Submission Number: 560891-00728
Received: 10/30/2012 9:06:23 PM
Commenter: Brad Everson
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
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First, let this discussion begin with the acknowledgement from both parties that this issue deals strictly with financial, trade, retail issues. If the ‘retailers’ had any interest in the well being of animals, the human animal bond, or preventing animal and human suffering/disease then they would have devoted their lives to veterinary medicine, biological sciences, or animal support industries. They would already have an understanding of these issues thus negating the need for a workshop. It is clear in the 2nd sentence of the supplementary information that House Bill 1406 is about the $7 billion out of $53 billion that ‘retailers’ feel they ‘missed out on’. Calling HB 1406 the ‘Fairness to Pet owners Act’ indicates that veterinarians are unfair or deceitful and undermines the lifelong dedication, expensive education, and compassionate care that are the foundation of the veterinary profession. If ‘retailers’ are willing to subjugate our profession so profoundly at the onset of this discussion then how should we have any faith that they will try to understand the issues involved or even care about them. At this time, profit seems to be the only thing ‘retailers’ are concerned with so the bill should be renamed ‘Retailers want pet owners’ money but want veterinarians to do the work Act’. Furthermore the bill says that veterinarians can’t charge for their services and that we must be liable for their potential mistakes which we have no control over. Consumer protection is a misnomer as the consumer is viewed as a commodity that must be protected by the ‘retailer’ so that this consumer can purchase everything from them. This bill would actually hurt the consumer in the end.
Perhaps the main purpose of this workshop is to tell pharmaceutical manufacturers that they must sell their product to anyone that wants to buy from them, in this case we’ll call them ‘retailers’. Diversion (grey market sales) is morally and ethically wrong (although technically not always illegal, it is illegal in some instances). It is done with total disregard for the Veterinarian’s Oath that all vets should be familiar with. This area of commerce is also unregulated and seems to nearly model the illegal drug trade. Instances of repackaging, faulty handling, and counterfeit products have all been documented. This issue doesn’t concern most veterinarians, who by in large, will play by the rules we are given (except the wayward few lured by quick profit). If someone wants to sell their product to a group they feel is more qualified and not another then that should be their decision. To undermine their decision with diversion is childish chicanery and wrong. If someone wants to purchase prescription medications without a valid prescription they are not legally able to do so because they are unqualified. They may attempt to purchase the medication through alternate channels but this is nefarious and potentially dangerous. We do not allow this and we should not allow diversion of veterinary pharmaceuticals.
In an attempt to facilitate the requests of the workshop I will attempt to answer the questions asked (see the attached document).