RMB Newsletter Vol 3:4 Once-in-a-lifetime opportunity October 2003
Dear Reader,
A once-in-a-lifetime opportunity has arisen, but we need to act in the
lifetime of the opportunity before 17 December 2003.
Recently I spoke with the British government officer, Mr Paul McDonald,
who is coordinating submissions for the review of the Veterinary Surgeons
Act (the Act governing the conduct of British vets). Mr McDonald was most
helpful but, perhaps not surprisingly, he had no prior knowledge of the
pet food industry/veterinary profession scientific and consumer fraud.
After our telephone discussion I sent a letter setting out some of the
issues (see foot of Newsletter).
About 75% of veterinary time is devoted to the treatment of domestic
pets pets poisoned by the junk food diets recommended and sold by
veterinarians.
Junk food injures the health of animals in broadly three, sometimes five,
different ways.
1.) Soft canned foods and grain based kibble fail to clean teeth
giving rise to chronic oral disease and resultant production of toxins.
2.) Cooked carbohydrates, proteins and fats are toxic in differing
degrees. Absorption into the circulation through the small intestine
adversely affects several body systems.
3.) Poorly digested grains support a large population of toxin
producing bacteria in the lower bowel. Local reactions of the toxins on
the bowel lining and absorption of the toxins affect several body systems.
4.) Disease processes arising from the aforementioned insults, for
instance nephritis, hepatitis and dermatitis, give rise to further toxins
and thus further insult.
5.) Veterinary medicines prescribed for disease processes, for
instance nephritis, hepatitis and dermatitis, add to the toxic load.
Many vets appear not to know these facts but the veterinary schools,
veterinary organisations and veterinary regulators do know.
Now is our chance before 17 December to let the British Government
know so that the veterinary schools, veterinary organisations and
veterinary regulators can be held accountable for their role in
distorting the scientific evidence and promoting dietary products that
are neither suitable nor safe.
The main Web link for the Government proposals is:
http://www.defra.gov.uk/corporate/consult/vetsurgeons/index.htm
The Department for Environment, Food and Rural Affairs asks for any
other views you may have on reforming the Act. (See Clause 46 in letter
below.)
Please dont be deterred if you are not a UK resident your views still
count.
By providing the British Government with the facts - before the changes
become law - we can expect flow-on effects in other countries.
Please write/email to:
Mr Paul McDonald
VSA Team
Department for Environment, Food and Rural Affairs
Area 605
1A Page Street
London
SW1P 4PQ
Email: Paul.A.McDonald@defra.gsi.gov.uk
Fax: +44 (0)20 7904 6962
Below theres a suggested email letter that can be modified to suit your
circumstances.
If you need help with your submission please contact:
Australia: Tom Lonsdale tom@rawmeatybones.com Phone: 040 3046 464
UK: Dr Johan Joubert jojou@eye2eye.cc Phone: 077 5378 3942
UK: Roger Meacock MRCVS roger@naturalhealingsolutions.co.uk Phone: 07866
687296
USA: Alison Tyler Atyler1462@aol.com Phone: 770-757-1498
Please copy any correspondence to tom@rawmeatybones.com I shall maintain
an archive and may publish items in future RMB Newsletters.
Heres looking forward to an effective, peaceful campaign to change a
small but important part of the world.
Best wishes,
Tom Lonsdale
__________________________________________________________________________
EXAMPLE EMAIL WHICH CAN BE MODIFIED FOR YOUR PERSONAL USE
__________________________________________________________________________
To: Paul.A.McDonald@defra.gsi.gov.uk
Subject: Modernisation of Veterinary Surgeons Act
Cc: tom@rawmeatybones.com
Dear Mr McDonald,
Thank you for the opportunity to comment on the proposals for
modernisation of the Veterinary Surgeons Act.
In my opinion much vital information has been locked-up behind the pet
food curtain with resultant distortion and loss in key areas:
Pet health and welfare widespread animal suffering and needless
veterinary work
Economic costs £millions in pet food costs and veterinary activities
Human health costs diet related dog bite injuries, stress associated
with caring for chronically ill animals, sub-standard medical research etc
Environmental costs pollution issues, manufacturing and production
costs, needless pharmaceutical production
WRITE HERE COMMENTS/OBSERVATIONS/SUGGESTIONS WRITE HERE
I hope that the British Government takes due account of the failings of
the present Veterinary Surgeons Act and thereby ensures that the new Act
provides redress.
