Memorandum submitted by the Council of
the Laboratory Animals Veterinary Association (Vet 23)
EXECUTIVE SUMMARY
1. The Council of the Laboratory Animals
Veterinary Association (LAVA) believes that the Royal College
of Veterinary Surgeons (RCVS) should have the power to delegate
specified procedures to people holding qualifications recognised
by the RCVS Council.
2. It believes that one such group of people
should be non-veterinary surgeons who hold Personal Licenses granted
under ASPA by the Home Office.
3. It believes that such Licensees should
be allowed to use the techniques specified on their licence for
diagnostic or therapeutic purposes, so long as they are working
at Designated Establishments, under the direction of the Named
Veterinary Surgeon who has the animals under his or her care.
SUBMISSION
1. The Council of the Laboratory Animals
Veterinary Association (LAVA) supports the view that the Royal
College of Veterinary Surgeons (RCVS) should have the power to
delegate specified procedures to people holding qualifications
recognised by the RCVS Council.
2. This is in agreement with the RCVS stated
aim of increasing the range of tasks that veterinary surgeons
are able to delegate to appropriately trained paraprofessionals.
3. The following comments apply specifically
to the role of veterinary surgeons and persons holding Personal
Licensees in establishments designated under the Animals (Scientific
Procedures) Act 1986 (ASPA).
4. In ASPA Designated Establishments, many
of the same procedures may be carried out on an animal for either
clinical (diagnostic or therapeutic), or scientific reasons. The
former are carried out by veterinary surgeons as acts of veterinary
surgery under the Veterinary Surgeons Act 1966 (VSA), the latter
by Personal Licensees under ASPA: the distinction being whether
or not the procedure is carried out for the benefit of the animal
or its peers, or whether it is for a scientific purpose.
5. Personal Licensees are persons licensed
by the Home Office to carry out specified techniques under ASPA
for a scientific purpose. Personal Licensees must be competent
to perform the techniques for which they are licensed and frequent
repetition of the procedure can allow them to become very skilled
indeed at a limited number of techniques. For example, in small
rodents, a Licensee may be more skilled at withdrawal of a blood
sample, or embryo transfer, than a veterinary surgeon that performs
such procedures only rarely. In this case, allowing the skilled
Personal Licensee to perform the same technique for diagnostic
reasons would actually result in improved animal welfare.
6. We suggest that Named Veterinary Surgeons,
employed by the Certificate Holder of ASPA Designated Establishments,
should be able to delegate to Personal Licensees, those procedures
for which the Licensee is already trained and holds a current
Home Office Licence.
7. The Home Office sets out the training
required for, and regulates the issue of, Personal Licences. In
addition, many scientific establishments work to GLP standards
and maintain training and competence records for their staff.
8. LAVA has been in discussion since at
least 1992 with the RCVS regarding the delegation of procedures
in establishments designated under the ASPA.
9. The deregulation of Procedures Designated
as Acts of Veterinary Surgery was the subject of an extensive
consultation between 1998 and 2000 by the "Schedule 3 Working
Party" chaired by Professor A R Michell, then president of
the RCVS. LAVA was represented on this Working Party.
10. The resulting RCVS policy was sent to
the Rt. Hon Nick Brown MP, then Minister of Agriculture, Fisheries
and Food, on 6 July 2000. This document received unanimous support
from the RCVS Council and the Council of the British Veterinary
Association. It provided a framework for liberalising the freedom
of veterinary surgeons to delegate specific tasks to suitably
trained paraprofessionals while safeguarding the clinical welfare
of patients. In our view it provided an entirely satisfactory
alternative to new exemption orders under Schedule 3, and LAVA
believes that the recommendations of this Working Party should
be included in any new VSA.
11. This matter was raised formally with
Mr A Hughes of the Animal Welfare Division of MAFF on 7 August
2000, but has not subsequently been progressed by Defra.
September 2007
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