Memorandum submitted by the British Small
Animal Veterinary Association (Vet 37)
The BSAVA is the largest specialist division
of the veterinary profession and represents some 6,000 members,
the majority of whom are in general practice and who have an interest
in the treatment of small animals (dogs, cats, rabbits, rodents
and other species including pet birds, fish, reptiles and amphibians).
The BSAVA welcomes the opportunity to respond
to the specific questions posed by the Environment, Food and Rural
Affairs Committee relating to the need to replace the Veterinary
Surgeons Act.
Are the provisions of the 1966 Act out of step
with developments in the veterinary surgeon and related professions?
Since 1966 there has been an increase in the
range of animal services offered by paraprofessionals. It is appropriate
that this development should be considered, and appropriate regulation
of such groups put in place to ensure animal welfare. In parallel,
it is increasingly important to define the boundaries within which
such paraprofessionals may work, recognising the fact that the
veterinary surgeon, by virtue of training and examination, is
best qualified to ensure the welfare of the animals under their
care.
Ought there to be regulation of providers of veterinary
care other than veterinary surgeons?
The BSAVA agrees that all disciplines providing
veterinary services ought to be regulated, in the interests of
animal welfare and for the protection of the public. We also agree
that there is an advantage in veterinary surgeons, veterinary
nurses and non-veterinarians providing veterinary services being
regulated side by side, presenting a single face to users of these
services and to the wider public.
With this model all groups will have a collective
responsibility in agreeing and maintaining standards. The actions
of one group could bring all collectively into disrepute. However,
we doubt whether it will be possible to impose such regulation
on all groups offering veterinary services, or indeed to force
individuals to become members of a regulated group.
The BSAVA further has concerns that the onus
for financing the regulation of groups other than veterinary surgeons
and veterinary nurses will fall largely on the veterinary profession.
It will be important to ensure that the costs of regulation are
borne fairly according to membership and workload created by each
group.
Should the delivery of veterinary services be
regulated through a mandatory practice standards scheme, with
a professional code of ethics, rather than the RCVS regulating
practitioners on an individual basis?
The BSAVA supports the concept of clinical excellence
on both an individual and a practice basis. To this end, the BSAVA
encourages all of its members to achieve good basic practice standards,
and to aspire to develop these further with time. The BSAVA does
not believe, however, that the current practice standards scheme
should become mandatory, as this would be extremely demanding
in terms of time and resources, yet would not necessarily improve
the delivery of veterinary services nor animal welfare.
The BSAVA would instead support a Practice Code
of Ethics, which would operate in parallel with the current individual
Guide to Professional Conduct. The combination of professional
expectation on an individual and a practice should ensure good
clinical standards.
Should the RCVS and Veterinary Nurses Council
(VNC) be given the power to require continuing professional development
and revalidation?
The Association is committed to mandatory continuing
veterinary education. We would therefore broadly support a system
of self-certification of compliance with requirements for continuing
professional development, with periodic revalidation. We remain
concerned that the financial and time costs of such a scheme to
our members should not be burdensome.
Should the governing body of the RCVS and VNC
include appointed lay persons as well as veterinary professionals?
The BSAVA accepts that the RCVS and Veterinary
Nurses Council should have appointed lay members representing
the viewpoint of users and of the public at large. We feel that
these lay members should be appointed by an independent body and
not by a Government Department. There may also be an argument
for a small number of appointed members of the profession on the
Council, and for some cross-representation between Councils. However,
we feel strongly that a minimum of 50% of the members of a Council
should be elected members of the relevant profession.
Should the RCVS and VNC have a separate conduct
committee with the powers to investigate complaints, give warnings
and to make interim orders pending proceedings?
The BSAVA agree that the RCVS and VN Councils
should each have a conduct committee which is separate and distinct
from the committees involved in laying down standards for professional
regulation. Recent debate in the veterinary literature has highlighted
the flaws in the current system, whereby the same body both sets
and enforces professional standards.
Should the RCVS have the power to delegate specified
procedures to people holding qualifications recognised by the
RCVS Council
The BSAVA would broadly agree that veterinary
surgeons should be empowered to delegate appropriate acts of veterinary
surgery to a person holding a qualification recognised by the
RCVS. The process by which a qualification may become recognised,
and whether membership of a regulated group will be a parallel
requirement, will need to be carefully defined.
September 2007
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