Memorandum submitted by the Oxford College
of Equine Physical Therapy (VET 29)
1. Thank you for the opportunity to present
evidence to this inquiry.
2. Oxford College of Equine Physical
Therapy (OCEPT) has for the past five years been offering
an educational programme in the manipulative treatment of animals,
primarily horses. The course is managed and run by both registered
and retired chiropractors, with substantial input from a veterinarian
and other suitably qualified ancillary staff. The course actually
has its origins in post-graduate chiropractic education, having
evolved from the course in animal chiropractic, which was run
by Oxford College of Chiropractic for approximately 10 years prior
to the formation of OCEPT.
3. The primary method of animal manipulation
taught is the McTimoney-Corley technique, but please note that
this College is in no way associated with the McTimoney College
of Chiropractic in Abingdon.
4. The course is currently twelve months
in duration, functioning on a part-time, mixed-mode educational
basis, and is presented throughout with due reference to the Veterinary
Surgeons Act, which at this time dictates that the treatment of
animals can only be administered with veterinary approval.
5. Tutorials are held at The Witney Stud
Farm, now a part of Abingdon and Witney College, which has specialist
facilities for equestrian training courses. Students also make
visits to the Bristol Veterinary College Equine Unit, and the
Hartpury Equine College Therapy Unit.
6. Applicants to the course are required
to possess a significant background of appropriate prior academic
achievement, preferably to degree level, with a clear motivation
to pursue the course. People below the age of twenty-five must
have a first degree on entry, but in common with most educational
institutions consideration is also given to motivated, mature
people with a demonstrable record of achievement in non-academic
areas, where a high level of determination and will to succeed
can be evidenced. However, prior equine experience and a general
competence in handling horses is a necessary prerequisite for
all applicants.
7. Graduates of the OCEPT programme are
awarded a Diploma from the College that bestows the title "Animal
Manipulator", and thus become eligible to join the Association
of McTimoney-Corley Spinal Therapists (AMCST—who have also
made a separate submission to this inquiry).
8. With regard to your specific terms of
reference, we would like to submit the following:
Are the provisions of the 1966 Act out of step
with developments in the veterinary surgeon and related professions?
9. The professional expertise of
any person providing any kind of veterinary care needs to be assured
in the following four principal areas:
— competence in the administration
of that particular mode of treatment/therapy;
— knowledge of any contraindications
and possible adverse side-effects of that particular mode of treatment/therapy;
— competence in assessing when
that particular mode of treatment/therapy both is and is not indicated;
and
— knowledge of referral procedures
where further opinion or other veterinary input is required.
10. The ethical conduct of any person
providing any kind of veterinary care needs to be assured in the
following principal areas:
— that they confine their activities
to those disciplines in which they do have professional expertise;
— that the welfare of the animal
is their primary concern;
— that they are honest and open
in all dealings with the owners or guardians of the animals that
they see;
— that they do not make any definite
claims to the efficacy of the treatment/therapy that they offer
that cannot be substantiated; and
— that they do not make any claims
of superiority of their particular form of treatment/therapy over
other viable alternatives where that superiority cannot be substantiated.
11. With strict adherence to all of the
above points relating to both expertise and conduct, it would
appear to be appropriate for any such veterinary service to be
administered without requiring the (mandatory) approval of a veterinary
surgeon, and as such the Veterinary Surgeons Act 1966 may require
some changes.
12. The course of education provided by
OCEPT is designed to produce animal manipulative therapists who
do meet all of the above points relating to both expertise and
conduct.
13. Many past OCEPT graduates have established
good working relationships with veterinary surgeons, who are evidently
confident in the form of manipulative therapy that they provide.
Should there be regulation of providers of veterinary
care other than veterinary surgeons?
14. For the protection of members of the
public, and for their animals, we would say that the introduction
of regulation for veterinary practitioners of all persuasions
appears to be a sensible one.
15. In reality its introduction will most
likely be fraught with problems, as those with aspirations of
"elite" status may well view such a process as a vehicle
to impose unnecessary educational standards, thus eliminating
other entirely competent practitioners from the equation, whilst
those devoid of ambition will seek to evade the imposition of
anything to which they may become accountable. Neither of these
extremes will ultimately benefit the people or the animals that
such regulation will be meant to protect.
16. Any significant changes to the current
situation, and certainly the introduction of anything mandatory,
must only be implemented with the provision of a substantial period
of transition, and the facility to "grandfather-in"
those people who are already established in practice.
17. Any initial or ongoing costs to the
individual practitioner of introducing and maintaining a mandatory
form of regulation must be minimised as far as possible.
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?
18. The introduction of regulation together
with an associated mandatory practice standards scheme/code of
ethics for providers of veterinary care other than veterinary
surgeons appears to be sound in principle. However, care must
be taken to ensure that.
19. Any stipulated minimum educational standards
are appropriate for that particular mode of treatment/therapy,
and that those standards are dictated by practical reality rather
than by the academic and/or professional ambitions of a minority.
