Submission Number: 560891-00500
Received: 9/14/2012 5:19:12 PM
Commenter: Kerry Jackson
Organization: East Orlando Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Thank you for allowing comments regarding veterinary prescriptions.
Florida Veterinary Practice Act requires that a written, portable prescription be provided upon request by a pet owner of their veterinarian. Even without this requirement, I, and many of my associates regularly provide written prescriptions for medications offered for free or at a greatly reduced price at local pharmacies. This reduces our need for inventory and storage of generic and common drugs, and allows the owner to afford a better standard of care for their pet.
The problems I encounter with certain situations are as follows:
Pet Med Express, an online pharmacy, routinely and frequently violates federal law by dispensing prescription Heartgard to dog owners without a valid veterinary prescription, and disregards the potentially fatal side effects of this heartworm prevention if used in undiagnosed heartworm positive dogs.
Pharmacists receive no training nor are required to complete any continuing education in veterinary pharmaceuticals. In my experience, I have had pharmacists that do not understand veterinary abbreviations, do not dispense the correct drug, and use a form of the drug different that prescribed that contains xylitol, a sweetener toxic to dogs. Pharmacists have informed owners that the dose was incorrect based upon human dose alone, and change the dose without consulting the veterinarian with fatal results in the patient.
If veterinarians are forced to use human pharmacists to dispense animal drugs, we will have to retrain ALL pharmacists to include the 2 years of veterinary pharmacology that veterinarians are required to complete. Then, these pharmacists would need to complete 4-10 hours of continuing education in veterinary pharmacology to remain competent in dispensing veterinary drugs. Remember that small animal veterinarians alone see 10-20 different species, each with its own idiosyncracies regarding which drugs can be used, what dose would be safe, and different manifestations of side effects.
Or, we could just utilize the existing resources provided by trained veterinarians, who not only know what drugs to dispense and when, but can provide correct prescriptions when that we know pharmacists can fill without undue risk to the pet.
It is very obvious that a pet owner has no trouble accessing drugs for their pets given the sales of online pharmacies alone. It would be wrong and dangerous to bow down to corporate greed over small businesses that provide safe and effective pet care. This can only result in poorer care and service to the pet owning public.
Thank you for allowing comments on this matter