Memorandum submitted by the World Wide
Association of Equine Dentistry (Vet 26)
1. The World Wide Association of Equine
Dentistry (WWAED) welcomes the opportunity to comment on the proposals
from the Royal College of Veterinary Surgeons (RCVS) on reviewing
the Veterinary Surgeons Act (VSA). We applaud the EFRA for initiating
a broad and open review of the future of regulation of the veterinary
team.
2. The veterinary team continues to expand
and one area of recent growth is equine dentistry. The WWAED represents
professionals dedicated to ethical, practical care for horses
and horse teeth. We support the idea that a qualified body of
independent, professional equine dentists should be able to provide
treatments and services in this area in conjunction with other
competent professionals. The WWAED is an international organisation
established in the USA 1991, in Canada 1992, in Australia 1995
and in the UK in 2001. The UK Chapter has a membership of 30 consisting
of full and probationary members. The WWAED is recognised by the
DEFRA and the RCVS as a course and examination provider for the
proposed Exemption Order Examination for Advanced Equine Dental
Procedures.
3. We have responded to the proposed changes
to the VSA as identified in your email in the order as follows:
Whether the provisions of the 1966 Act are out
of step with developments in veterinary surgery and related professions
4. The current regulatory system is failing
to protect the public and their animals. There is a significant
system in place at the RCVS for Veterinary Surgeons. This includes
education, standards, regulation and discipline. Most other aspects
of provision of veterinary services have to fit awkwardly into
this system. The mechanism has been a system of exemption orders,
developed by DEFRA, with advice from the RCVS. The system is awkward
because DEFRA has had to understand what could and should be regulated,
but is faced with advice from a variety of competing sources.
Whether there ought to be regulation of providers
of veterinary care other than veterinary surgeons
5. The system for accountability for those,
other than veterinary surgeons, is unclear. Equine Dentistry is
currently either self-regulating or if the equine dentist is a
member of an Association, he/she conforms to their code of conduct
and disciplinary procedure. It is not compulsory for an equine
dentist to belong to an Association so the welfare of the animal
is only protected by the new Animal Welfare Act.
Whether the delivery of veterinary services ought
to be regulated through a mandatory practice standards scheme,
with a professional code of ethics, rather than the RCVS regulating
practitioners on an individual basis
6. Although not mentioned in this consultation,
we are aware that competition issues are having a major impact
on Veterinary Surgeons. Good regulation should be proportionate
and balance the public interest for best value in service delivery
with the protection of the vulnerable. Veterinary Surgeons are
now embracing the use of professionals in other areas, be it in
equine dentistry, animal manipulation or cattle feet trimming.
Experience has shown that resisting competition benefits no one
in the long term. However, within equine dentistry there is more
than one organisation, the British Equine Veterinary Association
(BEVA), the British Association of Equine Dental Technicians (BAEDT)
and the WWAED. This may pose problems as to who sets the standards
for each group, who judges if standards are met, who decided and
administers any disciplinary action? This is an issue for public
and animal protection and also fair competition and sanction.
Although we would support the setting up of
a council to govern equine dentistry, the WWAED suggests there
should be a common framework to ensure fair and even setting of
standards and a common approach to discipline for all levels of
equine dentistry provided by any practitioners. This could then
be governed by one Council, sub groups and a Disciplinary board.
The WWAED whilst offering its full support to
the regulation of the equine dental industry, would like to highlight
other considerations relating to extra costs which may affect
our members. The setting up of a regulatory body will cost money
and who will fund this? Any administrative costs linked to providing
information to the RCVS will have to be passed onto our members.
Assuming our organisation would have representation on any regulatory
council, who will incur the cost of attending meetings? Who will
hold lists of qualified individuals that are deemed competent
to practise—if not our organisation would the RCVS incur
extra costs in setting up more database records?
Whether the RCVS and VNC should be given the power
to require continual professional development and validation
7. We are currently considering a continual
professional development training programme for our members. The
WWAED welcomes forging links with the veterinary profession in
order that new developments and ideas can be shared. At the present
time, the veterinary profession educates individuals with seminars
restricted to members of the RCVS. The WWAED suggests that access
could be granted to "qualified" equine dental professionals
in order that information is shared and professional relationships
forged. However, we do believe that handing complete powers of
validation over to the veterinary profession would not be appropriate
as it could result in them having control over what training they
think is appropriate. As our members work alongside the veterinary
profession we believe that with co-operation from both parties
a comprehensive development programme can be built which will
benefit both parties.
Whether the governing body of the RCVS and VNC
ought to include appointed lay persons as well as veterinary professionals
8. The WWAED supports this idea as it would
potentially introduce unbiased and broader views to the council.
Appropriate representatives on the governing body would ensure
that the views of all organisations providing equine dental care
be made known. As equine dentistry is a specialised field, it
would be essential that representatives are present who are regarded
as competent in their field to guide the council on matters of
expertise.
Whether the RCVS and VNC ought to have a separate
conduct committee with the powers to investigate complaints, give
warnings and to make interim orders pending proceedings
9. The WWAED has its own disciplinary procedure
should any of its members be deemed incompetent or unprofessional
whilst carrying out their job. Should we receive any customer
complaints these are investigated and the equine dentist is dealt
with in the appropriate manner. We would consider having an open
channel between the RCVS and the WWAED to report/discuss any matters
of grave mis-conduct; otherwise we feel that we are best able
to discipline our own members if deemed appropriate.
Whether the RCVS ought to have the power to delegate
specified procedures to people holding qualifications recognised
by the RCVS Council
10. The RCVS and DEFRA together with representatives
from the equine dental industry are currently discussing an Exemption
Order Certificate for Equine Dentists. There are two approved
course and examination providers in the UK, the BEVA and the WWAED.
both organisations have successfully run courses and advanced
equine dentistry examinations for the industry. The WWAED whilst
supporting the Exemption Order has voiced its concern that legislation
and examinations should govern the whole industry and not just
those performing advanced procedures. Accountability should be
across the board. As there are two organisations the WWAED recommends
that there is one comprehensive list held of qualified individuals
by the RCVS to limit confusion amongst the horse-owning public.
11. In conclusion, we would like to thank
EFRA for inviting us to comment on the proposed changes to the
Veterinary Services Act 1966, and the WWAED would like to offer
its full support.
September 2007
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