Although I live in Maryland, my veterinarian is in Virginia (VCA Alexandria Animal Hospital).  This is because I am convinced they provide me with high quality care, and I had a bad experience when I switched to a Maryland vet after moving here, so I drive back to Virginia.  I spend THOUSANDS of dollars a year there, since I have several elderly cats with chronic conditions.  These conditions include those which cause pain (arthritis); I also lost a cat to cancer and needed pain control for him and for a cat that threw a blood clot.  Although none of my pets are currently on opiates, I want to comment because it could happen any time with this old, sick crew.

I am against this regulatory change for two reasons, in order of importance:

1.  It will not make a significant contribution to reducing the opioid crisis.  The doses of these drugs prescribed for our pets are very small, would not be affective for humans, and if on some weird off-chance a human decided to swallow their pets entire week or months presciption to get an effective dose for themselves, this would become readily apparent t the prescribing vet because the owner would be contacting them asking for refills long before due, etc.

More importantly, the contribution veterinary drugs make to the opioid crisis is through DRUG DIVERSION by practitioners and staff.  This regulation will not do anything to stem that, and will create complications for veterinarians and clients seeking to provide adequate pain control for pets.  Lets put the regulations and effort where it can make a difference - identifying and stopping drug diversion by practitioners.

2.  It may lead to unintended consequences that harm pet health.  As the owner of cats, I am very aware of the dangers that Metacam and other NSAID pain control options pose for them.  If, due to the regulatory complications of prescribing a drug like buprenex, veterinarians beging prescribing more metacam, the result will be cats in kidney failure and angry clients.  By the same token, another potential consequence of this rule will be that veterinarians do not provide pain control for patients at all.  This will take us back to the dark days when our pets were expected to suffer without aid.  Many of hte pets in my charge over the years have had multiple extractions during dentals, some have had abdominal surgeries.  I cannot imagine how horrible it would have been if they had either not had pain control, or had a form of pain control that threw them into organ failure.

Again, because of the unintended consquences and because it will not contribute to stemming the opioid epidemic, I ask you to drop this regulation.  Thank you.

Stefani Olsen

3004 Dawson Avenue, Silver Spring MD 20902

Client of VCA Alexandria Animal Hospital