Memorandum submitted by the British Horse
Society (Vet 39)
1. The British Horse Society (BHS) represents
the interests of the 4.3 million people in the UK who ride or
who drive horse-drawn vehicles. With the membership of its Affiliated
Riding Clubs, the BHS is the largest and most influential equestrian
charity in the UK.
2. The membership of The BHS comprises of
representatives of every field of equestrianism. It is the provider
of the most widely acknowledged and respected equestrian qualifications
and operates a riding school and livery yard approval scheme that
sets the benchmark for nationally acceptable standards. Through
its network of qualified instructors, approved yards and members,
The BHS has an input into the lives of a very high proportion
of the estimated 1.3 million horses in the UK.
3. The BHS is also heavily involved in equine
welfare through a programme of education aimed at preventing welfare
breaches and promoting best practice. A nationwide network of
volunteers carry out site visits on behalf of The BHS where equine
welfare is thought to have been compromised. BHS Welfare offers
a helpline service that receives thousands of calls and e-mails
annually. This facility is open to members and non-members alike
with enquiries covering the full gamut of equine topics. As a
consequence, The BHS is in a uniquely privileged position to represent
the views and experiences of UK horse owners and users.
SUMMARY
4. The BHS is of the opinion that the Veterinary
Surgeons Act is largely in step with the equine veterinary profession.
However, the growth of paraprofessions such as Equine Dental Technicians
(EDTs) and Equine Artificial Insemination Technicians (EAITs)
has led to concerns that the 1966 Act is no longer adequate to
regulate all parties involved in the veterinary care of equids.
5. The experiences of The BHS suggest that
there are grounds for concern over welfare breaches that have
taken place when horses are treated by paraprofessionals. There
is also concern that there is a lack of public awareness of the
regulatory framework that currently exists.
6. The BHS therefore considers that there
is a need for transparent and robust regulation of all those involved
in equine veterinary care, including paraprofessionals. Failing
to adequately regulate paraprofessionals is likely to result in
further welfare breaches, particularly if these professions continue
to grow at their current rate.
7. The BHS is in full support of regulation
of veterinary nurses adhering to the suggestions made by the RCVS.
8. Where the regulatory framework is contravened,
there is a clear need for a transparent and flexible range of
disciplinary measures. Disciplinary measures must be seen by the
public to be independent and should offer a range of sanctions
to include warnings and remedial measures. These procedures should
apply to veterinary surgeons, veterinary nurses and those involved
in the paraprofessions.
9. The BHS does not support a mandatory
practice standards scheme and considers that self-regulation,
and the regulation of individuals, is the preferred option to
ensure adequate standards of delivery of veterinary services.
10. The BHS supports the notion that the
RCVS and VNC should have the power to require compulsory continuing
professional development. The BHS is also in favour of revalidation
of veterinary surgeons and nurses through satisfactory completion
of continuing professional development.
11. In the interests of transparency and
public confidence, The BHS is in full support of the presence
of appointed lay persons on the governing bodies of both the RCVS
and the VNC.
12. The instigation of conduct committees
for both the RCVS and VNC is supported by The BHS. However, it
is considered that, to ensure public confidence, these committees
must be entirely separate from their parent councils. The BHS
would strongly support the presence of appropriate lay persons
on any such committee.
13. The BHS would be in favour of a good
deal more flexibility in the disciplinary process and would like
to see a greater range of sanctions available to a conduct committee
than currently exist. However. The BHS would not be in favour
of a conduct committee having the power to impose interim orders
on individuals pending disciplinary proceedings.
14. The BHS does not support the proposal
that veterinary surgeons be able to delegate specified procedures
to individuals holding qualifications recognised by the RCVS.
This proposal is not thought to be a satisfactory means of regulations
paraprofessionals and may place veterinary surgeons in the invidious
position of being legally responsible for work in which they have
played no part.
Question 1. Are the provisions of the 1966
Act out of step with developments in the veterinary surgeon and
related professions?
15. The BHS believes that, despite manifold
developments, the 1966 Act remains largely in step with the equine
veterinary profession.
16. However, the growth of related professions
in recent years has highlighted inadequacies in the 1966 Act.
A number of recognised paraprofessions, such as Equine Dental
Technicians (EDTs), Equine Artificial Insemination Technicians
(EAITs) and equine chiropractors, now exist. Such paraprofessions
do not require the exponents to be qualified veterinary surgeons
and, as such, are not fully regulated by the 1966 Act.
17. The BHS regularly receives complaints
and concerns from horse owners about the aforementioned paraprofessional
groups. This highlights a lack of public awareness of the regulatory
framework that currently exists. Furthermore, The BHS considers
the 1966 Act does not provide sufficient regulation of paraprofessional
groups and is inadequate to protect public confidence in veterinary
and related professions.
18. The BHS believes that there is a need
for more transparency in disciplinary procedures for both veterinary
surgeons and those involved in paraprofessions. Disciplinary procedures
must be seen by the public to be independent and should offer
a range of outcomes and sanctions to include warnings and remedial
measures.
