Submission Number: 560891-00369
Received: 9/12/2012 6:23:33 PM
Commenter: Jennifer Mills
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I understand the concerns the FTC has regarding protection of consumers from unfair price inflation by restricting the distribution of veterinary medications to veterinary hospitals. The FTC's main goal is protection of the consumer. My fear for consumers is that opening the distribution channels to non-veterinary personnel could put our pets and patients at risk. It is imperative that medications are given appropriately, side effects are adequately discussed, and medications are not combined with others that may create a health hazard for our patients. Human pharmacies employ trained pharmacists that review prescriptions, verify dosages to avoid accidental over or under-dosing, verify that different drugs prescribed by multiple doctors do not create dangerous reactions. These human pharmacists receive no training in animal pharmacology. They have no animal physiology training. They have no way of safe-guarding our pets and livestock from dangerous pharmacological events or accidents. When patients receive there medications through a veterinary hospital, the record reflects what medications the patient is on. Veterinarians can warn owners not to mix certain medications, when medications should be spaced from others, whether that medication goes with food or on an empty stomach. To expect pharmacists to be responsible for the entire animal kingdom would be foolish. As the current system exists, the individual veterinarian is held responsible for the medications that are dispensed. Fewer people involved allow for fewer sources of errors. Veterinarians only prescribe medications for the species they are knowledgeable about, and if they prescribe outside that realm they are held responsible. Unique problems of medication administration that occur with each species can be discussed with the veterinarian, and potential problems can be identified and avoided. I feel that taking away these safeguards found within the current system will further put our consumers at risk, and not protect them in any way. Clients would face receiving medication from someone who can not further discuss or explain the medication. In Texas, as the law currently exists, veterinarians can not refuse to provide a written prescription at the clients requests. There is a wide variety of costs to the consumer among differing veterinary clinics, and consumers have the option to chose a veterinary hospital that meets there medical, personal, and financial needs.