Memorandum submitted by the British Veterinary
Nursing Association (Vet 19)
INTRODUCTION
1. The British Veterinary Nursing Association
(BVNA) is the representative body for veterinary nurses and veterinary
paraprofessionals in Great Britain. It has fulfilled this role
since its inception in 1965 and it has worked with other veterinary
organisations including the Royal College of Veterinary Surgeons
(RCVS) and the British Veterinary Association (BVA) to facilitate
the development of the veterinary nursing training scheme. The
main aim of the BVNA, as outlined in its mission statement, is
the promotion of animal health and welfare through the ongoing
development of professional excellence in veterinary nursing.
As part of this commitment the BVNA fully supports the introduction
of formal regulation by means of a statutory register for qualified
veterinary nurses, ie individuals who have fulfilled the RCVS
requirements for Veterinary Nurse or Equine Veterinary Nurse (VN/EVN)
status.
1.1 The present RCVS VN training scheme
has enabled standardisation of trained veterinary nurses in this
country and has provided a template for the training of veterinary
nurses in many other countries. In its present format it enables
student nurses to attain upon qualification a level of clinical
competence similar to that of human-centred nurses and indeed,
the original VN training scheme was based on that of the SRN when
it was introduced in 1961. Qualified veterinary nurses are trained
to work in a number of aspects of veterinary practice including:
— Nursing care of inpatients;
— Client education and support;
— Monitoring of anaesthesia;
— Performing laboratory analysis
on clinical samples; and
The special status of qualified veterinary nurses
was recognised in 2000 when an Amendment to Schedule Three specified
that listed VN/EVNs were able to perform minor acts of surgery.
Are the provisions of the 1966 Veterinary Surgeons
Act out of step with developments in the veterinary and related
professions?
Should there be regulation of veterinary care
providers other than veterinary surgeons?
2. The BVNA considers that the 1966 Veterinary
Surgeons Act, whilst appropriate for its time, has now been superseded
by the requirements of modern veterinary practice. Today's small
animal clients demand a more sophisticated approach to the care
of their pets and veterinary practice has developed to meet these
demands. One of the most significant of these developments has
been the broadening of the role of the qualified veterinary nurse
(VN). The availability of qualified nursing care for veterinary
patients has enabled the veterinary surgeon to delegate appropriate
aspects of clinical management to suitably trained individuals
which in turn allows for the maximisation of patient welfare.
2.1 The identification and delegation of
specific nursing responsibilities mirrors the development that
has taken place in human-centred nursing and the BVNA would advocate
that the resultant increase in the assumption of responsibility
for patient care be restricted to regulated individuals to ensure
standardisation of patient care and professional accountability.
These would therefore be persons who have received appropriate
training and who are required to subscribe to a framework of accountability
as stipulated by an appropriate regulatory body. The RCVS would
appear to be the most logical regulatory body at this time and
it has taken the first step towards formal regulation of VN/EVNs
by introducing a non-statutory register in September of this year.
2.2 The BVNA would see this move towards
regulation and accountability for qualified veterinary nurses
as a positive one in that it would provide a framework for the
VN/EVN to work with the veterinary surgeon in a complementary
manner as part of a team of healthcare professionals. This framework
should ideally promote and develop the existing role of the VN
rather than undermine the existing role of the veterinary surgeon
which is predominately to diagnose and treat illness and to take
overall responsibility for the care of veterinary patients.
2.3 Whilst the 2002 amendment to Schedule
Three of the 1966 Veterinary Surgeons Act formally recognises
that qualified, listed VNs receive training that allows them to
perform techniques such as minor acts of surgery, this has had
no significant effect upon the development of a professional ethos
for veterinary nurses that recognises the increased levels of
nursing care that VN/EVNs are able to provide. This requires the
definition of an individual and specific role separate to that
of the veterinary surgeon. Although the recent introduction of
veterinary nursing degree programmes has prompted a growth of
this nursing culture, there is still a need to fully recognise
the role that the veterinary nurse plays in today's veterinary
practice and the BVNA believes that this can only be fully facilitated
by means of the legal recognition of the existing VN/EVN qualification.
