Submission Number: 560891-00440
Received: 9/13/2012 11:37:58 PM
Commenter: Jan Ginsky
Organization: Maryland Veterinary Medical Association
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Re: Pet Medications Workshop, Project No. P12–1201
Dear Sir or Madam:
I am writing on behalf of the Maryland Veterinary Medical Association, representing veterinarians and veterinary technicians throughout the state of Maryland. We want to express our concerns over the proposed legislation, HR 1406, that would mandate prescription writing by veterinarians. We believe such a mandate would present risks to
the health and welfare of our patients.
Veterinarians are trained to understand the physiology of a multitude of species, and the pharmacology associated with each species. Pharmacists have not received the training necessary to understand the multispecies complexities. We frequently hear of cases where a drug, or a dose, is changed by a pharmacist without consulting with or informing the prescribing veterinarian. Not all drugs can be used in all species, and doses can vary greatly between species. The wrong drug or the wrong dose given can prove anywhere from ineffective to dangerous for veterinary patients.
Most veterinary clinics maintain on-site animal pharmacies, allowing veterinarians to immediately address the needs of the patient. This also affords veterinarians the opportunity to thoroughly explain the medication; from administration (which is often demonstrated), to possible side effects. When a pet owner opts to take a prescription elsewhere, treatment is often delayed, or the prescription may never be filled and the veterinarian never told, complicating future follow-up and treatment. Mandatory prescription writing would encourage the pet-owner to look elsewhere, thereby increasing the frequency of these issues. In addition, a pharmacist has neither the ability nor facilities to coach a pet owner on administration of the drug to the species in question, leading to misuse of products and an additional risk to the patients’ health.
Many, if not most, of the pet drugs are sold directly by the manufacturer only to facilities with a licensed veterinarian with the understanding of a valid Veterinary-Client-Patient relationship for the use of the drug. Online and retail pharmacies obtain these products through third channel parties, opening the possibilities of mishandled, foreign, out-of-date and/or counterfeit products, putting our patients’ health and welfare at risk.
Where does the liability fall? Considering the (often times) unknown source of animal drugs at outside pharmacies, and the fact that prescriptions are often changed without the veterinarians knowledge or approval, who would be held liable when things go wrong? If prescriptions were mandated, veterinarians should be allowed to have the client sign a waiver of responsibility when a client chooses to purchase the drugs outside a veterinary clinic, as a form of minimal protection.
A final concern is the financial repercussions of requiring a script to be written for every drug a veterinarian prescribes. The paperwork involved would require increased time, manpower, and resources for the veterinary clinic. Such an increase in expenses would lead to the need to increase fees elsewhere, and the perceived or possible savings to the client by buying elsewhere would be lost.
In conclusion, the Maryland Veterinary Medical Association believes that HR 1406, and its mandates, would be detrimental to veterinary practices and pet owners, and would put the veterinary patients’ health at risk.
Thank you for your time and consideration.