20. Where there is significant clinical
disparity between the application of that particular mode of treatment/therapy
to humans as opposed to animals then the setting of minimum educational
standards for the treatment of animals must not be unduly influenced
by those established for the treatment of humans.
21. The content of any Code of Practice/Conduct,
or similar, for a particular mode of treatment/therapy must again
be based on practical reality rather than on the desires of an
academic/professional minority.
22. If a single Code of Practice/Conduct,
or similar, were to be implemented to cover all forms of veterinary
care, it must be suitably "broad-brush" to cover the
great diversity of veterinary care available.
23. Given the great diversity mentioned
above, thought should be given to whether the existing professional
associations/organisations might continue to be best placed to
police the activities of practitioners in the field, and to what
part they might continue to play post-regulation.
Should the RCVS and the Veterinary Nurses Council
(VNC) be given the power to require continuing professional development
and revalidation?
24. Mandatory continuing professional development
(CPD) is common in many other professions, and the imposition
of a reasonable requirement here for those providing veterinary
services should not be perceived as unduly onerous by those with
a genuine interest in what they do. However, again, given the
diversity within the veterinary services field, considerable latitude
must be allowed in the content of such CPD, and the minimum annual
stipulated CPD hours must also be dictated by practical reality
rather than by the academic and/or professional ambitions of a
minority.
25. The current (2007) OCEPT student's
"Terms of Agreement" already stipulates that: "The
Student, when qualified, shall make a commitment to a process
of continuing education to keep abreast of developments in animal
manipulative therapy, to further his/her own professional development,
and to comply with any requirements resulting from any future
changes to the Veterinary Surgeons Act or other legalities governing
the treatment of animals".
26. Revalidation is potentially a far more
significant issue than CPD and serious thought must be given to
the mechanism for its implementation, and to ensure that it does
not develop into yet another tool for any "elitist"
faction to cynically exploit to eradicate competition.
Should the governing body of the RCVS and the
VNC include appointed lay persons as well as veterinary professionals?
27. The governing body responsible for any
aspect of any regulated veterinary activity should comprise a
balanced mix of professional expertise and those who can provide
a strong, objective and politically neutral perspective in the
conduct of any of its affairs. In theory, an appointed lay person
should be able to provide this input. In reality, great care must
be taken over their selection to ensure that they do in fact possess
these essential qualities.
Should the RCVS and VNC have a separate conduct
committee with the powers to investigate complaints, give warnings
and make interim orders pending proceedings?
28. The need for any such committee will
be driven by the detail in the terms under which statutory regulation
is introduced, and the content of its associated Code of Practice/Conduct,
or similar, against which any practitioner's performance would
be judged.
29. If regulation of all veterinary services
does happen, and it can be shown that the provision of such a
committee will have the potential to speed-up processes, and/or
reduce the associated costs, then this must be considered.
30. Thought should also be given to the
contribution that the existing professional associations/organisations
might be able to offer here, perhaps in an initial case "screening"
capacity or in the execution of other associated duties.
31. Again, given the great diversity of
veterinary care available, such a "core" committee may
be appropriate, but with the provision to co-opt external personnel,
perhaps from the existing professional associations/organisations,
where the core committee lacks the specific knowledge or expertise
needed to properly assess a particular case.
Should the RCVS have the power to delegate specified
procedures to people holding qualifications recognised by the
RCVS Council?
32. Referring back to paragraphs 9-11 of
this submission, where the particular expertise and conduct of
practitioners can be assured there appears to be no reason why
any such procedure should not be considered for delegation.
EXECUTIVE SUMMARY
33. Oxford College of Equine Physical
Therapy has a long and well-established history of successfully
training suitable students in the field of animal manipulative
therapy. Graduates gain access to membership of the Association
of McTimoney-Corley Spinal Therapists, who have also made a separate
submission to this inquiry.
34. From the perspective of an institution
that currently falls outside of the existing regulatory framework,
we would say that the introduction of regulation for veterinary
practitioners of all persuasions appears to be a sensible one.
However:
35. The introduction of any mandatory changes
to the current situation must only be implemented with the provision
of a substantial period of transition, and the facility to "grandfather-in"
those people who are already established in practice.
36. It must be ensured that any mandatory
changes are realistic, manageable, cost-effective, and are not
adversely influenced by the wishes of a professional/academic
minority at the ultimate expense of the animals and members of
the public, whose interests such changes will be required to protect.
37. The setting of any minimum educational
standards, and the formulation of any Codes of Practice/Conduct,
or similar, must be based on practical reality rather than on
the desires of an academic/professional minority. The setting
of minimum educational standards for the treatment of animals
must also not be unduly influenced by those established for the
treatment of humans.
38. An ongoing role for the existing professional
associations/organisations should be considered, and the professional
composition of any particular conduct committee must be tailored
to the particular case being considered.
39. If changes are implemented, then this
College will seek to participate in any developmental discussions
in good faith, and from a position of common-sense and sensible
compromise. We have confidence in the form of manipulative therapy
that we teach, and in the competence of the practitioners that
we produce. However, we will also acknowledge the limitations
of our methods (as should everybody) and our willingness to consider
sensible changes in the education that we provide.
September 2007
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