Submission Number: 560891-00163
Received: 8/23/2012 2:12:21 PM
Commenter: Thomas McGowan DVM
Organization: Green Trails Animal Clinic
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 business owner I have many concerns both for safety of my patients and my ability to continue to provide jobs for my employees. All areas of the veterinary practice provide much needed income to continue to provide reasonably priced and high quality medical and surgical services to our clients and their pets. The money generated from internal medicine, surgery, radiology, dentistry, preventive health care, rehabilitation, and pharmacy helps to pay the overhead which includes payroll. In my area, most of the clients know about purchasing medications from other sources. I do not charge a fee for writing a prescription, but most want the medication filled at our clinic pharmacy for the convenience. If the income produced by the pharmacy was significantly decreased or if due to the burden of legislative action I no longer had an in clinic pharmacy then I would need to consider cutting jobs, and raising the cost of all other services to make up for the lost income, thus creating more of a financial burden to the pet owner.
Another concern I have is that human and animal medicines may seem the same, but because human pharmacists do not have the training in animal pharmacology there are many medications that can be ineffective or even toxic to my patients when dispensed as a cheaper alternative. I have recently had 2 cases of this happening and if it wasn't for my intervention one of my patients may have died. The first example in a patient that was taking the animal product Metacam for pain. The human generic version is Meloxicam. My clients pharmacist told the owner that she could buy the liquid Meloxicam much cheaper and sold her the bottle. Liquid Meloxicam is sweetened with Zylitol which is toxic to dogs, and can cause hypoglycemia, liver failure and death. It was only by luck that the client came to the clinic for me to advise her on the proper dose (pharmacist did not know) and I discovered that Zylitol was in the product. The owner had purchased the product and was unable to use or return it, and I had to stop my busy day to do the pharmacist's job. The second example was with an antibiotic, animal form Clavamox, similar but NOT the same human form Augmentin. The pharmacist told the owner that they were the same product but that is not true. The ratio of Amoxicillin to Clavulonic Acid is different for these two products. Using a product that may not be effective against a bacteria can allow the bacteria to develop resistance and further endanger animal and in some cases human life.
These are just two examples, but there are many more cases I have had to deal with over the years. Each time an owner pharmacist has a request for a cheaper substitute human product I have to stop and look up in a reference source for possible problems for my patient. I have been working 55 - 70 hours a week for the last 26 years and the burden of this UN-needed legislation will only create longer work weeks, loss of jobs, dangers to my patients, and increased veterinary cost to the consumer.