Submission Number: 560891-00468
Received: 9/14/2012 11:25:53 AM
Commenter: Sarah Ripper
Organization: Teegarden Veterinary Clinic
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 in opposition of HR 1406, Fairness to Pet Owners Act. As a Certified Veterinary Technician (CVT), working in the veterinary medical industry for over 6 years, I have first hand experience with dispensing and instructing owners on veterinary medications. I believe that if this Act is passed, it will create problems that may be to the detriment of pets, and ultimately to their owners, due to the loss of pets and increased medical expenses.
First, this Act will create delayed compliance with the administration of necessary medications used to treat particular diseases. One example is that often times my Veterinarians start treatment with injectable medications that need to be followed up with the administration of the same medication in oral form within 12 to 24 hours. This is done in cases where oral medications may not be able to be administered right away due to anesthesia or vomiting. If the pet owners elect to fill the oral counterpart at a pharmacy to continue treatment, there could be a chance that the particular medication could not be dispensed at that time due to several reasons. The pet owners would then have two options: wait for the medications to be filled at the pharmacy which may take days and miss the scheduled administration time, potentially causing treatment failure and adverse effects on the pet’s health; or return to the Veterinary Clinic to fill the medication incurring further travel cost to the detriment of the pet owner’s expense.
Delayed compliance may also be hindered when veterinary exclusive medications are prescribed. Many medications used to treat pets are exclusive to veterinary medicine and are used for specific diseases and conditions. These medications are specifically labeled for use in animal species and are not for use in humans. Like our clinic, I am sure that pharmacies try to keep their overhead cost down to a minimum. One way to do this is to only stock medications that are frequently used and special order those that are rarely used. I fear that these veterinary exclusive medications will only be ordered as needed and patients will not be started on vital medications in a timely manner. My Veterinarians understand that the prompt administration of certain medications is critical to the treatment of special cases and we routinely stock these medications even if it hurts our bottom line.
Second, this Act will create further confusion of veterinary safe medications and human medications particularly in the over-the-counter (OTC) market because of the lack of veterinary pharmaceutical education with pharmacy personnel. If this Act is passed pharmacy personnel/Pharmacists will be looked on for expertise by pet owners on prescription and OTC medications regarding pets; however, they do not have the education and knowledge to answer those questions. I’ve had many examples like this in my clinic; a dog owner feels like their pet is in pain so they give them Aspirin for a few days, because their breeder, the internet, or a friend with human medical experience suggested it. These sources all have some sort of expertise somewhat related to the veterinary industry but they all give misleading information. When the symptoms do not improve, they come into the clinic to find out their dog has Intervertebral Disc Disease (IVDD). My Veterinarians’ treatment of choice for this disease is corticosteroids; however, these are contraindicated when a non-steroidal-anti-inflammatory medication like Aspirin is administered, thus prolonging the time the necessary treatment can be started to the detriment of the pet. If this pet owner had contacted the clinic and talked with one of our CVTs or Veterinarians, the pet’s symptoms, breed dispositions, contraindications, and treatments of choice would have been considered when giving advice in these cases and proper treatment could have been instituted immediately, yielding a better outcome for the pet.