I shall be pleased to supply more information as you may require.
Thank you for your consideration.
Yours sincerely,
__________________________________________________________________________
Letter from Department for Environment, Food and Rural Affairs (DEFRA)
http://www.defra.gov.uk/corporate/consult/vetsurgeons/letter.htm
__________________________________________________________________________
24 September 2003
Dear Sir or Madam
MODERNISATION OF THE VETERINARY SURGEONS ACT 1966
1. I am writing to invite your comments on proposals to update and
modernise the Veterinary Surgeons Act 1966 (VSA). The Act provides for
the management of the veterinary profession, for the registration of
veterinary surgeons and veterinary practitioners, for regulating their
professional education and professional conduct and for cancelling or
suspending registration in cases of misconduct. It also permits
veterinary nurses to carry out medical treatment and minor surgery (not
involving entry into a body cavity) on any species of animal. It also
provides for the making of Exemption Orders allowing procedures
considered to be acts of veterinary surgery to be carried out by suitably
trained and competent persons not registered as veterinary surgeons. The
VSA designates the Royal College of Veterinary Surgeons (RCVS) as the
competent authority for supervising the veterinary profession within the
UK.
2. Since the VSA was passed there have been major developments both in
the veterinary profession and in the way veterinary services are
delivered. In the intervening period the expectations of the public have
changed and are now more demanding in terms of the services provided.
This applies to professions across the board and not just to the
veterinary profession. It is particularly the case in those professions
where there is frequent face-to-face contact, the medical professions
being the prime example. The public's perceptions have also changed in
that they now expect the professional bodies to monitor standards to
ensure that problems do not arise, rather than dealing with them when
things go wrong. It is considered that now is an opportune time for a new
modernised Act to be introduced.
The Time for Change
3. It is now over 35 years since the VSA was passed. The profession has
moved on in the intervening period both in terms of technical
developments and in skills. Users of veterinary services, and the public
in general, need to be confident that their animals are receiving the
best care and most modern approaches to treatment. They need be sure that
the regulatory bodies are setting standards that are maintained across
the profession. This means that the regulatory bodies and the profession
as a whole must be accountable and transparent in their dealings with
their customers and the public at large.
4. Many veterinarians recognise that their time may be better utilised as
leaders of multi-disciplinary teams that include veterinary nurses and
fully trained and experienced para-professionals. This enables veterinary
surgeons to spend more of their time on diagnosis and advanced medical
procedures leaving the more routine procedures to veterinary nurses and
paraprofessionals Defra recognises that there is scope for further
deregulation of the profession, but before any further liberalisation
occurs there must be systems in place to ensure the competence of the
individual para-professional. This will involve training, continuing
professional development and revalidation as necessary.
5. On the question of transparency there is increasing pressure for
greater clarity on the way the profession and RCVS operate. This is
particularly so in relation to the disciplinary procedures of the RCVS.
There have been an increasing number of complaints in recent years that
the interests of animal owners are not given sufficient weight in the
deliberations of the various disciplinary committees. While the
Government has seen no evidence to support this view there appears to be
a need for greater openness to restore the faith of clients in the
fairness of the system. Linked to this is the need to ensure that the
procedures are in compliance with human rights legislation, and that the
system provides veterinarians with an accountable and transparent
disciplinary system with access to an independent appeals procedure.
6. While some individuals and organisations have called for an
independent regulatory authority to oversee the profession, the
Government's view is that self-regulation should continue to be the
preferred option. Accordingly the RCVS will remain the competent
authority for the profession with responsibilities for the education,
registration and disciplining of veterinary surgeons in the UK.
