Memorandum submitted by the Dogs Trust
(Vet 40)
EXECUTIVE SUMMARY
1. Dogs Trust considers that changes in
both the veterinary field and external influences such as entry
into the EU and devolution make changes in the Veterinary Surgeons
Act imperative. In addition the introduction of the Animal Welfare
Act has redefined some issues making the 1966 Act out of step
with more modern views.
2. We consider that proper regulation of
paraprofessionals is long overdue. The lack of any measure of
competence of some paraprofessionals, such as behaviourists, causes
us considerable concern.
3. Dogs Trust now deals with a number of
corporate practices. We consider they should be directly regulated
and that could in some measure be achieved by a practice standards
scheme. However, we also consider that individual veterinary surgeons
must remain responsible for their personal actions as well.
4. CPD is an essential activity as the pace
of change in technical matters is considerable. However, we caution
whether the concept of revalidation is a practical proposition.
5. Dogs Trust considers that the inclusion
of a proportion of lay persons throughout the governance of the
veterinary profession engenders confidence in the general public
that could not be achieved by any other means.
6. We see no advantage in separating totally
the regulation of conduct from the governance of the profession
and consider this would increase bureaucracy and costs with no
clear benefit.
7. We are content that RCVS can delegate
some procedures to persons who have shown to be competent in them.
However, we caution against restricting more complex procedures
to veterinary surgeons with some form of higher qualification
as we do not consider it necessary or cost effective.
INTRODUCTION
8. Dogs Trust is pleased to respond to the
Select Committee's inquiry on the Veterinary Surgeons Act. Dogs
Trust is the UK's largest canine welfare charity. We care for
over 15,000 dogs a year through our network of 17 Re-homing Centres.
We also provide subsidised neutering and microchipping in the
areas of greatest need, provide veterinary care for the dogs of
people in housing crisis (the Hope Project), provide care for
the dogs of women fleeing domestic violence (the Freedom Project),
and provide financial assistance for owners on state benefits
whose dog requires emergency treatment (the Emergency Help Fund).
9. Inevitably a number of dogs brought to
our Re-homing Centres are diagnosed with chronic diseases that
make them very unattractive to potential adopters. To enable us
to re-home such dogs we run a foster dog scheme under which the
adopter pays all the routine costs of keeping the dog but Dogs
Trust pays for the veterinary care of the specific condition or
all veterinary care with very old dogs. This enables the dogs
to be re-homed which dramatically improves their quality of life
and leaves space in our Re-homing Centres for more dogs that need
our help. Consequently we pay vets' bills for over four thousand
foster dogs.
10. Because of this high level of activity,
Dogs Trust is a significant user of veterinary services. We have
contracted veterinary practices working in all our Re-homing Centres,
and practices providing subsidised neutering and veterinary care
for dogs in the Hope and Freedom Projects. Many other practices
use the Emergency Help Fund and care for our foster dogs.
11. Dogs Trust total veterinary spend is
in excess of £5 million per annum through practices. We therefore
consider that we have a significant interest in the manner in
which the profession functions. The comments in this submission
will be restricted to those matters that concern dogs as that
is our field of interest.
Whether the provisions of the 1966 Act are out
of step with developments in the veterinary surgeon and related
professions
12. There is no question that the world
has changed dramatically since 1966. The availability and nature
of veterinary services has altered with the advent of improved
diagnosis and treatment modalities and a significantly more business-like
approach to running practices, including the advent of corporate
practices. Inevitably this has affected the manner in which practices
are managed on a day to day basis. In addition the entry of the
UK into the EU and, in more recent years, devolution have had
significant effects on the running of practices.
13. The Animal Welfare Act 2006 defines
an animal as "a vertebrate other than man" (Section
1(1) and suffering as "physical and mental" (Section
62). Both definitions are at variance with the Veterinary Surgeons
Act but are based on sentience. As the latter aims to protect
animal welfare as well as the general public, the definitions
at least need to be reviewed.
14. The Act continues to provide effective
protection of animal welfare and so we do not consider a review
is essential. However, in view of the fairly radical changes in
medicine, science and social attitudes, Dogs Trust considers that
changes are urgently required in the Veterinary Surgeons Act.
