Submission Number: 560891-00224
Received: 8/31/2012 12:19:49 AM
Commenter: Stephanie Todd
Organization: Harmony Veterinary Clinic
State: New York
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am compelled to comment on H.R.1406, the Fairness to Pet Owners Act.
First, I would like to make clear that our four-veterinarian practice has routinely given prescriptions to clients for their pets' medications for almost 20 years. That is not a hardship, it is a service we are happy to provide. However, the means by which we are asked to do so in future is a significant problem for us. Currently, if I suggest that a client look into an outside pharmacy as the source for a medication, they go on-line or call the pharmacy and request the drug. We then receive a fax from the pharmacy, sign it , and fax it back. We are not asked to spend the time to write out a prescription, especially in the event the client actually prefers to buy the drug from us for convenience.
In addition, I would like to stress that we are very reluctant to be put in the position of policing pharmacies by "verifying" prescriptions! How could we possibly be considered 'expert,' over the authority of a pharmacist? We are very afraid of our potential legal liability should the client choose to order from a pharmacy that lacks accreditation and makes a grave error.
We would be more than happy to post a notice to the effect that we will provide a prescription for any pet medication (we already do)! We simply object to the time burden of constantly writing scripts, whether or not they are really wanted by the client! We also strongly object to being forced to put ourselves in a liable position, losing the ability to counsel owners on the use and potential side-effects of certain medications at the time of dispensing. We are forbidden to release ourselves from responsibility...are we to be held liable if a dog dies of intestinal ulceration after a scripted NSAID is mislabeled by an outside pharmacy? Or are we to be forced to spend even more of our time counseling pet owners on the use and side-effects of drugs being dispensed elsewhere? Human pharmacists are often not aware of proper dosages and possible side-effects of drugs in animals!
We understand that there is concern over veterinarians monopolizing the dispensing of medications. Honestly, the shoe seems to be on the other foot! If we are required to script, required to "verify," and denied a disclaimer of responsibility, then we are being potentially excluded from dispensing while being forced to bear risk that the dispensing pharmacy should bear. This legislation seems to be quite self-serving on the part of the large corporation(s) advocating it, and crushing to us as small business owners. Isn't that a travesty of the role the FTC is supposed to uphold?
Thank you for your attention to this matter.
-Stephanie E. Todd, DVM