Submission Number: 560891-00101
Received: 8/1/2012 5:49:33 PM
Commenter: Julie Forbes
Organization: Brea 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 pet owner myself, I am keenly aware of the rising cost of excellent veterinary care. Prescription medications make up a large percentage of this cost. I have serious concerns regarding consumer access to safe and efficacious medications. There are 3 main areas of interest I would like to address.
The first is the case of the consumer ordering and receiving a prescription drug without a valid veterinary client-patient relationship. While I feel the incidence of this has dropped over the last several years, I still encounter those who are receiving a prescription drug without a proper prescription from a licensed veterinarian. There is great potential for harm when this occurs. The consumer is often unaware of the risk of using a drug inappropriately. Examples are the use of heartworm prevention without proper testing, mixing non-steroidal anti-inflammatory drugs with others in the same class or corticosteroids, as well as the use of ivermectin concurrently with comfortis, to name a few.
The next category of concern is the storage and handling of these products. As many manufacturers sell directly to licensed veterinarians, some online pharmacies acquire the drugs third-hand. I fear the prescriptions may not be held at optimum temperatures during transport and storage, which can significantly affect the efficacy of the active ingredient in the prescription product.
Lastly, there are still counterfeit products being distributed by some non-reputable online pharmacies. In the race to offer the least expensive product, less than honest individuals have taken the competition to this dangerous extreme.
Consumers most certainly deserve access to competitive prices when purchasing products for their pets. However, the current situation leaves areas of vulnerability and risk that are just not acceptable. As an advocate for my patients, I feel it is imperative to have stricter oversight regarding prescription drug access outside the "direct from veterinarian" channel. Being forced to provide a written prescription which a consumer can utilize virtually anywhere is disturbing to me. Presently, I try to guide my clients to the most reputable sources I know when they choose to fill a prescription elsewhere. They request a medication from the pharmacy, and I receive a fax request from the pharmacy. This allows me to confirm the drug, dosage and directions for use are correct. While I still fear for product safety, efficacy and authenticity, I am actively involved in the process.
I urge the commission to require greater oversight of the acquisition, storage and distribution of pet medications in order to protect the consumer as well as the pet patient.
Dr. Julie Forbes