Submission Number: 560891-00686
Received: 10/25/2012 12:52:48 AM
Commenter: Jennifer Kramer
Organization: Animal Hospital of Richboro
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
1. Prescription fulfillment: We all know how inconvenient it is to go to the pharmacy and wait half an hour for our own prescriptions. The last thing a pet owner wants to do is wait around for their pets medications too. Furthermore, they can't bring their pet into the store or leave the pet in the car (if it's too hot outside) while they go to get the prescription filled so they would have to make an extra trip out after bringing their pet home, which they probably won't do. If veterinarians are required to always give a prescription for medications, we will never know if they ever get the prescription filled by the pet owner or if they get filled in a timely manner. Often clients call our office requesting that we dispense a medication (i.e. ear medications) for a recurring problem but then don't pick it up until several days later. Veterinary offices are often open later than most human pharmacies so many people wouldn't even be able to get medications until the following day (or even longer if they have to work).
2. Lack of availability: Animals require many many different drugs that aren't used for humans. How could the human pharmacies possibly stock enough medications and options for all species? It would be ridiculous for pet owners to have to call around to several pharmacies to see if they have the products prescribed.
3. Mistakes: Human pharmacists and pharmacy technicians know nothing about animals and the pharmacokinetics of medications in animals. They would HAVE TO go through additional extensive training in order to be able to responsibly dispense medications to animals on a regular or frequent basis.
4. Veterinarians work very hard and do not make a lot of money (especially when compared to the lobbying pharmacies). While some profit is made on pharmacy items, this profit often helps support a business with huge overhead expenses. If veterinarians don't dispense enough medications from their own pharmacy, they won't be able to afford to stock their pharmacy so clients would still have difficulty getting what they need.
5. When clients do request written prescriptions, they usually find very little difference in price between the vet's price and a pharmacy price(some may be more, some may be less).
6. Fraudulent products: Greater availability of veterinary products/medications will encourage production of more fraudulent products. Currently many companies only sell their medications to veterinarians since we are the only people licensed to appropriate use or dispense certain animal medications, so we know those medications are authentic. However, when products have been purchased from many online pharmacies, the manufacturers have found many fraudulent products (especially flea and tick medications). This puts animals lives in danger, especially since the veterinarian would not even know what medication may have been given to the pet since we didn't dispense it.