Submission Number: 560891-00624
Received: 10/14/2012 1:45:37 PM
Commenter: Karen Raisanen
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
PLEASE DO NOT PASS HR 1406!!
I have been a credentialed veterinary technician for 29 years, and there have been multiple times that I have treated animals whose problem was a result of pharmaceutical error. The wrong medication has been sent, wrong dosages prescribed, and I have been involved in three of these that resulted in patient death! I can't tell you how many times we have had to hospitalize and treat those who have survived such incidents. We in the veterinary community work with these dosages day in and day out and it catches our attention when a dose just doesn't sound right(like 0.9 mg vs 9 mg) The human pharmacist has no point of reference to cue them that that is an excessively high dose. Furthermore, we know our patients and their size, and a human pharmacist will not be able to develop a feel for appropriate dosing because he doesn't know if the script is for a 4 pound chihuahua or a 190 pound mastiff, a much broader range of dosing than in people, who do not have such a broad range of weight and thus dose.
Please do not pass this legislation! I am certain that we will see an increase in inappropriate dosing, and the pets (and pet owners) will end up paying the price. Sometimes pharmacists think they know what dose an rx should be and they fail to notice things like decimal points, the result of which are often fatal! Our trained technicians fill the prescriptions, which are then reviewed by a licensed veterinarian before they are sent home with a pet owner. Our rate of accuracy far exceeds that of a human pharmacist. HR 1406 is a really bad idea, driven by big business who only see dollar signs, not the suffering of animals and their owners that pharmaceutical errors cause.