Memorandum submitted by the Worshipful
Company of Farriers, the Farriers Registration Council and the
National Association of Farriers, Blacksmiths and Agricultural
Engineers (Vet 36)
Submissions have been invited on the proposed
changes to the 1966 Veterinary Surgeons Act. The responses below
represent the views of a Working Group set up by:
(a) The Worshipful Company of Farriers;
(b) The Farriers Registration Council; and
(c) The National Association of Farriers,
Blacksmiths and Agricultural Engineers.
The Working Group (two representatives) would
be happy to provide evidence in person to the Committee if required.
EXECUTIVE SUMMARY
Farriers work closely with veterinary surgeons,
and all Registered Farriers were invited to provide input to the
consultation.
The Worshipful Company of Farriers, the Farriers
Registration Council and the National Association of Farriers,
Blacksmiths and Agricultural Engineers support the case for updating
the Veterinary Surgeons Act 1966. They feel that there is a need
for a proportionate degree of regulation for providers of veterinary
care other than veterinary surgeons. Farriery itself is already
regulated by the Farriers (Registration) Act 1975, which it is
hoped to update in the near future with a Regulatory Reform Order.
The possibility of subsuming farriery within
a new Veterinary Services Act has been considered in the RCVS's
preliminary consultations, but farriers are deemed professionals
in their own right rather than veterinary para-professionals.
The three main farriery bodies mentioned above would be willing
to consider the possibility of farriers being subject to an over-arching
multi-disciplinary committee which carries out the disciplinary
function in relation to animal welfare on behalf of all its contributing
bodies but would need to see detailed proposals as to how such
a body would be constituted and funded before committing themselves.
The possibility of updating the existing farriery
legislation with a Regulatory Reform Order has reduced the urgency
of farriers being included in any possible forthcoming legislation
relating to veterinary surgeons.
SUBMISSION
1. Whether the provisions of the 1966 Act
are out of step with developments in the veterinary surgeon and
related professions
The Farriers (Registration) Act 1975 makes provision
for veterinary surgeons as well as farriers to practise farriery.
It would be helpful if any new Veterinary Surgeons Act made clear
that while it is appropriate for veterinary surgeons to be able
to perform acts of farriery in the course of treating equines,
the practice of farriery as a regular and gainful activity should
be restricted to individuals on the Register of Farriers.
2. Whether there ought to be regulation of
providers of veterinary care other than veterinary surgeons
A clear definition of what consititutes veterinary
care is needed. On the assumption that it is intended to cover
work that could result in an adverse effect on animal welfare
(eg trimming the hooves of horses that are going barefoot, or
trimming the feet of cattle), it is recommended that this should
be regulated. The basis of this regulation should be that anyone
carrying out this work for gain or reward should have been properly
trained, should have passed a recognised test of competence and
should be bound by a professional code of conduct. Owners or their
agents should be exempt from this restriction in relation to their
own animals.
Farriers are already regulated by their own
Act.
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
No comment.
4. Whether the RCVS and Veterinary Nurses
Council (VNC) should be given the power to require continuing
professional development and revalidation
Yes. Mandatory CPD is both practicable and desirable
but may not be practicable if there is no satisfactory method
of enforcement. Mandatory revalidation is desirable in theory
but may have adverse effects on clients (and therefore animals)
if it leads to a reduction in competent practitioners who are
unable or unwilling to undertake the necessary CPD. This is particularly
true in relation to small businesses and sole operators and/or
in areas of the country where there is already a shortage of the
relevant practitioners.
The Farriers (Registration) Council would like
to be able to make provision for mandatory CPD within the Farriers
(Registration) Act but believes that widespread acceptance of
a voluntary system is a pre-requisite. A voluntary system is currently
being strongly promoted by the three main bodies concerned. We
would therefore recommend a power to require mandatory CPD and/or
revalidation for all practitioners in relation to animal welfare
but with discretion as to when the mandatory power should be brought
into effect left to the individual professional bodies/agencies
concerned.
5. Whether the governing body of the RCVS
and VNC ought to include appointed lay persons as well as veterinary
professionals
The general principle is endorsed with the added
proviso that some of the persons should be independent as well
as lay. Thought needs to be given to how these individuals are
identified, recruited and appointed.
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
It is assumed that this is intended to refer
to a committee that can react to minor complaints more quickly
and with less cost than a full Disciplinary Committee. The concept
is endorsed, but it may be difficult in practice to introduce
streamlining without jeopardising a fair hearing.
7. Whether the RCVS ought to have the power
to delegate specified procedures to people holding qualifications
recognised by the RCVS Council
Yes. For example farriers are frequently the
best qualified and most readily available individuals to carry
out some procedures (such as removing abscesses in the hoof) that
might normally be regarded as veterinary surgery.
The Worshipful Company of Farriers;
The Farriers Registration Council; and
The National Association of Farriers, Blacksmiths
and Agricultural Engineers
September 2007
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