Submission Number: 560891-00037
Received: 7/25/2012 3:17:49 PM
Commenter: Kelly Byam
Organization: Abel Pet Clinic, Inc.
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
HR 1406 must not become the law of the land. It constitutes a danger to the public, all in the name of increasing WALMART’S profits.
You may as well call it the "What's good for Walmart" bill. They are engaging in predatory practices against veterinary hospitals, all of which are already struggling. Walmart wants to circumvent existing law, and give owners an ADDITIONAL written prescription.
Controlled substances absolutely can NOT be dispensed this way (to have the meds in hand, as well as a prescription for additional supply.) And Walmart cannot demand that the practice owner or whoever has the DEA license stop whatever they are doing to write a prescription for someone else's patient; all so Walmart can have more pharmacy business. Most associate veterinarians do not even have a DEA license, nor should it be mandated that they have one.
Not only that, but Walmart and other pharmacists trained only in human physiology do not have the requisite training in multiple species physiology to be able to determine the proper dose and drug for the patient and to catch any dispensing errors or medication interactions when filling prescriptions from different veterinarians for the same patient.
Walmart has been complicit in drug diversion when it obtains Frontline for sale in its stores. Frontline is sold only to veterinarians, and not to wholesalers or the general public. For big box stores like Target and Walmart to obtain this product, it is being purchased from drug diverters. This practice is unethical and unsafe, and the black and grey market only exist because of greedy companies like Walmart willing to operate in back alleys because what they are doing can’t be done in the light of day. They have already shown willingness to endanger the public by buying and selling drugs secondhand from unknown sources who have no guarantee of safe storage or handling practices. EVERY dose of Frontline sold in any establishment without a licensed veterinarian has been re-sold and is not coming direct from the manufacturer. It has been diverted.
This law is unnecessary (existing law already requires that we post a written notice that people are entitled to a written rx.) It does NOT say that they can have it immediately. We have the right and the responsibility to verify all prescriptions.) My own DOCTOR is not required to do the same thing for his patients. Walmart is very simply, GREEDY. This law also creates an unnecessary burden on all doctors to waste paper resources, time and energy (not to mention the additional record keeping), only to increase WALMART'S profits.
Please don't let Walmart continue to destroy communities and wipe out more small businesses. I have a right to make a meager profit at my pharmacy, and I guarantee that my employees are better trained and better paid than Walmart's ever will be.
Kelly Byam, DVM