Memorandum submitted by the Equine Podiatry
Association (UK) (Vet 41)
EXECUTIVE SUMMARY
The EPA represents the largest group of professional
equine hoof trimmers in the UK.
The 1966 Act was written in a previous climate
where veterinary surgeons were the only profession actively involved
in the diagnosis and treatment of equine conditions. In the 21st
century, a significant number of new professions allied to the
veterinary sciences have evolved, especially in the area of equine
healthcare. As such the 1966 Act is no longer fit for purpose
as it does not allow for these allied professions to independently
diagnose and treat equine conditions. There is a need for changes
to the legislative framework that recognise both the new allied
professions and potential further allied professions that may
evolve in the future.
At present the regulation of the new professions
is somewhat variable with some groups undertaking high quality
self-regulation and some doing nothing at all. Self-regulation
should certainly be encouraged and this can be done by providing
recognition and encouragement for those professions that adopt
high quality self-regulation. At present, legal regulation of
these professions is not felt to be necessary by the EPA and could,
if not handled carefully, prove to be counterproductive.
A solution needs to be found to the problem
of how to allow the new professions to diagnose and treat within
their competencies. Such practices need to be carefully controlled
while still allowing the flexibility for future innovation. The
concept of delegating limited subsets of veterinary powers to
those professions that are deemed appropriately trained and self-regulated
seems to be a good solution to this problem. The EPA would welcome
developments in this direction.
BACKGROUND
1. Farriers have traditionally had a monopoly
on hoofcare in the UK, although a significant number of horses
(especially young stock and brood mares) have always been trimmed
by owners. In recent years, horse owners have become interested
in the concept of working horses without shoes and a new group
of hoofcare professionals has sprung up to meet this demand. There
are various schools of hoof trimming of which Equine Podiatry
is one.
2. The term Equine Podiatry, as used by
the Equine Podiatry Association, is used to describe the study
and application of both the science of the equine foot and practices
(including, but not limited to, trimming) that promote the health
of the equine foot.
3. Equine Podiatrists (EPs) are professionals
who provide an holistic hoofcare service to horse owners. The
service is mainly aimed at horses that are not shod, but some
aspects of the service are also applicable to horses that are
shod. As well as trimming hooves, EPs also provide guidance on
all aspects of horse welfare that may have an impact on the health
of the feet. This may include advising on such areas as: the fitting/use
of removable hoofboots; the level of work that a horse is capable
of given the current state of the feet; the role of infection
in hoof pathologies; approaches to controlling such infections;
the role of diet in the health of the feet and approaches to optimising
the diet for foot health.
4. The Equine Podiatry Association (EPA)
is a professional body representing the largest group of professional
equine hoof trimmers in the UK. The EPA was set up, amongst other
things: to promote the role of Equine Podiatry in improving equine
welfare; to maintain and publish a register of qualified EPs;
to promote good practice and to set and maintain standards of
professional conduct and competence in Equine Podiatry; to organise
and maintain schemes for the regulation and discipline of the
EPA's members in matters of professional conduct and to provide
a means of redress to those who feel that they have a professional
grievance with a member of the EPA.
5. The following sections outline the EPA's
response to each of the terms of reference of the inquiry.
Whether the provisions of the 1966 Act are out
of step with developments in the veterinary surgeon and related
professions
6. There is currently a significant level
of innovation in the equine welfare industry. New approaches to
equine healthcare are being adopted and this trend has seen the
rise of a number of new professions such as equine dentists, equine
osteopaths and various schools of hoof trimmers. The 1966 Act
was not written with this in mind and so fails to meet the demands
of the 21st century.
7. Specifically the 1966 Act reserves the
right to diagnose and treat conditions solely to veterinary surgeons.
Even before recent developments, this potentially led to grey
areas and anomalies. For example, if an owner feels that a horse
has poor quality hooves and decides to use a dietary supplement
to gain an improvement, this could potentially be seen as diagnosis
and treatment and hence be illegal.
