Memorandum submitted by the National Association
of Agricultural Contractors (Vet 31)
Founded in 1893, the National Association of
Agricultural Contractors (NAAC) represents contractors in the
UK who supply all types of land-based services to farmers, government,
local authorities, sports and recreational facilities.
It is committed to representing the interests
of its members at national and European level; it will offer information
and advice; promote the services of its members and assist contractors
in providing a professional and competitive service to farmers
and the community. I will base our comments around the activities
of the NAAC and our member's activities.
1. EXECUTIVE
SUMMARY
1.1 The NAAC would support the regulation
of lay-persons allowed to carry out paraprofessional operations.
1.2 It would also support the proposal to
introduce lay-persons on the RCVS Council to give greater independence
and an impartial view.
1.3 It is important that an independent
party can have the power to delegate specified procedures to people
holding qualifications recognised by the RCVS Council. This should
not be the RCVS.
2. Regulation of providers of veterinary
care other than veterinary surgeons
2.1 The NAAC would support the regulation
of lay-persons allowed to carry out paraprofessional operations.
2.2 This should apply to "acts of veterinary
surgery" that could be safely derogated to fully trained
and qualified paraprofessionals. The NAAC believes that procedures
which do not require a veterinary diagnosis could be potentially
deregulated.
2.3 We would suggest examples such as equine
scanning, cattle foot trimming, sheep foot trimming, freeze branding,
artificial insemination, blood testing of sheep.
A good example is The Veterinary Surgery (Rectal
Ultrasound Scanning of Bovines) Order 2002 (Statutory Instrument
Number 2002 No 2584), which permits trained and competent non-veterinarians
to carry our rectal ultrasound scanning for the purpose of detecting
whether cows are pregnant. This is an area the NAAC has supported
Defra in ensuring that the industry is properly trained and professional.
We would support the need for professionally qualified laypersons
taking on other such procedures.
2.4 There must, however, be caution with
the cost of training as some of these specific operations have
a limited number of lay operators and small numbers of trainees
can mean very expensive training due to economy of scale. We would
ask that this be considered when prescribing training.
The NAAC has been very supportive in the development
of the certification of cattle scanners in regard to the Exemption
Order. However, we are now concerned that new entrants may struggle
(or find it virtually impossible) to get qualified as it appears
difficult to get booked onto a new entrants course.
2.5 The NAAC is very clear that record keeping
requirements of lay operators must be in line with veterinary
surgeons to ensure that the para-professionals can operate on
a level playing field with the vets—in terms of paperwork,
training and costs to ensure fair competition.
2.6 The NAAC would urge that any new changes
do not require those para-professionals that have already invested
significant finance and time into becoming qualified are not undermined
by changes to legislation (eg cattle scanning operators).
It is very important that those who have been
trained must be allowed to continue to operate. We would not wish
to see a process whereby operators had to be retrained or had
additional costs to remain in practice.
2.7 We would support the training of lay
persons but would question the need to have these persons on a
"register" if additional costs were to be incurred.
It is important that a record of qualified persons is available
for customer cross-checking but this could be held by a training
organisation eg National Proficiency Test Council, or even an
organisation such as the NAAC.
The NAAC is in the process of developing an
independently audited Assured Land-Based Contractor Scheme which
will be a positive way forward to ensure that "Assured contractors"
are properly trained and qualified. I would be pleased to supply
additional information on this Defra-funded project if requested.
3. Whether the governing body of the RCVS
and VNC ought to include appointed lay persons as well as veterinary
professionals
3.1 We support the proposal to introduce
lay-persons on the RCVS Council to give greater independence and
an impartial view, particularly if considering disciplinary issues.
The NAAC would welcome involvement, in terms of para-professional
representation.
This is important to ensure a balanced view
to ensure that lay operators can compete fairly with vets.
4. Whether the RCVS ought to have the power
to delegate specified procedures to people holding qualifications
recognised by the RCVS Council
4.1 The NAAC believes that the Defra delegation
of lay-powers has been a success.
We are concerned that if the RCVS need to delegate
specific procedures this may result in unfair competition—as
effectively the RCVS would be taking work away from their own
members which may not be a well-supported vote within RCVS membership!
This should therefore be done by independent
group such as Defra.
I hope that our comments will assist you and
that you will not hesitate to contact me if you require any further
information.
September 2007
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