Submission Number: 560891-00083
Received: 7/31/2012 8:00:02 AM
Commenter: Marianne Bailey
Organization: South Arundel Veterinary Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As a small animal veterinarian and recent graduate, I am strongly against this bill.
Any veterinarian will willingly write a prescription at the request of a client which makes this bill unnecessary. In addition, it would create undue regulatory and administrative burdens on veterinary practices. Clients already have the flexibility to fill a prescription on-site or off-site at a pharmacy of their choice. Also the Principles of Veterinary Medical Ethics state veterinarians should honor client requests for written prescriptions.
The bill's requirements would interfere with the collaboration between a veterinarian and client regarding decisions for a pet's care and its welfare. Many veterinarians, like myself, fear that clients will wait a day or more to pick up prescription, delaying treatment for a pet. This would also discount veterinarians' education and training to make treatment recommendations based on sound clinical judgment and current medical information. We must first prescribe medications that are labeled and approved for cats and dogs before we prescribe off label human medications for pets that are cheaper. Approving this law will put veterinarians in a situation where clients are requesting "off label" medications because they can pay less but they are not using a medication that is approved for their pet.
Lastly, I worry that human pharmacists are not trained or prepared to answer pet owner's questions about medications. Will they have a course to complete regarding side effects and drug interactions? They will often times not be the same as in humans and the difference between cats and dogs is significant.