Memorandum submitted by Richard Matson
(Vet 34)
EXECUTIVE SUMMARY
Since 1966 there have been major innovations
and changes, principally for the better in the management of horse
welfare. The work carried out by paraprofessionals such as dentistry,
artificial insemination and physiotherapy is all new since the
act came into force 40 years ago. These new professional groups
need to be working alongside veterinary surgeons; their work should
be complimentary to the work of the veterinary surgeon and they
should be regulated in parallel.
The advent of horse passports opens up opportunities
for decreasing fraudulent practises, improving animal welfare
and improving the health and safety of those that ride and work
with horses. Passports are a new tool available to all horse owners
and that tool needs to be made the best use of.
It is vital that existing regulation is used
to its optimum before bringing in yet more regulation and the
ability to obtain passports at will is a case in point. Tidy up
and implement the passport for all equines policy and there will
be many benefits for animals and humans too.
Too much regulation brings a lack of respect
for all regulation, good or bad, so we must not have new rules
for the sake of it; there needs to be a very clear need and benefit
from any new regulation.
1. Whether the provisions of the 1966 Act
are out of step with developments in the veterinary surgeon and
related professions
1.1 I believe that the act has not always
kept up with the need to ensure that equine welfare and the horse
owning public have the optimum advantages that should be available
to them with the aid of new techniques and procedures. An example
of this is the increasing skills of the veterinary surgeon allowing
surgery to be undertaken for the benefit of the horse but to be
unseen after a period of time both by a would be purchaser and/or
a veterinary surgeon examining the animal on behalf of the purchaser.
1.2 Examples of this are the "Hobday"
operation and operations for colic. I was brought up to be able
to examine a horse to see if it had been hobdayed and there was
a good chance that even after several years that the scar in the
throat of the horse could be felt. Nowadays the technique for
this operation leaves little or no scar and even the best of examining
veterinary surgeons are not going to be able to tell in many cases
if a horse has had the operation.
1.3 Similarly with operations for colic
when sometimes large lengths of intestine are removed the skills
of the surgeon leave such a small scar which after a while cannot
be seen; this is especially the case with those animals which
grow a thick coat.
1.4 There are other operations, some perhaps
only infrequently carried out, which can go undetected. One such
operation, "de-nerving" may have serious consequences
for the safety of both the horse and rider should they not know
that the horse they ride has been de-nerved.
1.5 The advent of compulsory passports for
all horses gives the opportunity for all operations on equines
to be recorded in the passport. Since horses must be accompanied
by their passport when they travel to the veterinary surgery it
should be a relatively simple matter to include a "Surgical
Operation" page and for the veterinary surgeon to record
brief details of the surgery carried out.
1.6 Veterinary surgeons are in general opposed
to this record of surgery but principally because they fear that
the client may take their horse to a veterinary surgeon that was
prepared to operate without recording in the passport. If it was
a legal obligation and if it was enforced it would improve the
description of a saleable commodity by a very large degree; it
would make it much more difficult for the seller to pass on a
horse without declaring surgery.
2. Whether there ought to be regulation of
providers of veterinary care other than veterinary surgeons
2.1 In the 40 years since the Veterinary
Surgeons Act 1966 there has been a major increase in the number
of people training to be veterinary nurses; there has also been
over that period of time a proliferation of "paraprofessionals".
Both these groups of people need some regulation; currently, in
practice, a "pass" in many of these fields is a licence
for life but many having "passed" are not practicing
their new skills and may only start doing so many years hence.
Consideration should be given to insisting on filing annual returns
of work carried out in order that the use of those skills is either
used or given up.
2.2 An example of this is in the Artificial
Insemination of Equines Technicians course. I estimate that as
many as one third of those who take these course never go on to
inseminate mares; this proportion of technicians have taken the
course as a means of learning about the techniques involved (and
especially semen assessment) so that they can have a discussion
on level terms with those that do the work for them; they also
feel more confident when discussing reproduction problems in their
mares with their veterinary surgeons. But all this proportion
of qualified (but totally inexperienced) technicians can currently
start to do AI work many years after they received their training.
2.3 I believe consideration should be given
to putting all newly qualified AI technicians on an approval system
for say three years during which time annual returns of the work
done, signed by their employer and/or a supervising veterinary
surgeon, are submitted to a central authority. It is possible
that this could become self regulated by the professional bodies
which support the paraprofessionals.
3. 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
3.1 No, my experience is that the existing
system works well as seen from the layman's side of the fence;
it is also significant that there is a tendency for more vets
to work as individuals, self employed or as employees of a business
as is the case with my business.
4. Whether the RCVS and Veterinary Nurses
Council (VNC) should be given the power to require continuing
professional development and revalidation
4.1 Yes and especially if it is applied
to the new para-professional groups such as the AI technicians
and equine dentists. This comment is complimentary to my comments
in paragraph 2.
5. Whether the governing body of the RCVS
and VNC ought to include appointed lay persons as well as veterinary
professionals
5.1 Yes. It has for many years struck me
that it is odd that the RCVS does not have on its council lay
people who might be said to represent the views of their clients.
I have been fortunate to have had a very good business relationship
with the only two veterinary practices that I have used on a regular
basis in more than 40 years. However, I have experienced out dated
working procedures and attitudes with other practices over that
time.
5.2 An example of this is the current attitude
by some vets in regard to EVA testing of mares before going to
stud; while some vets exhort studs to insist on EVA blood testing
before entry to a stud some take a contrary view. One member of
the Artificial Insemination of Equines Technicians Trade Association
recently wrote as follows:
"...regarding the eva situation I have
found myself trying to educate my vet on the seriousness of the
virus earlier in the season. Is it somehow possible that the powers
that be can educate/inform our vets for us in order to prevent
`the head in the sand' approach currently being taken by the majority
of vets not just mine? Most of my mare owners have been quite
happy to have eva blood tests taken on my advice, but why do the
vets not recommend this along with the cem cert at the time? Surely
they can advise the mare owners?"
5.3 While Dr Madeleine Campbell has been
exhorting members of the Breeders Quality Mark Scheme (BQM) to
insist on it the problem arises because such a small proportion
of mares are tested before going to stud. It would appear that
the problem is greater in the north of England and one person
from Scotland said that not one of the mares visiting her stud
had been EVA blood tested. Following the Horse Race Betting Levy
Board recommendations should be a requirement for BQM members
but if it were to be done in the context of EVA testing many studs
including my own would lose a great deal of business and more
than we could afford to do. (Only 24% of mares visiting our stud
had been EVA tested prior to arrival; a risk assessment exercise
is carried out on the remainder and 5% of these were immediately
tested).
5.4 An issue such as this should surely
be discussed by the RCVS governing body with the lay representatives
giving their view which should be in line with animal welfare
nationally.
6. 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
6.1 I am not in a position to comment on
this.
7. Whether the RCVS ought to have the power
to delegate specified procedures to people holding qualifications
recognised by the RCVS Council
7.1 I am not sure what you have in mind.
What are the types of procedures that you are considering delegating?
7.2 As far as I am aware veterinary surgeons
do already have the power to authorise certain procedures to be
carried out by others.
7.3 What such delegating should not do is
allow veterinary surgeons to help individuals circumnavigate the
current training of technicians for qualifications such as AI,
dentistry etc. This would lead to a two tier qualification and
confusion.
September 2007
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