Proposals
Council of the RCVS
Proposal 1
7. It is proposed that the Council of the RCVS should remain
approximately the same size with a membership not exceeding the current
40 members. However we are proposing a change in the composition of the
Council. The present number of council members elected from among the
members of the RCVS would be reduced from 24 to 18. The lay membership of
the Council would be increased from the current 3 to 14. Lay members
would be appointed by Defra / the Privy Council / an independent
appointments panel in consultation with the devolved administrations
through open competition and in line with the Nolan principles. Your
views on whether appointments should be through a Government department
or an independent panel would be welcome. The representation of the six
UK Veterinary Schools would be reduced from 12 to 1 or 2 (greater
representation would result in fewer elected members). The UK's Chief
Veterinary Officer would be an ex officio member, and there would be
provision for representation from the veterinary nursing profession. We
would welcome your views on the appropriate length of term for elected
members, and for the length of term, and how many consecutive terms
should be served for appointed members.
8. There is an argument that specific customer groups should be
represented on the Council. We would welcome views on this suggestion and
suggestions for representation by any specific groups of stakeholders.
Representatives from specific stakeholder groups would be included as
part of the lay membership of the Council. We would also welcome views on
how a stakeholder group should be defined. There is the question of
whether there should be provisions to ensure that there is regional
balance in representation on the Council with seats designated for
Scotland (2), Wales (1) and N. Ireland (1). We would also welcome views
on this.
OR
Proposal 2
9. We propose a reduced Council in line with developments in other
professions. This would consist of 14 elected members, a reduction from
the current 24 elected members, an increase in lay membership from 3 to
10, and a reduction in the number representing the veterinary schools
from 12 to 1 or 2 (greater representation would result in fewer elected
members). Lay members would be appointed by Defra/the Privy Council/an
independent appointments panel through open competition and in line with
the Nolan principles. Your views on whether appointments should be
through a Government department or an independent panel would be welcome.
In addition the UK's Chief Veterinary Officer would be an ex officio
member, and there would be provision for representation from the
veterinary nursing profession. We would welcome your views on the
appropriate length of term for elected members, and for the length of
term, and how many consecutive terms should be served for appointed
members.
10. There is an argument that specific customer groups should be
represented on the Council. We would welcome views on this suggestion,
and suggestions for representation by any specific groups of
stakeholders. Representatives from specific stakeholder groups would be
included as part of the lay membership of the Council. We would welcome
views on how a stakeholder group should be defined. There is the question
of whether there should be provisions to ensure that there is regional
balance in representation on the Council with seats designated for
Scotland (2), Wales (1) and N. Ireland (1). We would welcome views on
this.
11. With reduced membership the Council it may find it difficult to fill
all the College's committees with elected members of the Council. In this
situation ordinary members of the RCVS could be invited to join specific
committees, for example academics from the veterinary schools could be
invited to join the Education Committee. In all cases, however, it is
suggested that the Chairpersons of all the committees should be members
of the Council.
12. Both proposals would mean that vets constitute approximately 60% of
the membership of the Council (not including appointed members, i.e. the
CVO and the representative of the veterinary nursing profession), with
lay members constituting 30%-35%.
Supervision of Professional Competence
13. The great majority of veterinary surgeons in the UK provide a good
quality of care to the animals they treat, and deal with their clients in
a professional manner. However, as with all professions a small minority
fall below the standards the rest of the profession expect. As a result
they may put animals' lives at risk, weaken animal disease controls or
have an adverse affect on public health, resulting in damage to the
reputation of the profession as a whole. It is proposed that the RCVS
would continue to exercise powers to rule on the fitness of veterinary
surgeons to continue to practice their profession in the UK. The RCVS
will be given specific powers to determine an individual's right to
continue to be registered to practice. These powers will cover
professional competence (including the state of health of the veterinary
surgeon in question), conduct and criminal convictions of the veterinary
surgeon.
14 Legal powers will be granted to enable the RCVS to take effective
action to deal with veterinary surgeons that fail to meet the required
standards. This will protect the welfare of animals and the rights of
their owners against the failure of a veterinary surgeon to meet the
necessary professional standards. It will also protect against any
adverse effects on public health and animal disease controls. However,
these powers will need to be balanced against the human rights of the
individual veterinary surgeon concerned. It is intended that the range of
disciplinary powers currently available to the RCVS will be expanded to
provide greater flexibility when dealing with varying degrees of
misconduct and range of offences that do not constitute misconduct but
may bring into question the veterinary surgeon's fitness to practise.
