Submission Number: 560891-00725
Received: 10/30/2012 3:24:54 PM
Commenter: Susan Longo
Organization: Annapolis Cat Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As a professional, I am charged not only legally, but ethically, to advocate for my patient's health. I have concerns about how the marketplace has inserted itself as a substitute for learned and experienced professional care. And consequently the value of medical expertise is lost. Unfortunately, the uneducated consumer assumes that the internet will only "publish" or otherwise make available information and products that the government has sanctioned. I have even had a client remark: "the government wouldn't let the internet sell counterfeit products." This seems to place undo pressure on your agency, especially given the rampant availabilty of all sorts of illegal merchandise at the touch of a button. It seems to me that the charge of your agency, and even more so the FDA, is to protect the consumer against unsafe business practices and products, as well as the unnamed and untraceable charlatan.
I am concerned that my client will believe I have confidence in "medications" sold over the internet simply because I have faxed a prescription. I am reluctant to inform my client that these "pharmacies" have been known to sell inferior and mislabelled products because those businesses have been known to financially crush the "problem" small practices with legal fees. This lack of confidence concerns me further in case that product is not only ineffective but actually harmful to my patient. Does this mean I am legally responsible for my patient's suffering and my client's costs? Quite a sobering thought for a small business owner.
All in all, I feel the internet is a faceless conglomerate that can act with complete impunity, knowing it can shift the blame and legal ramifications to me as a small business owner with a face and storefront and a reputation.
Just wondering when the FDA and FTC will step up to the task of truly protecting the consumer instead of concerning itself with those who have no knowledge, little investment in the patient or client,and no peril of accountability for shady practices.