Whether there ought to be regulation of providers
of veterinary care other than veterinary surgeons
15. A significant proportion of dogs received
into the care of Dogs Trust have some sort of issue with their
behaviour. Consequently we use the services of a variety of so-called
behaviourists, both as employees and as consultants. The quality
of behavioural advice we receive and the apparent competence of
the behaviourists is very variable and yet there is no formal
recognition of the term behaviourist. We have seen a number of
examples where advice from such persons has had a significant
adverse effect on the welfare of the dogs they have "treated".
16. Although these are the only paraprofessional
services with which Dogs Trust has significant contact, we are
aware that other unregulated "treatment" services exist
provided by persons other than veterinary surgeons and unauthorised
by Schedule 3 of the Act. We are concerned that the absence of
any measure of competence or discipline in such services may have
significant adverse effects on the welfare of the dogs they claim
to "treat".
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
17. Two of the practices providing veterinary
care at Dogs Trust Re-homing Centres are corporately owned practices.
Both provide a level of service that is acceptable to us and our
dealings are, in the main, with the veterinary surgeons at the
practice. However, we are aware of the influence of non-veterinary
higher management on occasions and it seems to us that some policy
decisions are made on business grounds with veterinary and welfare
issues as a secondary concern.
18. However, Dogs Trust would be concerned
if every veterinary surgeon was not accountable for their personal
actions. Even in a well managed corporate veterinary practice
it would be possible for an individual veterinary surgeon to act
unprofessionally and the consequence of that should not be left
to internal disciplinary measures in the practice. We therefore
consider that a combination of regulation of the individual veterinary
surgeon and the practice in which they work would give the best
protection to the animals under their care.
Whether the RCVS and Veterinary Nurses Council
(VNC) should be given the power to require continuing professional
development and revalidation
19. We have already mentioned the issue
of the competence of paraprofessionals and it is axiomatic that
the competence of those already regulated is as important. Given
the pace of change in technical veterinary issues, Dogs Trust
cannot conceive that some form of CPD should not be required.
However, care should be taken that the implementation of such
a requirement is not overly bureaucratic.
20. Having accepted the need for CPD, Dogs
Trust is concerned that it should be relevant to the area of veterinary
surgery in which the person is active. However, if revalidation
were to be introduced we consider the potential consequences for
individuals could be significant. For example, if the veterinary
surgeon is in solely companion animal practice, would a revalidation
process require them to maintain a level of competence in production
animal practice? If so, we have difficulty in seeing how this
might be achieved in an already pressurised profession. Equally
if revalidation concentrated on a practitioner's primary role,
would they be excluded from treating other species? Dogs Trust
therefore considers that revalidation of such a broad based discipline
as any of the veterinary and allied professions not to be a practical
proposition.
Whether the governing body of the RCVS and VNC
ought to include appointed lay persons as well as veterinary professionals
21. To engender public confidence Dogs Trust
considers it imperative that lay persons are involved at all levels
of the governing of the profession. While we have no specific
experience, we receive not infrequent enquiries from members of
the public about the actions of individual veterinary surgeons,
and the involvement of lay persons in the governance of the profession
give us some comfort that matters are dealt with appropriately.
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
22. Dogs Trust understands that the current
disciplinary procedure is laid down in the Act. We can see no
advantage to issues of conduct by individual veterinary surgeons,
paraprofessionals, or by practices being dealt with by a separate
body as the establishment of such a body would lead to an inevitable
increase in costs and bureaucracy.
Whether the RCVS ought to have the power to delegate
specified procedures to people holding qualifications recognised
by the RCVS Council
23. We are not clear what this question
wishes to know. If the aim is to enquire whether some procedures
may be delegated to paraprofessionals who are authorised by RCVS
or a similar body that monitors competence and has disciplinary
procedures, Dogs Trust would support such a proposal. We have
already commented on behaviourists as an example. We consider
that establishing a structure under which paraprofessionals may
work without such a procedure would be illogical.
24. If the question refers to more complex
acts of veterinary surgery, such as complex orthopaedic procedures,
Dogs Trust has reservations about limiting the ability of any
veterinary surgeon to undertake a specific procedure. We find
it difficult to see how such a restrictive system could function
without some form of validation. We are, of course, aware that
veterinary surgeons are able to specialise and gain further qualifications
in specific disciplines. However, not all veterinary surgeons
choose to follow that career path and yet remain competent to
undertake relatively complex procedures. From a purely pecuniary
view we also consider any such proposal would be likely to lead
to a significant increase in the cost of already expensive complex
procedures. Many dog owners would then be unable to afford the
procedures and their dog's welfare would be adversely affected.
September 2007
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