2.4 A formal framework as developed by the
RCVS will allow for standardisation of training which should promote
confidence in the provision of veterinary nursing care. The RCVS
proposal and introduction of non-statutory regulation will, if
further supported by a new Veterinary Surgeons Act which recognises
the importance of the role played by these uniquely qualified
individuals enable this standardisation to take place by means
of compulsory regulation, retraining for those individuals who
opt to return to veterinary nursing following a significant period
of absence and a formal disciplinary procedure to deal with complaints
against registered VNs.
Should the delivery of veterinary services be
regulated through a mandatory practice standards scheme, with
a professional code of ethics, rather than the RCVS regulating
practitioners on an individual basis?
3. In principle, the BVNA supports mandatory
regulation of veterinary practices by means of further development
of the existing RCVS Practice Standards Scheme. However, this
should not undermine the principle of individual professional
accountability based upon the use of a professional code of conduct/ethics
for both the veterinary surgeon as well as other potentially accountable
veterinary staff such as qualified veterinary nurses.
Should the RCVS and VNC be given the power to
require CPD and revalidation?
4. If the principle of regulation for qualified
veterinary nurses is accepted, the BVNA fully supports the proposed
RCVS model of compulsory CPD, a formal disciplinary process and
revalidation of those VNs who have not practised for a significant
period of time. However, whilst the initial stages of this process
are being implemented by RCVS at the present time, the BVNA would
welcome the eventual inauguration of a separate body specifically
dedicated to the regulation of veterinary nurses. It is envisaged
that this would mirror the existing regulatory structure of both
doctors and nurses within the medical profession.
Should the governing body of the RCVS and VNC
include appointed lay persons as well as veterinary professionals?
5. The BVNA is fully supportive of the concept
of appointing appropriate lay persons to play an important role
in the regulation of all veterinary professionals. The inclusion
of lay persons is integral to a transparent regulatory mechanism
which would help to ensure fair treatment of both veterinary nurses
and the public as well as maintaining the all important concept
of duty of care to patients.
Should the RCVS and VNC have a separate conduct
committee with the powers to investigate complaints, give warnings
and to make interim orders pending proceedings?
6. The BVNA strongly believes that separate
conduct committees for both veterinary surgeons and veterinary
nurses are essential as a separate VNC conduct committee composed
of nurses and lay persons would be better placed to deal with
disciplinary matters concerning VNs in a fair and unbiased manner.
As the majority of VN/EVNs are directly employed by veterinary
surgeons it could be argued that there is a potential conflict
inherent in a dual role for veterinary surgeons in this respect.
Should the RCVS have the power to delegate specified
procedures to people holding qualifications recognised by the
RCVS Council
7. The BVNA believes that the RCVS should
have the power to delegate specified procedures to qualified,
registered veterinary nurses as this concept is entirely compatible
with the emerging role of the qualified veterinary nurse. The
precedent has already been created with the amendment to Schedule
3 of the Veterinary Surgeons Act which allowed legal recognition
of qualified veterinary nurses. However, the actual details of
what may be performed by qualified and listed VNs has been kept
deliberately vague and if regulation is introduced the BVNA would
strongly support the identification of a specific role for the
VN which would allow for a greater degree of autonomy whilst ensuring
compatibility with the existing role of the veterinary surgeon.
SUMMARY
8. The BVNA is committed to the promotion
of increased animal welfare and patient care within the veterinary
environment and as such considers the introduction of regulation,
by means of a statutory register, an essential requirement for
qualified veterinary nurses.
8.1 The proposed revision of the Veterinary
Surgeons Act would be an ideal opportunity to introduce such a
register and the BVNA would support legal recognition and a greater
degree of autonomy within the confines of a formal nursing role
for the registered veterinary nurse.
8.2 The existing veterinary nursing qualification
was developed in response to a need expressed by veterinary employers
and has been in existence for several decades. As such it is a
proven qualification which is well recognised within the veterinary
environment and increasingly by the general public.
8.3 The BVNA commends the preparatory work
undertaken by the RCVS in developing and introducing a non-statutory
register to replace the existing list of qualified veterinary
nurses and would see this as a suitable framework upon which to
build the new regulatory structure. This should be facilitated
by means of the imposition of a code of conduct, a compulsory
CPD requirement and a disciplinary procedure which should encompass
the use of appropriate lay persons.
September 2007
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