15. It is proposed that the RCVS should have powers to:
A.
Issue a formal and public rebuke;
Demand a formal apology be made;
Order that professional fees be waived, reduced or refunded;
Adjudicate when the level of fees is disputed;
Require the provision of all relevant records;
In the case of the most serious allegations, suspend the right to
practice pending a hearing by the Disciplinary Committee, but with
provision for financial compensation in the case of the hearing finding
in favour of the veterinary surgeon;
B.
Make orders regarding costs;
Award compensation payments to clients;
Impose fines;
Enter and seize records when these are not provided on request;
Place restrictions on right to practice, e.g. retraining,
supervision, medical treatment, etc.;
Suspend/remove the right to practice; the Disciplinary Committee
will recommend the period before reinstatement can be considered
depending on the severity of the offence, this will range from a minimum
of 1 year to a maximum of 3 years;
C.
Issue Code of Conduct; provide advice and guidance to the
profession; failure to comply with the Code of Conduct could be cited in
any disciplinary proceedings.
16. Your views are sought on: (i) whether the Preliminary Investigation
Committee should continue to only investigate complaints and refer to the
Disciplinary Committee those they believe should be taken further; or
(ii) should they have the power to reach a decision on less serious cases
which do not constitute misconduct, and where appropriate impose
penalties? In the latter case, should the Preliminary Investigation
Committee be able to impose the penalties listed in Section 15A? Should
there be other penalties the Committee can impose? We would also welcome
your views on the required standards of proof in any disciplinary
procedures. Should this be based on 'the strong balance of
probabilities', rather than the stricter requirements of 'beyond
reasonable doubt', as required in criminal prosecutions? It may be that
different standards of proof should be obtained, depending upon the
severity of the alleged offence and the likely disciplinary action.
Previous legal advise with regard to disciplinary procedures in another
profession was, that to comply with the European Convention on Human
Rights, the most serious charges should attract a criminal standard of
proof. However, for less serious allegations it was considered that a
sliding civil standard might be appropriate.
Disciplinary Procedures
17. We are proposing that the non-veterinary membership of the Council of
the RCVS be increased substantially bringing the veterinary profession
into line with the medical and dental professions. Currently, members of
the veterinary profession have the right to appeal to the Privy Council
against decisions taken by the Disciplinary Committee of the RCVS. We are
proposing that those who have brought complaints against a veterinary
surgeon should have a similar right to appeal against a decision taken by
the Disciplinary Committee. Do you agree with this and, if so, what would
be the appropriate mechanism by which such an appeal could be heard? Your
views are also sought on whether the Judicial Committee of the Privy
Council should continue to act as the final appeals body for the
veterinary profession, or should it be brought into line with other
professions and the right of appeal to the Privy Council abolished. If
the Privy Council's role is abolished what would be the appropriate
appeals body? Should, for example, appeals be made to the High Court or
an independent appeals tribunal? Finally should there be a role for an
ombudsman to oversee the entire appeals process?
RCVS Disciplinary Committees
18. It is proposed that the current structure of the statutory committees
of the RCVS should be maintained, although there may be changes in the
way they operate. The current committees are the Preliminary
Investigation Committee and the Disciplinary Committee.
Preliminary Investigation Committee
19. It is proposed that the Committee's composition and powers will be as
follows:
The committee will have a membership of 12, consisting of six
MRCVS and six non-veterinarians. A non-veterinarian will act as
Chairperson of the Committee and have the casting vote in the case of a
tied vote;
A quorum of the Committee will be 5 so that if required two
panels might hear cases simultaneously. Each sub-group of the committee
will be constituted 50/50 as described above, and both sub-groups will be
chaired by a non-veterinarian;
Either the President or one of the two Vice-Presidents of the
RCVS will sit on the Committee;
The Committee will have the powers to hear complaints and either
dismiss them, make orders as specified in Section 15A, or pass them to
the Disciplinary Committee for further investigation and final disposal;
The Committee will investigate complaints against a veterinary
surgeon where the surgeon's competence is alleged to have fallen short of
the standards expected by the profession. It will also investigate cases
where an individual has been convicted of an offence, or where their
behaviour has been such as to bring the profession into disrepute;
A veterinary surgeon charged with an offence under the VSA will
not have the right to appeal against a decision to pass the case to the
Disciplinary Committee. However, defendants will have the right to demand
a hearing before the Disciplinary Committee should they dispute any
penalty imposed by the Preliminary Investigation Committee. Complainants
will have the right to appeal to an independent arbitrator/ against a
decision of the Committee to dismiss a case, or against any penalty
imposed should they feel it to be too lenient.
