Submission Number: 560891-00609
Received: 10/11/2012 7:30:29 PM
Commenter: Bonnie Walker
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am opposed to the proposed legislation H.R. 1406, Fairness to Pet Owners Act 2011. Pet owners should have the ability to obtain prescriptions to SAFELY obtain medications for their pets. This presciption process is already in place and being utilized by pet owners. Passing legislation for a process that already exists is not only redundant, but burdensome and costly, both to the government and veterinary clinics (small businesses).
Veterinarians are the most highly trained individuals to provide the best professional guidance and education to pet owners when dispensing prescription products. They are trained on multiple companion animal species that consists of hundreds of breeds, and are educated to understand the multitude of doses, contraindications, drug interactions and side effects.
To address the issue of SAFELY obtaining medications for animals, unless human pharmacists have had advanced training, they do not have sufficient knowledge of species and even breed nuances to dispense and advise on animal medications safely or give accurate advice to pet owners. In fact, I have seen cases of pharmacists switching out medications, without the veterinary prescriber's consent, that have had detrimental health impacts on the animals.
There are two additional issues which must be brought to light: 1)prescription fraud and 2) on-line pharmacy fraud. I know a veterinarian whose clinic has personally dealt with prescription fraud which involved local law enforcement and someone who had obtained a blank copy of a prescription form then made copies to use any way they chose. The other concern is on-line pharmacy fraud. If the government forces veterinarians to hand out written prescriptions, people can use them wherever they choose, and there are numerous unscrupulous on-line pharmacies out there selling fraudulent, sometimes toxic or black market obtained products.
If this bill passes, we will lose the ability to protect ourselves from fraudulent prescriptions and our patients and clients from fraudulent on-line pharmacies. In both cases it appears that we will be held accountable for prescribing situations over which we will no longer have control.
If the goal is to protect pet owners and the animals they cherish, this is not the way to do it. In fact, passage of this legislation will put pets at risk and make owners vulnerable. I do not believe society will be well-served by mandating a move away from veterinarians in medication procurement.