Submission Number: 560891-00724
Received: 10/30/2012 1:49:56 PM
Commenter: Samuel Strauss, DVM
Organization: Weston Road 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 have serious concerns about the increased dispensing of veterinary pharmaceuticals through "human" pharmacies. There are tremendous variations in drug doses among animal species, and tremendous differences between doses of the same medication for humans & animals.
In Florida, there is a veterinary licensing requirement to have a minimum of two credits of continuing education in pharmacology evrery biennium."Human" pharmacists have no formal training in veterinary pharmacology and no educational requirements in veterinary pharmacology even if dispensing for pets.
In addition, the nomenclature & prescribing information training for veterinarians and MDs & pharmacologists is very different. Some examples:
1-Veterinarians are trainined to write prescriptions for liquids in mg/ml, wheras MDs write mg/tsp (5ml). I have had pharmacies call me because I have written 50mg/ml; I have been told that the drug is unavailable in that concentration but that they have it in 250mg/5ml (if you can't do the math, that's the same concentration).
2-Veterinarians are trained to write SID on prescriptions for "once daily". Pharmacists have no idea what this means; once daily to them is qD or q24h. I had one pharmacist prescribe for 7 times daily!(would have resulted in patient death if the owner hadn't called me for verification).
3-Veterinarians are trained to write prescriptions using the drug name only. Pharmacists are trained to fill prescriptions based on company name. For example, if I write furosemide, the drug name, pharmacist will call & say "did you mean Lasix?"
4-Due to bioavailability & blood volume differences, drug doses are frequently much higher for pets. I have had numerous pharmacsts change my Rxs stating, the vet must have made a mistake, the dose is too high, then dispense an inappropriate dose.
5-Potential side effects are different between humans & pets for the same medication. How can a pharmacist educate a client about adverse reactionsof medication for their pet if they don't know what the side effects can be?
In summary, I have grave reservations about mistakes and consistency of care if pharmacists for humans continue to dispense prescription medications for pets without any formal training in veterinary pharmacology. The assumption that pharmacolgy for pets & humans is "almost identical" is spurious and dangerous.
At the very minimum, pharmacists that dispense pet medications should be properly trained in veterinary pharmacology throught the use of continuing education, & such training should be a requirement for license renewal.
Sam Strauss, DVM