The Committee will no longer hear cases of fraudulent entry in
the register of veterinary surgeons unless the individual accused of
providing fraudulent information disputes the case.
Finally, should the hearings of the Preliminary Investigation Committee
be held in public?
Disciplinary Committee
20. It is proposed that the composition of the Disciplinary Committee and
its powers will be as follows:
It will consist of three members, two MRCVS and one non-
veterinarian appointed by open competition; the non-veterinarian will be
the Chairperson;
OR
The Committee will consist of three members, one MRCVS and two
non-veterinarians appointed by open competition; the Chairperson to be a
non-veterinarian;
OR
The Committee will consist of three members all of whom will be
non-veterinarians appointed by open competition. They will be assisted by
two veterinarians, not members of the Council of the RCVS but appointed
by the Council, who will assist the Committee by providing the necessary
technical background to cases being investigated.
OR
The Committee will consist of three members selected from a panel
of suitably qualified veterinary surgeons and lay persons appointed by
open competition. None of the members of the panel will be members of the
RCVS Council. At least one of the Committee members will be a veterinary
surgeon. (This alternative is based on the new model adopted by the GMC
and due to come into effect in 2004).
Your views are sought on these alternatives.
21. The Committee will examine all cases passed to it by the Preliminary
Investigation Committee and decide whether the allegations of failure to
maintain professional standards are justified, or whether an individual
by their actions have brought the profession into disrepute;
22. A veterinary surgeon found to have failed to maintain the standards
expected, or to have brought the profession into disrepute, will be
subject to a range of sanctions to reflect the severity of the offence as
outlined in Section 15B. The ultimate sanction will be removal from the
list of registered veterinary surgeons for a minimum of 1 year and a
maximum of 3 years before reinstatement can be considered;
23. Both the veterinary surgeon concerned and the complainant(s) will
have the right to be represented before the Committee and to give
evidence;
24. There will be an appeals procedure both for the veterinary surgeon
and the complainant;
25. We would welcome your views on whether appeals should be heard by the
Privy Council, judicial tribunal, or ombudsman. The appeal body's
decision will be final.
Registration
26. Under the current registration requirements of the VSA a graduate of
a recognised UK veterinary school, an EU/EEA national who is the holder
of a recognised European veterinary qualification, a graduate of an
overseas school recognised by the RCVS, or a graduate of an overseas
veterinary school who has passed the RCVS statutory membership
examination, are entitled to be registered to practice veterinary surgery
within the UK. They may set up their own practice immediately should they
so choose.
27. We would welcome your views as to:
Whether there should be a period under the direction of an
experienced veterinary surgeon before new graduates gain full
registration, and if so how long this period should be?
Should there be any restrictions on what procedures the newly
qualified veterinary surgeon can carry out?
If newly qualified graduates are restricted in the procedures
they can carry out who should pay their salaries?
Do you agree that newly qualified overseas veterinary surgeons
should be required to undergo the same period under the direction of a
qualified veterinary surgeon?
Should newly qualified veterinary surgeons be able gain the
necessary experience, prior to full registration, in the State Veterinary
Service, the Meat Hygiene Service, or other similar official bodies?
28. There is also the issue of the assumed omni-competence of veterinary
surgeons. Should veterinary surgeons be licensed to practice on
particular species of animal or in a particular area of the profession,
or should they, as now, be permitted to practice veterinary
surgery/medicine on all species of animals and all areas without any
further specific training? Your views on this issue would be welcome.
