Submission Number: 560891-00404
Received: 9/13/2012 12:28:00 PM
Commenter: Spencer Tally
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am writing to express my concern regarding H.R. 1406, the Fairness to Pet Owner Act. I oppose the bill. The interest of large retail stores should not dictate how veterinarians operate their practices. The prescribing veterinarian is the most appropriate professional to provide guidance and education when dispensing a veterinary prescription product. This legislation is unnecessary and redundant. State laws already govern veterinary prescription writing, making this bill unnecessary. Pet owners already have the freedom to take a prescription to be filled at the pharmacy of their choice. Also, the AVMA has a long standing policy encouraging veterinarians to write a prescription in lieu of dispensing when asked by a client. This bill would create unnecessary paper work and could result in increased office visit fees beyond what some pet owners are able to pay in this economy. It could ultimately compromise pet and animal health. As a licensed pharmacist, I am also concerned about the limited training pharmacists have in veterinary pharmacology. Animal doses can vary greatly from human doses. There are multiple companion animal species with hundreds of breeds. Drug doses can vary greatly among different species and breeds along with contraindications, side effects, and drug interactions. Lack of specific training in veterinary pharmacology can lead to pharmacists altering the drug dose which can result in loss of therapeutic effect or overdosing with potentially fatal consequences. Drug substitution in veterinary medicine can result in lack of therapeutic coverage. For example, a heartworm prevention product prescribed may also treat intestinal parasites; substitution to a different heartworm product may not have the same intestinal parasite coverage. The result could lead to compromised pet health care with zoonotic consequences. Animal health and public health could be at risk. Thank you for your consideration of my concerns.