Submission Number: 560891-00048
Received: 7/26/2012 11:25:14 AM
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Appreciate the effort of FTC to review ongoing practices. I would like the commission consider following comments in their deliberations.
1) How contact lenses which is Standard operating Procedure product can relate to diverse product line relevant to veterinary profession ?
2) How a prescription product can be sold on over the counter especially with fewer new drug applications and approvals. Once they are inappropriately used the resistance developed in disease vectors and disease etiological factors is a burden on the pet industry, zoonotics and society. Large animal practices in antimicrobials, antibiotics and antiparasitic drugs are already on this slippery slope.
3) Introducing competition for free market facilitation while is noble I am not sure whether deregulation is the way to go about it. - if you look at number of veterinary hospitals in small animal industry in a city like ATLANTA you would understand there is enough competition. Yardstick for better product and services is a) cost involved and efficacy of the treatment.
4) The mindset of veterinary hospital regulations are predominantly based on human model. We are yet to understand that veterinarians need a different model. Farmer selling produce to public can be argued as lacking consumer protection. We all know how that lead to losses to farmer and consumer in the current marketing trends. Tweaking direct service is always detrimental to end user based on historical experience of mankind. I hope people leave pets alone with their chosen veterinarians instead of introducing more benefactors who do not have a stake in the welfare of pets. While distribution services can be improved to assist veterinarians to choose better products for the benefit of consumer I hope the current effort does not lead to non stakeholders to benefit in the process.
4) If you encourage loss making decisions for veterinarians in the name of Free trade there will be less veterinarians serving the society hence our zoonotic first line defense will be weakened.
As much as the concept of free trade is to benefit consumer I hope we do not create a walmart model where neither cost to consumer nor national interests will be served.