8. With the rise of new equine professions,
the problem of diagnosis/treatment has become more pronounced.
For example, a qualified Equine Podiatrist is fully competent
to recognise a hoof infection such as thrush and white line disease
and recommend a suitable topical application for treatment. But
this again falls foul of the 1966 Act.
9. The new diversity of professionals working
in the area of equine health should be welcomed. It allows certain
areas of healthcare, traditionally not given sufficient coverage
by the veterinary sciences to be covered by professionals who
are specialist in their own areas. The new professions bring much
benefit in the form of knowledge, skills, experience and new approaches
to the veterinary science community. The presence of these new
professions encourages innovation.
10. There is a need for a realignment of
the law so as to recognise that it is appropriate and indeed often
desirable for a limited range of conditions to be diagnosed/treated
by other than veterinary surgeons. In some situations, it may
be appropriate for an owner to diagnose/treat (eg minor injury).
In other situations it may be appropriate for other professions
to diagnose/treat (eg a farrier or hoof trimmer diagnosing/treating
thrush).
Whether there ought to be regulation of providers
of veterinary care other than veterinary surgeons
11. The EPA supports the idea of regulation
where this has the effect of raising and ensuring standards.
12. Given the recent emergence of new professions,
it is clear that this is an area subject to significant levels
of innovation. It is important that any new approach to regulation
does not set the current status quo in aspic, but allows for the
development of new professions.
13. Self-regulation may well be the best
approach to regulating emerging professions allied to the veterinary
sciences. Such self-regulation needs to be of a high standard
so as to allow service users to have confidence in the quality
of the professionals they use.
14. For emerging professions to effectively
self-regulate, they need to have an incentive for professionals
to subscribe to the appropriate professional bodies. Recognition
by the established professions may well prove to be a key such
incentive. The EPA would encourage the established professions
to work closely with emerging professional bodies and provide
some form of formal recognition of those that set high enough
standards of professional conduct, etc.
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
15. This topic does not directly affect
the EPA or its membership. The EPA has no opinion in this area.
Whether the RCVS and Veterinary Nurses Council
(VNC) should be given the power to require continuing professional
development and revalidation
16. This topic does not directly affect
the EPA or its membership. The EPA has no opinion in this area.
Whether the governing body of the RCVS and VNC
ought to include appointed lay persons as well as veterinary professionals
17. This topic does not directly affect
the EPA or its membership. The EPA has no opinion in this area.
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
18. This topic does not directly affect
the EPA or its membership. The EPA has no opinion in this area.
Whether the RCVS ought to have the power to delegate
specified procedures to people holding qualifications recognised
by the RCVS Council
19. As discussed above, the 1966 Act creates
grey areas and anomalies with reference to diagnosis and treatment
that particularly affect the emerging equine healthcare professions.
This is also already an issue for farriers, particularly those
working as remedial farriers. The EPA feels strongly that the
diagnosis and treatment of certain conditions relating to the
equine foot should be allowed by those specialist professionals
who have demonstrated sufficient competence in those areas.
20. The concept of delegation of a limited
subset of veterinary procedures to allied professionals who hold
appropriate qualifications is one that very neatly addresses this
problem.
21. The exact subset of procedures relevant
to each qualification would need to be carefully controlled, for
example by using National Occupational Standards to capture the
level of competence recognised in each profession. This would
also allow for a natural evolutionary path as new professions
mutate over time.
22. The delegation of procedures should
only be allowed to those professions that adopt suitably high
standards of self-regulation.
23. The EPA has, from its inception, been
set up with the aim of providing a professional framework to the
highest standard that would be acceptable to the traditional equine
healthcare professions. The EPA is working closely with LANTRA
with the aim of developing a National Occupational Standard for
equine hoof trimming. The EPA is very keen to work with those
developing policy in regard to proposed new legislation so as
to help provide a more appropriate legislative framework in the
future for professions allied to the veterinary sciences
September 2007
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