Question 2. Should there be regulation of
providers of veterinary care other than veterinary surgeons?
19. The BHS is very strongly of the opinion
that there is a need for robust and transparent regulation of
all providers of veterinary care whether veterinary surgeons or
those in differently qualified, but associated, roles.
20. The 1966 Act is thought to provide an
adequate definition of veterinary surgery that should not be changed.
The performance of acts of veterinary surgery should be restricted
to veterinary surgeons and fully regulated, suitably qualified
individuals carrying out specified veterinary procedures.
21. The BHS considers that any regulatory
framework must be extended to cover all aspects and providers
of veterinary care and should not be restricted to veterinary
surgeons and nurses. Failing to provide adequate regulation of
paraprofessions such as EDTs and EAITs is likely to result in
compromises to equine welfare. The BHS is already aware of significant
numbers of welfare breaches relating to paraprofessions highlighting
a need for a comprehensive and enforceable regulatory framework
applicable to paraprofessionals as well as to veterinary surgeons
and nurses. The BHS takes the view that failing to provide suitable
regulation is likely to result in more numerous, and potentially
serious, breaches of equine welfare.
22. The BHS is in full support of regulation
of veterinary nurses adhering to the suggestions made by The RCVS.
Question 3. 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?
23. Many equine veterinary practices are
relatively small practices situated in rural areas. The BHS is
therefore concerned that the cost of a mandatory practice standards
scheme would be difficult for these practices to bear. Should
this be the case there are two possible outcomes, neither of which
The BHS considers desirable. The costs of a mandatory scheme may
result in compromises in the service provided by veterinary practices
or may be passed on to clients, resulting in certain procedures
being pushed out of their financial reach. Either outcome could
be to the detriment of equine welfare.
24. A mandatory practice standards scheme
may appear to be desirable but the levels of dedication and commitment
displayed by equine veterinary surgeons do not suggest that one
is necessary. The BHS therefore, on balance, considers that a
combination of a voluntary practice standards scheme and the regulation
of individuals is sufficient.
Question 4. Should the RCVS Council and VN
Council be given power to require continuing professional development
and revalidation?
25. The BHS is unequivocally in support
of mandatory CPD for all veterinary professionals. Furthermore,
The BHS supports revalidation with the proviso that this be based
on satisfactory completion of CPD as stipulated by the RCVS and
VN Councils.
Question 5. Should the governing body of
the RCVS and VNC include appointed lay persons?
26. In the interests of transparency and
public confidence, The BHS is in full support of the presence
of appointed lay persons on the governing bodies of both the RCVS
and the VNC. The BHS suggests that the current lay representation
on the RCVS Council be extended and that it be introduced to the
VN Council.
Question 6. Should the RCVS and VNC have
a separate conduct committee with powers to investigate complaints,
give warnings and to make interim orders pending proceedings?
27. The BHS considers that the instigation
of conduct committees for both the RCVS and VNC to be desirable.
The establishment of conduct committees is likely to enable effective
enforcement of, and increase public confidence in, the regulatory
framework.
28. However, for such committees to be truly
effective, The BHS believes that they must be entirely separate
from their parent councils. It would not be conducive to public
confidence were individuals permitted to serve both on the parent
council and the conduct committee.
29. The BHS would strongly support the presence
of lay persons on any newly established committee. The appointment
of all committee members must be a transparent process and the
terms of reference robust enough to ensure public confidence.
30. The BHS would be in favour of a good
deal more flexibility in the disciplinary process and would like
to see a greater range of sanctions available to a conduct committee
than currently exist. The aim of a conduct committee must be to
maintain public confidence in the veterinary profession and safeguard
both the public's interests and animal welfare.
31. The BHS would not support conduct committees
having the power to impose interim orders pending proceedings.
The infrequency of genuine instances of professional misconduct
concerning equine veterinary practitioners suggests that such
powers would not achieve a great deal more than having a serious
impact on the finances, and public standing, of individuals subsequently
found to be innocent of professional misconduct.
Question 7. Should the RCVS have the power
to delegate specified procedures to people holding qualifications
recognised by the RCVS Council?
32. The BHS has serious concerns over the
regulation of professions that surround and compliment veterinary
professionals. Such paraprofessions are perhaps more prevalent
within equine veterinary care than that of other species. There
is great need for robust and thorough regulation of these paraprofessions;
anything other than this is likely to have negative consequences
for equine welfare.
33. Whilst it would seem that a team of
paraprofessionals led by a veterinary surgeon would provide the
best care options for equids, The BHS is concerned that this places
too great an onus on the lead surgeon who may find themselves
legally responsible for the work of the paraprofessionals.
34. If paraprofessionals are sufficiently
regulated this may not be of consequence but it is difficult to
see how this level of regulation can be satisfactorily achieved
for all paraprofessionals. However, if this were feasible, with
adequate protection afforded to veterinary surgeons, The BHS would
be in favour of the proposal.
September 2007
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