Submission Number: 560891-00523
Received: 9/14/2012 5:16:00 PM
Commenter: Scott Bryant
Organization: South Carolina Association of Veterinarians
State: South Carolina
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
September 14, 2012
Federal Trade Commission/Office of the Secretary
600 Pennsylvania Avenue, NW
Room H-113 (Annex X)
Washington, DC 20580
The South Carolina Association of Veterinarians (SCAV) believes that the proposed legislation H.R. 1406 Fairness to Pet Owners Act of 2011, is not needed. Many pet owners already obtain prescriptions from their veterinarians, and retail pharmacies are filling these prescriptions.
Unfortunately, problems have arisen when the best standard of care for the pets is compromised and retail pharmacies are not following the best practices for pets.
The SCAV believes veterinarians are uniquely trained to provide the best guidance and education to pet owners when dispensing prescription products. The SCAV believes retail pharmacies should fully understand that animals have different physiological responses to drugs and should not, therefore, change a veterinarian’s prescription without first consulting with the veterinarian.
Also, the SCAV fears there is a great potential for retail pharmacists to change dosages of drugs prescribed by veterinarians and to dispense an entirely different drug without consulting the veterinarian. In South Carolina, there is more than one instance of retail pharmacists changing insulin prescriptions for cats. There are also examples of retail pharmacists recommending aspirins for companion animals.
Moving forward with H.R. 1406 that would allow unrestricted dispensing of prescriptions will put pets at increased risk threatening their health and safety.
G. Scott Bryant, DVM