As a manufacturer of animal pharmaceuticals, our sales base exists only of distributors and not directly to the consumer. Many of the distributors then sell to farm stores who sell to the end consumer. Therefore, providing data regarding sales for a specific species would only be guessing on our part and not adequately reflect the end use.
My other comment actually is directed to the current format for reporting. I am wondering what information is obtained from reporting monthly rather than yearly. This puts an extreme burden on our regulatory affairs department as it must be obtained all separately. The information is already provided in the annual reports, but not on a calendar basis but when the report is due.
Linda M Duple - Comment
This is comment on Proposed Rule
Antimicrobial Animal Drug Sales and Distribution Reporting
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