Submission Number: 560891-00397
Received: 9/13/2012 11:58:27 AM
Commenter: Darwin Stith
Organization: Pfizer Animal Health
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
There are major physiological and pharmacological differences between humans and animals that necessitate very different education to manage risks and benefits in providing health care advice and the safety for prescribing information. Pharmacists are uniquely trained to help provide this valuable service for the prescribing information for humans but not uniquely trained in veterinary medicine, veterinary physiology, veterinary pathology or veterinary pharmacology. This poses serious and life threatening risks to the veterinary patient and subsequent emotional harm to the pet owner should the health of their pet be compromised. Veterinary professionals in a client doctor relationship need to be in charge of their companion animal patient's health care and to the management of the protection of livestock animals and food safety and subsequently to the public health. Human trained pharmacists filling prescriptions without the direction of a veterinarian compromises the safety of the veterinary patient and potentially threatens public health and safety. Veterinarians should not be mandated to write prescriptions to human pharmacies but should do so when they determine it is medically appropriate, education is appropriate and is in the best interest of their client, their patient and the public health.
I have been a veterinarian in private practice, state government and industry for over thirty years and have valued the professional working relationship between human trained pharmacists and my profession. I see no value and great potential harm in legislating this relationship.