Submission Number: 560891-00155
Received: 8/21/2012 3:43:25 PM
Commenter: William Gay
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am a veterinarian and have been in private practice for 32 years. I have been in companion animal practice since 1993 and also helped start and own an internet based companion animal veterinary pharmacy since 2007. I am in a unique position to gauge the veterinary profession on this issue and monitor the dispensing of companion animal medicines through veterinarians, fulfillment pharmacies and retail pharmacies. My pharmacy was the first Vet-VIPPS certified pharmacy by the NABP.
The distribution of prescription medicines from pharmaceutical companies and distributors to veterinarians for dispensing to their clients continues to be safe and effective. The veterinarian is a "Learned Intermediary" prescriber as well as a retail dispenser for prescription medicines. This traditional arrangement has served pet owners well for decades and the right to do so is bestowed on veterinarians by their educational degree and licensure. Because of this tradition veterinarians have had the freedom to charge relatively higher prices for medicines to subsidize, in effect, lower prices for services. This economic model is changing with new competitive sources of medications.
The distribution of pet medications to these new competitive sources is a nightmare and is dominated by the diversion of OTC and prescription products. This diversion does not allow a prescription medication to have a pedigree, which is required in human pharmacy and the human prescription medication distribution chain.
In my experience, veterinarians are now over the initial shock of losing the exclusive dispensing business and are gradually, if not completely cooperative in providing a prescription to a pet-owning client if requested. Roughly 26 states require this and it is also governed by the AVMA Code of Ethics in all 50 states that veterinarians honor a client's request for a prescription to buy medicine elsewhere, if it is medically appropriate.
However, with the large amount of diversion of OTC and prescription medicines, it is impossible for a consumer to always verify the safety and efficacy of the pet medications that they purchase. There are hundreds of veterinary presription medications for pets, each with their own indications, contraindications, and side-effects. Some are proven safe (like canine heartworm preventitives) and could be dispensed by a non-knowledgeable pharamcist or pharmacy, but the dispensing of the majority of veterinary prescription medicines require the special knowledge of a veterinarian or the suitable, similar training in veterinary pharmcacy and pharmacology of a pharmacist.
Comparing the contact lens legislation previously passed by Congress to the Fairness to Pet Owners Act of 2011 is a huge mistake. Contact lens are a singular product with no potential for life-threatening consequenses. There are hundreds of veterinary prescription medications as well as hundreds more human medications that are prescribed for companion animal use. The average pharmacist in the United States does not have adequate knowledge to dispense all of these medications safely, nor do they possess the ablity to give advice about their use to pet owners.
The Federal Trade Commission must consider the "Protection of the Pet Owner and the Safety of their Pets" when it prepares a report or advises Congress on this issue. In my opinion the Fairness to Pet Owners Act of 2011, if passed and enforced in the present form will put the safety of pets in jeopardy and the security of pet-owners in question. Without pedigrees in the distribution of prescription veterinary medicines, there is a significant risk of fraud, substitution, and mishandling. And without basic knowledge of veterinary pharmacology by the average pharmacist in the United States,it would be unwise, dangerous and unethical to dispense medicines they are not familiar with.