Submission Number: 560891-00649
Received: 10/18/2012 12:38:21 PM
Commenter: Joanne Hughes
Organization: Sun Valley Regional Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
1. Requiring veterinarians to provide a written, portable prescription for each medication leads the consumer to believe that the medications available at a human pharmacy are equivalent to those available through veterinarians -- this is not always the case. While the generic name may be the same, the size/strength of pills available and the bioavailability of human medications may NOT be equivalent to medications specifically labeled for veterinary use.
2. Pharmacy staff at human pharmacies are NOT schooled in veterinary pharmacology, and drug pharmacodynamics are different between species. There are many drugs that are dosed much higher on a per-kilogram basis in animals than they are in humans. At times, the frequency of dosing is different in pets than it is in humans. Well-meaning pharmacists have been known to step in and *change* the written prescription from a veterinarian. Due to their ignorance of veterinary pharmacology and their assumption that it is identical to human pharmacology, they have changed these prescriptions to what would be appropriate for a human because they assume that the veterinarian must have made a mistake. While this is a clear case of a pharmacist overstepping their bounds, it happens nonetheless, resulting in subtherapeutic dosing which wastes the client's time and money while extending suffering for the pet.
3. Online pharmacies peddling pet medications have not always behaved in an above-board fashion. Even from online pharmacies with Vet-VIPPS certification, I still receive prescription approval requests for medications that are ONLY distributed directly to veterinary clinics (Trifexis and Comfortis are the most common). The only way online pharmacies are getting their hands on these medications is through illegal diversion & grey-market purchases. How is this in the consumer's best interest?
At least in California, veterinarians are required to make the client aware that they can ask for a portable, written prescription that they can have filled elsewhere. By requiring the client to ask, it allows veterinary staff the opportunity to open a discussion with the client that adequately educates them regarding the issues outlined above. Simply handing over a written rx every time medication is recommended for a pet would eliminate this opportunity for client education.
Pet medications cannot be compared to contact lenses. If the focus of this workshop is to protect the client, then giving them carte-blanche to surf the internet or local big-box stores for medications puts the client at risk for believing they are making a wise choice for their pet while allowing them to fall prey to shady chains of distribution and misleading marketing practices. I fail to see how this is in the best interest of the pet or the client.