29. There is some concern, within the profession, that veterinary
surgeons can be identified, through the register, by animal rights
extremists. The current Act requires the RCVS to print and publish the
register, which contains names and addresses. As it stands, the
legislation (Data Protection Act and the VSA) does not give a member the
right to request his or her details to be excluded. Views would,
therefore, be welcome on whether the modernised legislation should
include a clause for veterinary surgeons working in, for example,
laboratory animal science, to have the right to request their personal
details to be omitted from the published register.
Accreditation
30. It is proposed that the RCVS continue to supervise veterinary
training in the UK, provide accreditation for UK veterinary schools and
approve courses of study and examinations. It is also proposed that the
RCVS continue to provide accreditation for qualifications obtained in
countries outside the EU.
31. The issue of the recognition of EU qualifications is still under
discussion in Brussels as part of the overall discussion on the proposed
EU Directive on recognition of professional qualifications (COM (2002)
119 final). Currently the profession is governed by EU Council Directives
78/1026/EEC and 78/1027/EEC. These establish the basic qualifications
required to practice veterinary surgery within the EU and recognise
specific qualifications awarded by veterinary schools within the current
EU 15 Member States. The final outcome of the discussions on the
Directive will need to be taken into consideration when the modernised
VSA is being drawn up.
32. Currently holders of overseas veterinary qualifications not
recognised by the RCVS may be registered provided they pass the RCVS's
membership examination. It has been suggested that a more appropriate way
of judging the competence of foreign vets would be to require them to
undergo a period of training prior to being granted registration. An
alternative would be to issue them with provisional registration enabling
them to work under supervision in an approved evaluation practice, during
which time they would be assessed for full registration. During this
period language skills could also be assessed. We would welcome your
views on whether the current system of assessment by examination should
be retained, or attendance at a training course, or a system of
provisional registration, be substituted.
Continuing Professional Development
33. It is proposed that registered practising veterinary surgeons should
be required to undertake continuing professional training and development
as determined by the Council, on advice from the Continuing Professional
Development Committee established for that purpose OR the Education
Committee. Our initial view is that it will be incumbent on each
practising veterinary surgeon to provide to the registrar of the RCVS
documentary evidence of the training undertaken every year OR 3 years OR
5 years. An alternative would be for the veterinary surgeon to be
required to keep records of CPD undertaken, and to produce those records
on demand. If it appears to the registrar that a practising veterinary
surgeon has failed to comply with the continuing training requirements
the veterinary surgeon in question will be given such time as previously
determined by the Council, to make good the training deficit. Should the
veterinary surgeon fail to complete the required training within the
given period, the registrar may/will remove the veterinary surgeon's name
from the Register until such time as the training has been completed.
Provision will be made for an appeal against the registrar's decision. We
would welcome your views on these proposals.
34. An alternative to the above proposals on CPD would be to introduce a
requirement for all practising veterinary surgeons to have a licence to
practise and to undergo revalidation on a regular basis, to demonstrate
that they remain up-to-date and fit to practise. The General Medical
Council will be introducing such a requirement. From 1 January 2005 all
doctors will require a license to practise if they wish to practise as a
doctor (including prescribing and signing statutory certificates). These
will be granted to all doctors on the GMC Register at the end of 2004 and
will indicate that the GMC believe they are properly qualified and have
to agree to take part in periodic revalidation. The GMC are proposing
that revalidation would occur at 5 yearly intervals. Doctors who practise
within an established health care organisation, e.g. the NHS, will
undergo an annual appraisal system, and provided they participate fully
in the appraisal process, they will receive revalidation without having
to collect any additional information. Doctors outside an established
health care organisation will have to demonstrate to the GMC from time to
time that they remain competent and up-to-date in their particular field
of medicine. In order to do this evidence will need to be presented that
the individual is adopting the principles of good medical practise. This
will include evidence of CPD, but the process has not yet been spelled
out in detail.
35. We are seeking views on whether the veterinary profession should
adopt similar requirements, and if so how it would be implemented.
Clearly the annual appraisal route will not be as easy to implement as
for the medical profession where the majority of doctors work in the NHS.
What would be appropriate ways for veterinary surgeons to demonstrate
their competence? There is also the question as to how frequently
revalidation should occur. Is five years an appropriate interval, or
should it be longer or shorter? There is also an issue of how vets from
countries that did not have a revalidation system would be dealt with.
This is a complex issue and we would hope for a range of views.
