Submission Number: 560891-00462
Received: 9/14/2012 10:34:40 AM
Commenter: Charles Franz
Organization: Alabama Veterinary Medical Association
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
September 14, 2012
Federal Trade Commission
Office of the Secretary
600 Pennsylvania Avenue, N.W.
Room H-113 (Annex X)
Washington, DC 20580
The Alabama Veterinary Medical Association (ALVMA) appreciates the opportunity to comment on the issues involving H.R. 1406, Fairness to Pet Owners Act of 2011. The ALVMA opposes enactment of this bill because it is unnecessary. We would agree that pet owners should have the ability to obtain prescription veterinary medicines by obtaining a prescription from a veterinarian but that ability already exists without the need for federal legislation. We believe that enactment of the bill will put an unnecessary paperwork burden on veterinarians and would likely place the health of animals and, possibly, their owners at risk.
This legislation, if enacted, would place an undue burden on the veterinarians who have devoted their lives to caring for these animals. The requirement for a veterinarian to provide a written prescription each time a product is prescribed for a companion animal would be a ridiculous increase in time required. In addition, the legislation would require a veterinarian to provide a written notification that the prescription could be filled elsewhere. The ALVMA supports a client’s choice to fill a prescription at the location of the client’s choice and does not oppose providing a written prescription for clients who prefer to have it filled elsewhere. However, we strongly oppose a federal mandate to provide a written prescription each time a product is prescribed, regardless of whether a client wants to go elsewhere.
The American Veterinary Medical Association’s Principles of Veterinary Medical Ethics encourages veterinarians to honor a client’s request for a written prescription. State laws already govern veterinary prescription writing; in fact, many states have laws requiring a veterinarian to honor a client’s request for a copy of a prescription.
Veterinarians have been trained extensively in the use of drugs and are, without question, the best-qualified professionals to address any issues related to the dispensing of prescription products for animals. Veterinarians are the only professionals licensed to write a prescription for an animal. The veterinary profession is currently working with the pharmacy community to address challenges they face due to a lack of training in veterinary pharmacology. The veterinary profession will continue to address this issue in its effort to insure that animal patients receive proper medications at proper dosages.
Some have suggested there are similar issues between H.R.1406 and the Fairness to Contact Lens Consumers Act (FCLCA). We believe this is an unrealistic comparison. Contact lenses are a single commodity, dispensed by retailers familiar with the products. There are hundreds of veterinary prescription medications labeled and regulated by the FDA for animal use and hundreds of human medications regularly prescribed for animal use. Multiple animal species with many animal breed drug response variations exist. Doses, side effects, contraindications and interactions are variable depending on these species and breeds. A pharmacist, unless having had experience or advanced training, is unlikely to have sufficient knowledge to properly dispense or give accurate advice to pet owners. There are very few pharmacists who have had this degree of training.
To summarize, the ALVMA believes H.R. 1406 would place onerous regulatory burdens on veterinarians. Market forces will accomplish the intended goals of the proposed legislation without the need for its enactment. We believe that dispensing prescriptions of animal medicines requires the special training of a veterinarian or the additional, similar training of a pharmacist. Enactment of H.R.1406 will put pets at risk and the additional regulation is unnecessary.
Charles F. Franz, DVM William M. Allen, DVM
Executive Director President