Submission Number: 560891-00376
Received: 9/12/2012 11:43:35 PM
Commenter: Carole Dill
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
It will be particularly burdensome to have to write a prescription for every drug that an owner has chosen to purchase at the veterinary hospital. In addition, it opens a door to having prescriptions filled multiple times leading to potential overdose and overtreatment of the patient.
Having had the experiences of human pharmacies filling incorrect medications, changing concentrations without changing the volume of liquid compounds, and making medically contraindicated suggestions for medication administration (ie: advising owner to give meds in hotdogs to a patient with severe food allergy reactions), it is unfair that the veterinarian should be held potentially liable for the outcomes of the pharmacist's mistakes. If you consider it fair to have every client advised that they can have every prescription filled at an outside pharmacy, is it not also fair and ethical to advise clients of the increased potential for serious mistakes to be made when these same prescriptions are filled outside the clinic? Yes, we rely daily on outside human pharmacies to fill medications for our patients out of necessity and also convenience and cost considerations for the client. When a client requests an outside prescription it is only fair and just to provide this service with proper counseling on the use of the medication. To be forced to do it for every medication all for the benefit of " Big Box" retailers to tap into another source of revenue is wrong. It puts unfair pressure and liability on veterinarians, it puts owners in a position to cause harm to their beloved pets, and, of course, it opens significant pathways to injure pets through pharmaceutical mistakes.