Submission Number: 560891-00477
Received: 9/14/2012 1:38:39 PM
Commenter: Susan Wynn, DVM
Organization: American Academy of Veterinary Acupuncture
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
American Academy of Veterinary Acupuncture
PO Box 1058
Glastonbury, CT 06033
Fax: (860) 659-8772
The American Academy of Veterinary Acupuncture (the Academy) represents over 800 veterinarians nationwide. The Academy is comprised of veterinarians who practice acupuncture and Traditional Chinese Medicine (TCM). Veterinarians that practice acupuncture TCM vary from integrating the use of prescription drugs with Chinese Medicine to not using prescription drugs at all. Our member veterinarians have little to no reason to view the sale of prescription drugs as an income resource. Our interest as veterinarians in this issue is the health and safety of our animal population. Having human pharmacies fill prescriptions for veterinary patients could endanger the health of veterinary patients. If a client takes a written prescription to a local pharmacy, the pharmacist will be one that is trained in human pharmacology, not veterinary. The Academy believes that it is in the best interest for the patient's safety that the veterinarian, who is most knowledgeable about the effects of drugs on veterinary the patients, be the one advising and educating the client at the time of drug dispensing rather than a pharmacist instead of a veterinary pharmacologist. The problem is only multiplied if a client decides to purchase a drug from an online pharmacy where no personal instruction or education is available at the time the client receives the medication.
It is the opinion of the Academy, its Board, and membership, that legislation requiring veterinarians to write prescriptions whether a client purchases a medication through the veterinarian or not is neither fair to veterinary practice owners nor necessary.
Legislation requiring written prescription is unnecessary and redundant. The American Veterinary Medical Association (AVMA) representing more than 83,000 veterinarians nationwide, has long supported the right of clients to request a written prescription when desired and encouraged veterinarians to write prescriptions when asked.
State regulatory agencies already govern veterinary prescription writing. States such as the California Veterinary Medical Board, already have regulations requiring the display of publicly viewable posting of notices informing clients that a veterinarian must write a prescription if asked.
Susan Wynn, DVM