Submission Number: 560891-00012
Received: 7/15/2012 9:34:27 AM
Commenter: Dennis Woodruff
Organization: Avondale 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 appreciate your interest in helping out consumers to get quality prescriptions and OTC pet meds. I noted your comparison of this issue to the prescription lens issue in humans. I do believe this is a much different situation. Contact lens deals with 1 species (human) and 1 product (contact lenses).
The veterinary prescription and OTC situation is highly complex. Many species are treated (dogs, cats, pocket pets, birds, reptiles etc.)and each have their own metabolic issues, drug sensitivities and other peculiarities. Administering these meds is critical to success with them and I don't believe that traditional pharmacies have that expertise or knowledge. Also they don't have the pet present so they can demonstrate how to administer the product properly. This is a significant issue and meds that sit on the shelf at home because they can't be given......or that are given or applied improperly and thus "don't work" is a critical issue! That's the primary reason that most veterinary product manufacturers sell only thru veterinarians. They want to know that the product they've spent millions of dollars developing will be used properly and not cause untoward side effects. As an example, permethrin based products work well on dogs to control fleas and ticks.........but are quite toxic to cats. And cats don't have to have the product applied directly to them to have problems. Rubbing up against a dog that has received the product topically can be enough to kill the cat. Veterinary clinicians and their staff are aware of these issues and in the best position to make sure the are used properly. Warning labels on products are great but most owners don't read "the fine print"..........and thus the problem.
As veterinarians we routinely script out products that need to be compounded for a specific size of pet or for a specific situation. We also write scrips for clients who want to buy their product online...although many find they are actually more expensive online. Requiring a veterinary facility to write a scrip for all products dispensed is an onerous requirement and does not support the publics best interest. We work so hard to get clients to understand the need for their pet to be on heartworm and intestinal worm preventative as well as flea and tick control. If we can't sell the product to the client after explaining its importance it doesn't get given. Even with our best efforts to keep pets on HW and flea and tick control products we average 2 months out of the year that the pet is actually on the product. Clients may say it's too expensive and for some clients that is true. However most clients when asked if they need more preventative medication note they have some at home..........from last year. They had the meds but didn't give them......which in my opinion is a bigger issue than cost.
It is my belief that this legislation is driven by large companies looking to make money on pets........not to help make life better for clients and their pets. Veterinarians are interested in making money and staying in business but that is not our primary motive. We are in business to improve the quality of life of our pets and their owners.........PERIOD.
Please spend time in veterinary clinics so you understand these issues before legislating changes which would be a disservice to my clients. Thanks for the opportunity to share this perspective. Dennis D. Woodruff, DVM, CCRT