Submission Number: 560891-00209
Received: 8/30/2012 10:20:37 AM
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
To whom it may concern:
This is a very complex issue and though the underlying theme or concern on both sides is economically driven -- stores/pharmacies want to have legal (not grey-market) access to veterinary only products -- and veterinarians want to retain those products in their practice. Both parties want to profit, and consumers want decreased prices. However, I hope that the FTC also considers the health and welfare of the patients in addition to the economic issues.
I would like to focus on a couple of other key areas that should be considered:
1. I am not convinced that consumers do NOT have reasonable access to written prescriptions for medications. I have worked in several practices and they are always provided upon request of the owner or offered when appropriate. There are also several human-labeled products that we often script out. Is there substantial evidence that consumers do not have access to written prescriptions? It is true that retailers and pharmacies do not have open access to veterinary-only products, there are reasons for this that extend beyond economics and center around patient safety and client education.
2. The safety of veterinary products is significantly compromised by grey-market acquisition of these products (both prescription and non-prescription) by large retailers (Walmart, PetSmart, etc) as well as on-line retailers and pharmacies. These products go through multiple parties before ending up in the hands of the consumer, this compromises safety of the products. Certainly opening up distribution would eliminate this issue, but I feel strongly that pharmacists and retailers do not know enough about how these products are used, contraindications, interactions, and efficacy to be able to safely take on the task of appropriately recommend, dispense, or educate consumers. We already see these issues with current grey-market activities.
3. Pharmacist education. Currently pharmacy education (pharmacist, assistant etc.) does not include any coursework on veterinary pharmacology. If there is to be a widespread mandate that written prescriptions be provided for all medications, then it is essential that there is a corresponding addition of veterinary pharmacology in the pharmacists' education. Veterinary education (both DVM/VMD and technician) comprehensively covers veterinary pharmacology, it cannot be learned in a few CE sessions. Just as you would not expect a pharmacist to complete their degree over a few hours, they are not going learn veterinary parmacology without incorporation into their curriculum. In addition education for the exisiting licensed pharmacists will need to be addressed and in order to assure that there is a complete understanding of veterinary pharmacology in multiple species (canine, feline, equine, bovine, reptiles, etc) and likely a certification process should be initiated. Health and welfare is of utmost concern and without appropriate education this will be compromised. I personally have had pharmacists substitute inappropriate medications on written prescriptions. This has happened on 3 separate occasions. After speaking with the pharmacists they were not aware of the contraindicaitons or efficacy in animal species of the substitute. I did not report these to the board of pharmacy, which I probably should of done. Veterinarians in general are not whistle-blowers, but we may have to become so. I think that this is a more widespread problem which is not refelcted in acutal reports to state pharmacy boards. If veterinary-use only products also become available for human pharacists to dispense, it will become critical that pharmacists have appropriate education (and not just a few hours of CE) to safely dispense these products and provide the necessary client education.
I hope that as the FTC considers this issue, it also looks beyond the economic considerations to the health and safety of those we are trying to serve - the pet.