Submission Number: 560891-00702
Received: 10/28/2012 10:34:47 PM
Commenter: James Wilson
Organization: Priority Vet'y Mgmt Consultants
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I attended the HR 1406 FTC Workshop on October 2, 2012. I have submitted comments previously but need to add one that never surfaced on that date. During a meeting with five veterinarians yesterday, the following question arose. If HR 1406 became law, it is suspected that because of the convenience factor, as many as 80% to 90% of prescriptions written by veterinarians will continue to be filled before clients leave a veterinary practice. However, if the prescriptions for their pets are filled, some of which will be for controlled substances and others for drugs that could be used by humans as well as their pets, that means there will be millions of prescriptions floating around that could be filled in fraudulent manners and/or with dangerous consequences. In fact, pet owners could leave the veterinary practices with their pets' drugs and still have their prescriptions filled elsewhere. In doing so, they could then provide the duplicates to friends or, after acquiring them in any inexpensive manner, use the drugs themselves or resell them on eBay or elsewhere. One can only imagine how attractive this would be with respect to the masses of legally purchased controlled drugs that would now be available to supplement those already abused or sold on the street for tidy profits.
When the only prescription required by the Fairness to Contact Lens Consumers Act became law was one for contact lenses, this was an insignificant, one medical issue problem. However, with respect to veterinary medicine, we're talking about hundreds of drugs for many species of animals that could be misused by humans and their pets. It does not appear to me that anyone has considered this deleterious result of HR 1406. In my mind, this huge risk to society and the animal kingdom is enough by itself to prevent its passage.