Submission Number: 560891-00342
Received: 9/12/2012 12:56:19 PM
Commenter: Deborah Harris
Organization: Kitty Corner Cat Clinic
State: Rhode Island
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I thank you for inviting commentary from the veterinary community. This problem is a lot more complex than it appears, since the distribution of pharmaceuticals through on-line and discounted pharmacies, is only the part of the problem that the consumer sees. What they do not know is that many of these pharmaceuticals and neutraceuticals are entering the supply chain tainted, or fraudently repackaged by these same on-line pharmacies.Since these are veterinary medications, the major manufacturers( Merk, Merial, Pfizer, Novartis) will not sell to these entities. All of the inventory is diverted, and is no longer guaranteed for safety or efficacy by the manufacturers. There have been cases of reactions and deaths, to flea control products as recently as 2010. There were cases of heartworm disease in dogs who were recieving Heartguard purchased on line, which turned out to be counterfit.
The pet pharmaceutical trade differs significantly from the human pharmaceuticals, because there are different labeling entities. For a lot of flea control, the oversight is provided by EPA, not FDA. There are also a lot of neutraceuticals, which are feed additives and have circumvented the FDA approval process. These are commonly used in veterinary practice, and the nuances of each product are well understood. When clients purchase from an on-line or discount entity, their only guidance is from an untrained order-taker, and the only difference they can discern is price. I have already been in the unhappy occaision to witness incorrect pharmaceuticals in use in the pet trade, with potentially harmful consequences to humans who care for these animals. Many people use medications as behavior modification devices, and when you get it wrong, it can be worse than before the animal was treated. Don't forget, when you place prescription "reform" into law, it is no only dogs and cats who will be impacted, it is also horses, goats, small ruminants and cattle. These can be dangerous to humans if medicated incorrectly.
I think this legislation is a kind-hearted, but misguided attempt by a number of individuals to gain political favor with their constituents. This bill will not do anything to control pharmaceutical costs, since once the big-box stores and the on-line pharmacies gain control of the market share, thay will reset their prices to whatever the market will bear. I don't think anything meritorious has ever come from taking healthcare decisions away from the very people who were educated to assist the owners in making these complex decisions. I hope you will reconsider this legislation.