Submission Number: 560891-00689
Received: 10/25/2012 12:34:31 PM
Commenter: Jill Gastonguay
Organization: Poland Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am a very frugal person, so I completely understand wanting to create a market where my clients can get medication at a lower cost. My concern is the lack of communication and knowledge at the outsource facility. Here are a couple of examples:
1. I have had cats become terribly ill (seizures, muscle tremors, and vomiting) because their owner applied Advantix to their dog which slept with the cat. Another case occurred because the owners applied the Advantix then applied another cat product to their cat but didn't wash their hands in between. They purchased the product from an online source and a pet store and neither of these locations educated them about the risks of Advantix near cats. As veterinarians we educated our clients about any product sold at our practice, which can be harmful to another pet in the household.
2. Insulin- We prescribe NPH insulin to our dog diabetic patients and these prescriptions are filled at nearby human pharmacies. One of these pharmacies re-evaluates the drugs that participate in the reli-on discount drug program. For the past 2 years the insulin brand has changed from Novolin to Humulin and then back to Novolin. The pharmacists have repeatedly told my clients that it is the same insulin, so they do not need to worry about the brand change. This might be true in humans, but it is absolutely false in dogs! All 3 of my dog patients who received their insulin from this pharmacy became unregulated. Two patients glucose levels were too high and required repeat monitoring and dose adjustment to regulate them again. The third patient became hypoglycemic and needed emergency treatment.
My other concern about working with pharmacies and many of these pharmacies are requiring our DEA number to have our patients participate in the discount program. This goes against the recommendations of the DEA who states that our DEA number is ONLY for controlled drug prescriptions and NOT to be used as an ID number in their database. I have a few pharmacies that will not fill my patients non-controlled drug prescriptions because I will not provide my DEA number. This is an issue that needs to be resolved.
I strongly believe that if a source besides a veterinarian is going to fill prescriptions they need formal training. Although I am licensed to dispense prescriptions to animals, I would never dream of filling a prescription for a human because I have no formal training on human drug pharmacology.
Also a pharmacist may easily change a human prescription from a pill to a capsule or liquid formulation, but that can cause great injury in an animal. Capsules have been documented to cause esophageal strictures in cats. Liquids that contain xylitol are toxic to dogs and cats. This is information that pharmacists currently have no knowledge of due to lack of proper training. Yet if they make these changes, a veterinarian is liable under current laws.