Submission Number: 560891-00019
Received: 7/19/2012 11:40:29 PM
Commenter: Linda Banks
Organization: Sone Ridge Veterinary Hospital
State: New York
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Requiring veterinarians to provide a prescription to a client for any medication, to be filled at the location of their choosing places a huge, unfair burden upon the veterinarian, and will jeopardize the strength of the very important and necessary veterinarian-patient-client bond. Big boxed stores and internet pharmacies are motivated purely be sales; there is no concern for the patient, no counseling about use, no follow-up to monitor efficacy, and no way of making sure reliable, accurate information has been given to the client prior to using the prescribed product, all of which occurs when patients are required to purchase medications from their veterinarians.
If allowed to purchase any medication from anywhere, clients may obtain medications which are of substandard quality and efficacy, have potentially been mishandled or pirated and obtained illegally, or which are not recommended for that particular condition in that particular pet, something a client may not understand because he/she is not a veterinarian.
Veterinarians constantly deal with well meaning pet owners who give their pets over the counter medications in inappropriate doses, drug combination or giving the wrong medication to the wrong species; these accidents occur because they have not received accurate instruction or information about the use, safety, handling or efficacy of the product because they did not get it from their doctor. With the ability of clients to purchase medications from anywhere, veterinarians will lose the ability to provide them with accurate information and/or warnings on product use, since we may have no knowledge of the product they purchase; there will also be missed opportunities to give clients our opinion on which products are best suited for their individual pet's conditions.
It is difficult to recommend and stand behind a product you have no confidence in and know nothing about, yet that is exactly what this law, if passed, will be asking us to do. Our current arsenal of medications has been evaluated and researched, and we have experience and history with them either directly, or through communications with trusted colleagues, esteemed researchers and board certified professionals. To take away this knowledge is to strip the profession of it's long standing relationship with the client; we are the trained professionals who provide guidance and direction to clients about the best medications for their pet; how can we accomplish this when we have no input into what medication is purchased and no clue about the source? Is it really worth saving a few bucks, only to spend hundreds more treating a potentially life-threatening accidental poisoning because the kid working in the isle of "Name-Your-Store" told you it was OK to give dog arthritis medication to your cat, just give a little less, or that the canine flea/tick control you just purchased was OK to use on your cat, too?
I have personally seen these scenarios played out too many times, and fear passing this law will only make them more common occurrences.