Submission Number: 560891-00682
Received: 10/24/2012 4:47:42 PM
Commenter: Beth Taylor
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
October 24, 2012
To whom it may concern:
This is an important issue. I believe our AVMA provides standards for veterinarians to follow: (1) to help pet owners gain reputable medications their animals require and (2) to allow pet owners a preference for buying medications. Pet owners can complain and leave veterinarians who refuse to write prescriptions. Of course, AVMA has actively educated veterinarians on the fairness to consumer issue and identified agencies already in operation to protect consumers.
I would like the veterinarian to continue to have the choice as to how it is best for their veterinarian-client-patient relationship in handling prescription needs. Please, discourage any distribution of medications without a veterinarian-client-patient relationship. The use of telephone/internet help to ensure safety & monitoring of the patient/pet. Monitoring by the prescribing vet help retain continued efficacy of the medications being dispensed. In the 1980's ivermectin was known as a highly effective dewormer for horses. Ivermectin became accessible over the counter and generically. Today, the ease of access to ivermectin has contributed to the loss of its effectiveness in killing parasites and in inappropriate use in dogs. I would like to encourage the use of prescribing methods that are not prone to abuse. In addition, I would like to prevent prescribing methods that allow people in the chain the ability to change the original intent.
Veterinary Medicine varies in many ways to Human Medicine: terminology, pharmacology and physiology. The differences between species have led to errors by Human Pharmacies. In addition, the client and pharmacist may take a written prescription and use their own judgment in picking up similar products over-the-counter. How can it not be best for pet medications to be sold through a veterinary pharmacist and/or veterinary clinic? To prevent abuse and allow fair market, veterinarians need the ability to monitor the sources to which their clients purchase their pet medications. A written prescription takes the ability to monitor source from prescribing veterinarian and follow-up care suffers to the pet.
Generic products lack consistency and veterinarians should have the right not to prescribe them for the pet's best interest. Internet pharmacies also vary in their quality, due to sources. Of course, not all generics and internet pharmacies are bad; however, making something absolute with regulations can prevent natural balances from occurring.
I would like to understand more on how the pharmaceutical manufacturer companies contribute to their products being sold at highly variable costs. Distribution by the pharmaceutical manufacturers greatly influence the prices the private veterinarian and pharmacies charge. Overall, private practice veterinarians are not showing high net profits from the sale of pharmaceutical drugs.
Thank-you for your time and hearing my opinion.
Beth A Taylor, DVM