Submission Number: 560891-00367
Received: 9/12/2012 5:42:16 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
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With strong conviction, I oppose H.R. 1406, the Fairness to Pet Owners Act. This is an example of trying to fix something that is not broken.
Every veterinarian I know is willing to give a pet owner a written script to obtain medication at a pharmacy, if it is requested, or needed (if, for example, the veterinary hospital does not stock that medication). To mandate that a script must be written for every prescription is an unnecessary burden.
To mandate that all prescriptions receive a written script increases the chance that an untrained pharmacist or staff member will inaccurately fill a prescription. Will these individual be required to have training in veterinary pharmacology? The dosing and tablet sizes for Vitamin K and for thyroid supplementation in dogs are approximately 10-fold what they are in humans; will the pharmacy staff know that? I have had experiences where these medications were improperly filled, and patients were under dosed, due to the difference in human and veterinary dosing and available tablet sizes. If all pet owners will have the opportunity to obtain the medication at a human pharmacy, will it be guaranteed that they will be given correct advice? For instance, will they know that one acetaminophen tablet can be life-threatening to a cat? Or that dogs are uniquely sensitive to problems when given steroids in combination with NSAIDs; a combination which is routinely used in human medicine. If they are not trained in veterinary medicine, they will be putting our patients at risk. Ironically, veterinarians are then prohibited from having the client sign of waiver of liability. This is forcing a professional to take action that is not warranted, then potentially be held accountable for another’s mistake.
Since most veterinarians are willing to give a written prescription, and the AVMA encourages this be done when requested, there is no medical reason to support H.R. 1406, the Fairness to Pet Owners Act. If not medical, then the only justification is financial for the pharmacies. This does not correlate with Best Medicine, Veterinarians are there to treat animals, not to ensure that pharmacies are able to seek additional profit.
Do not try to “fix what is not broken” by enacting legislation that is unnecessary.