
Received: 9/11/2012 9:45:21 PM
Commenter: Shawn Messonnier
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Based upon existing laws protecting consumer choice, I would oppose any additional legislation. A major concern is the importance of the doctor-patient relationship. Already we are seeing certain companies, both internet and brick and mortar pet stores and pharmacies, continue to prescribe the wrong products at the wrong dosages for the wrong pet. (Certain internet pharmacies have already been punished for breaking the law in this regard.) Fortunately we are able to catch these mistakes that at best could costs the owners needless expenses and at worst could result in injury, illness, or death to the pet.
Regarding pharmaceuticals, unless a licensed veterinarian is on staff how would a non-veterinarian be able to judge the appropriateness and correctness of a prescription? In the human industry pharmacists must graduate from approved program and be licensed to practice pharmacy. This allows the pharmacist to be an extension of the doctor, catching mistakes in prescribing as well as helping to educate the patient. Unless this same education and licensure is required of a pharmacist to fill a pet prescription, the pet is put at risk.
Finally, a staff member at a pharmacy or pet store does not have the knowledge of how medications, both prescription and OTC, interact. Allowing just anyone to sell medications is dangerous and should not occur.
Regarding the expense of medication, that is really a non-issue. If veterinarians lose their pharmacy business they will simply be forced to raise prices on other services, making it no cheaper for an owner to purchase a product elsewhere.