Definition of 'Veterinary Surgery' within the VSA
36. The VSA defines 'veterinary surgery' as meaning "the art and science
of veterinary surgery and medicine and, without prejudice to the
generality of the foregoing, shall be taken to include -
(a) the diagnosis of disease in, and injuries to, animals including tests
performed on animals for diagnostic purposes;
(b) the giving of advice based upon such diagnosis;
(c) the medical or surgical treatment of animals; and
(d) the performance of surgical operations on animals."
We would welcome views on whether this definition needs to be modified
and, if so, in what way.
Further Deregulation of Procedures Designated as Acts of Veterinary
Surgery
37. It has been increasingly recognised in recent years that there are a
number of procedures defined as 'acts of veterinary surgery' that could
be safely derogated to fully trained and qualified paraprofessionals,
including veterinary nurses.
38. Several procedures, e.g. ultrasound scanning of cattle, equine and
cattle AI, equine dental treatment, etc., have been, or are being,
deregulated. Others that have been deregulated to a certain extent may
require further deregulation or amendment. These include:
Physiotherapy, osteopathy and chiropractic treatments;
Vaccination of poultry;
Sampling of faeces;
Epidural anaesthesia for, for example, embryo collection and
transfer;
39. A number of further procedures have been suggested for deregulation,
including Tuberculin testing of cattle (which is currently the subject of
a separate consultation). However, there may be other procedures suitable
for deregulation, and we would welcome your views on the procedures
listed here and possible additions to the list.
Administration of Veterinary Nurses and Veterinary Paraprofessionals
40. Since 1966 there have been major changes in the way veterinary
services are delivered. One of the most significant of these changes has
been the growth of the veterinary nursing profession. There are now
nearly 5000 qualified veterinary nurses listed with the RCVS, while
approximately a further 4000 have obtained the necessary qualifications
awarded by the RCVS but are not currently listed. Numbers are expected to
continue to grow as suitably qualified veterinary nurses may now work
with any animal species and not just companion animals. However, the
profession is currently governed by the limited powers contained in
Schedule 3 of the VSA. At issue is the future governance of the
veterinary nursing profession. Should veterinary nurses be regulated by
the RCVS with new powers provided to regulate their conduct, or
alternatively should veterinary nursing become an independent regulated
profession? We would welcome your views on this issue.
41. As discussed above, in recent years there has been a significant
increase in the number of areas of veterinary treatment where work is
being undertaken by paraprofessionals This reflects partly developments
in the range of equipment available for diagnosis of conditions in, in
particular, farm and large animals (e.g. pregnancy of cattle), and partly
the improved skill levels and experience of the paraprofessionals
Currently paraprofessionals undertaking acts of veterinary surgery are
regulated by Exemption Orders to the VSA. These identify the necessary
training and qualifications required by non-veterinarians before they may
undertake procedures subject to Exemption Orders. The necessary training
courses and examinations are approved by Defra in consultation with the
RCVS, and Defra issues Certificates of Exemption to those who complete
the training and pass the approved examination. It is proposed that this
procedure continue. At present the numbers of paraprofessionals covered
by Exemption Orders are small, although it is anticipated that numbers
will increase. Issues on which we would welcome views are: (i) should
there be registration of paraprofessionals over and above the issuing of
Certificates of Exemption, and if so by which body; (ii) should there be
a body responsible for maintaining standards of professional conduct; and
(iii) should there be provision for re-accreditation?
42. It has been proposed that other groups, in particular Senior/Animal
Health Officers of the State Veterinary Service, should receive specific
recognition for the training they undergo. This would be along the lines
of that granted to Veterinary Nurses once they had completed a recognised
training programme. Training programmes would be drawn up by Defra in
consultation with the RCVS. We would welcome your views on this proposal.
Other Issues
43. Other issues which have been suggested as requiring consideration
during the drafting of a new Act include: (1) the issue of the regulation
of the delivery of veterinary services; (2) the regulation and/or
registration of veterinary practices; and (3) the enforcement of the
prohibition on the carrying out of acts of veterinary surgery by those
not covered by an exemption. We seek your views on the need for all or
any such provisions and who should be responsible for enforcing such
provisions.
