Submission Number: 560891-00395
Received: 9/13/2012 8:49:00 AM
Commenter: Harold B. Hubbard
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As a practicing veterinarian for 57 years I wish to offer these comments about the pet medication
industry. I cannot attend the Workshop but would like these comments entered into the record.
Most pet medication companies are part of a larger corporation, with finances and resources that
all practicing veterinarians do not possess! Therefore, in the first place, competition is unfair!
Furthermore, I know many pharmacists and pharmacologists who have never STUDIED animal
anatomy, physiology, pathology, microbiology and clinical medicine! Under FTC and FHA
regulations, how can these persons be qualified to prescribe, administer and recommend
medications, many of which can be hazardous to the health of the animal, without a patient/
veterinarian relationship? The FDA is stringent with the veterinary profession about com-
pounding medications without their approval. How is it then that the pet medication industry
can ship medications as instate commerce or sell them at their store outlets?
When there is a medication bad reaction by the patient, where does the client take
their animal for help? The veterinarian ; not the pet medication pharmacist!! If the pet
medication industry can prescribe, recommend or administer the medication then they
should be responsible for the patient by legal regulations by the FTC/ FHA. Owner benefits
and privileges are one part but the health of the animal is paramount!
Harold B. Hubbard, DVM, MPH,; [redacted]