Memorandum submitted by the Animal Medicines
Training Regulatory Authority (Vet 01)
1. AMTRA is responding to the invitation
make a submission on the need to replace the Veterinary Surgeons'
Act 1966. These are some preliminary comments in advance of discussion
by the Council and Board of AMTRA, after which AMTRA may wish
to make a further submission.
2. AMTRA is recognised by the Secretary
of State under the Veterinary Medicines Regulations as the body
responsible for the training and registration of Suitably Qualified
Persons (SQPs) who are permitted under those Regulations to prescribe
and/or supply POM-VPS and NFA-VPS Medicines.
3. Until 2005 only Veterinary Surgeons could
prescribe animal medicines, but from 30 October 2005 a new category
of animal medicine, POM-VPS was introduced and they can be prescribed
by veterinary surgeons, pharmacists operating from a pharmacy
and AMTRA SQPs operating from registered premises. That is a fundamental
change which has implications to the role of veterinary surgeons.
Indeed many veterinary nurses are now registering with AMTRA so
they may legally prescribe and supply POM-VPS and NFA-VPS medicines.
4. AMTRA does have some initial representations
to make. In particular the offering of advice on the selection
of, or use of, a licensed POM-VPS medicine is what AMTRA trains
its SQPs to do. It is therefore wrong for the Veterinary Surgeons
Act, as the current one does, to try to prevent SQPs from using
that training and expertise in offering appropriate advice to
animal owners based upon their specialist training.
5. When an animal owner enters a premises
registered for the sale and supply of POM-VPS medicines, and asks
for a medicine for a particular purpose it must be open to the
SQP to ask the customer a number of questions to determine if
a particular medicine, eg an anathematic, is the appropriate product
to offer, and if so which particular product. It is no longer
appropriate for the skilled SQP to be expected to merely say to
the animal owner in such circumstances "all I can suggest
is that you consult your vet". That is both unnecessary and
a waste of the SQP's training and expertise in the field of POM-VPS
medicines. It is also appropriate, so that SQPs can offer the
right advice on the selection and use of POM-VPS anthelmintics,
that they be permitted to offer a faecal egg count service to
the customers, so that the advice they offer can be of the highest
possible quality. In general, the main aim of any new Act should
be to help ensure the highest degree of animal health and welfare,
it should avoid unnecessary prohibitions, or restrictive practices,
allowing those qualified to do so to offer the necessary service
to the animal owner.
6. For example, the following should be
specifically allowable under any new Veterinary Surgeons Act.
— the provision of advice on the
selection of and/or the use of an animal medicine that is POM-VPS
or NFA-VPS by a persons who is a member of the AMTRA Register
of Suitably Qualified Persons operating from a premises registered
for the sale and supply of POM-VPS or NFA-VPS medicines, or by
a pharmacist operating from a registered pharmacy.
— the provision of a service to
animal owners involving the sampling of faeces and the subsequent
offering of advice on the appropriate choice of POM-VPS anthelmintics
based upon the interpretation a scientific analysis of the sample
of faeces by an approved veterinary laboratory.
7. As indicated earlier, AMTRA may wish
to make a further submission after discussing the issue at its
Council/Board meetings in September 2007.
July 2007
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