Submission Number: 560891-00050
Received: 7/26/2012 11:55:45 AM
Commenter: Louis Gotthelf
Organization: Animal Hospital of Montgomery
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am very concerned about the safety issues of using human pharmacies to dispense prescription veterinary drugs. First, human pharmacists are not trained in animal drugs and most of them are not interested in learning about them because it is such a small part of their daily business activity. If they do dispense veterinary prescription drugs, they need to have a minimum amount of mandatory continuing education in veterinary drugs to be qualified to engage in the business of veterinary pharmacy. Second, animals come in various species and among the species are various weights of animal breeds. All animal species have pharmacologically different issues relating to drug doses,drug metabolism, drug actions, drug interactions and reactions, routes of administration, and duration of treatment using the same drug. Veterinarians who write drug prescriptions are prone to making mistakes that may not be picked up by an untrained human drug pharmacologist unfamiliar with animal drugs. Misplaced decimals, the use of mcg, mg, vs g doses not used in human drugs, latin pharmacy lexicon, pharmacist's decision to substitute equivalent drugs, as well as splitting large dose tablets to have the proper dose are all places where mistakes can be made. Many human drugs used for animals are not available in small enough dosage forms for dispensing to small dogs, cats, or exotics. Many drug tablets are not uniform in their dispersal of drug in the tablet, so splitting a tablet may not provide the proper amount of drug per dose. Third, marketing efforts for people to have their dog or cat drugs filled at their chain store pharmacies are only a way to get people to shop in their stores while they wait for 45 minutes to an hour to get their pet's prescriptions filled.
Another issue is profitability. Veterinarians generally do not charge very high fees for medical service, but they make up profits by marking up veterinary only drugs. If that source of income was to be taken away, then veterinary fees for services would rise accordingly, so there would not be any benefit to the consumer. More people would be locked out of veterinary care for their pets because of the higher costs involved. The time it takes to write a paper prescription for every drug that an animal needs takes the veterinarian's time, which would have to be charged for in some way. Again, there would not be a monetary benefit to a consumer if the fees for writing a lower cost prescription were built in to higher veterinary fees.