Submission Number: 560891-00202
Received: 8/29/2012 4:20:27 PM
Commenter: Daniel Hoekema
Organization: Westwood Hills Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I have been in veterinary medicine-small animal practice--for over 39 years and have been prescribing meds for my clients pets for that many years. Many of my drugs are only available in a veterinary form and dosage and should only be prescribed by a licensed practitioner and with his instructions. Human pharmacies don't carry many of the necessary drugs and pharmacists do not have a knowledge of animal drugs. As such, it is necessary for private practice veterinarians to stock a pharmacy of animal drugs. Occassionally, if a human drug is available for animal use then most veterinarians will prescribe such drugs according to the wishes of the owner.
With the onset of online veterinary pharmacies, veterinarians have been writing prescriptions for these animal drugs, again according to the wishes of the client. However, some of these online companies have been known to send non-FDA tested drugs, drugs from foreign companies that do not meet US standards, or drugs sent to the owner without a veterinarian's precription which is unethical and illegal.
Since most veterinarians are already giving their clients options on where they obtain their drugs, there is no need for the FTC or other governmental agencies to regulate this practice. It is just another attempt to promote governmental interference in the affairs of small business, which supplies 80% of the employment opportunities in the US and which is subject to a myriad of obstructive federal, state and local regulations already.
Furthermore, this new FTC law is only to support the greed of internet pharmacies and companies such as Walmart and Target to undercut and take business away from the small businessman.
Veterinarians are already complying with the intent of this new regulation, so there is no practical or moral reason for such a prescription regulation.