Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
After reading 625 public comments sent to the FTC and attending the FTC Meeting on Pet Medications in Washington DC on October 2, 2012 I think it best that the FTC use their own mission statement to guide them in their future actions and recommendations. The Federal Trade Commission's mission is to prevent business practices that are anticompetitive, deceptive or unfair to consumers. There was no compelling evidence presented in the public comments or at the meeting that veterinarians are anticompetitive, deceptive or unfair to pet owning consumers. The FTC should recommend to Congress that the proposed bill, H.R. 1406 Fairness to Pet Owners Act of 2011 is not needed and should be abandoned. The FTC should make a recommendation to the veterinary profession that state regulations and the AVMA Code of Ethics be followed. There was evidence presented at the meeting that some pharmaceutical manufacturers have anticompetitive policies. The FTC should use its legal authority to correct anticompetitive practices. There was evidence presented in the comments and at the meeting that problems exist with untrained pharmacists dispensing prescription medicines for companion animals. The FTC should make a recommendation to state boards of pharmacy and pharmacy associations that licensees and association member pharmacists and pharmacies refrain from dispensing prescription medicines they are unfamiliar with or untrained in. Pet owning consumers would otherwise be vulnerable to deceptive pharmacy practices. There was evidence presented in the comments and at the meeting that a large market for diverted prescription veterinary medicines and OTC veterinary products exists. This is deceptive to pet owning consumers. The FTC should use its legal authority to correct restriction of trade and recommend to state boards of pharmacy that all veterinary prescription drugs be required to be pedigreed in the pharmacy sales chain, similar to human pharmacy laws and regulations. The Federal Trade Commission asked for and received comments on ways to inform and empower pet-owning consumers to obtain the highest quality and cost-effective healthcare products for their pets. The FTC also conducted a meeting on October 2, 2012 to review and discuss "Competition & Consumer Protection Issues in the Pet Medications Industry". I urge the FTC to use their authority wisely and to follow their mission statement exactly when evaluating all the information and advice that they have obtained. Advice from practicing veterinarians should be highly regarded, because as a profession veterinarians place the health and well-being of their patients and owners at the highest priority. I believe the dispensing of the large array of prescription companion animal medicines requires the the special training of a veterinarian or suitable similar training in of a pharmacist in veterinary pharmacology. I believe the FTC should have the same conclusion from the information they have accumulated.