Partial Regulatory Impact Assessment
44. Enclosed, at Appendix B, is a Partial Regulatory Impact Assessment
(RIA). Under the Government's Better Regulation initiative an RIA must be
prepared assessing the costs and benefits of compliance with any new
legislation. We are, obviously, at the very early stages of the
legislative process. However, we would be interested to receive views on
the consequences for businesses, in terms of both additional costs and
benefits, on any of the proposals set out in this consultation / RIA, or
indeed any proposals you may have for change.
45. Information on specific businesses will not be identified in the RIA,
which will be updated and amended as we progress with the modernisation
of the Act, following the consultation exercise and will reflect the
comments received. The purpose of the RIA is to ensure that all potential
consequences of the new legislation have been fully considered before
Ministers agree to introduce them. I would welcome you comments on the
RIA.
The Consultation Process
46. In this document we have laid out broad proposals for reform and
modernisation of the Veterinary Surgeons Act. Individuals and
organisations are invited to submit their comments to Defra on any of the
issues dealt with in this document, and in particular those areas where
we have specifically sought your views on important matters related to
that reform. We would also welcome any other views you may have on
reforming the Act. We would be grateful to receive your comments by 17
December 2003. These should be addressed to:-
Paul McDonald
VSA Team
Department for Environment, Food and Rural Affairs
Area 605
1A Page Street
London
SW1P 4PQ
47. If you would prefer to submit your response electronically the fax
number is 020 7904 6962. Alternatively you may respond by e-mail to:
Paul.A.McDonald@defra.gsi.gov.uk. Attachments to e-mails should be in
Microsoft Word only please. When responding please indicate whether you
are replying on behalf of an organisation or as an individual.
48. Further copies of this document are available from the above address.
Alternatively you are welcome to make photocopies.
49. In line with other consultations, and in order to inform public
debate on issues raised, Defra intends that all comments received will be
made available at the end of the consultation period, unless you
specifically state that you wish part or all of your response to be kept
confidential.
50. Responses will be placed in the Departmental Library at Nobel House,
17 Smith Square, London, SW1P 3JR (telephone 020 7238 6575). On request
the Library will supply copies of the consultation responses to personal
callers or those requesting them by telephone. If you wish to obtain a
copy of the responses you should be aware that an administrative charge
would be made to cover the costs of copying and postage. To avoid
unnecessary delays for those calling at the Library in person, it is
requested that you give the Library at least 24 hours notice of your
requirements.
51. This document is being issued by Defra to stakeholders in England,
Wales, Scotland and Northern Ireland. If you are aware of any
organisations or individuals who might be interested in receiving this
document, please let us know and we will arrange for a copy to be sent.
If you have any questions relating to this consultation please contact Mr
McDonald, at the address in paragraph 46, or telephone him on 020 7904
6588, or email him (Paul.A.McDonald@defra.gsi.gov.uk).
Yours faithfully
Tony Hughes
Animal Welfare Division
__________________________________________________________________________
LETTER FROM DR TOM LONSDALE
__________________________________________________________________________
23 October 2003
Paul McDonald
VSA Team
Department for Environment, Food and Rural Affairs
Area 605
1A Page Street
London SW1P 4PQ
Dear Mr McDonald,
MODERNISATION OF THE VETERINARY SURGEONS ACT 1966
Since 1991 a group of concerned Australian veterinary surgeons have been
campaigning against the perceived scientific and consumer fraud
perpetrated by the veterinary profession acting with and on behalf of the
artificial pet food industry. http://www.rawmeatybones.com/No_3128.html
In 1997 the matter was brought formally to the attention of the Royal
College of Veterinary Surgeons (RCVS).
http://www.rawmeatybones.com/VetResearch.html
Every year since 1997 I have stood as a candidate in RCVS Council
elections. http://www.rawmeatybones.com/elections.html My election
campaigns have focussed on the pet food scandal and each year I have
polled about 10% of the votes cast. (From 1997 until his death in 2002 Mr
Oliver Graham-Jones FRCVS, himself a long-serving former RCVS Councillor,
provided the nomination.)
Repeated calls for a full and independent committee of enquiry,
commissioned by the RCVS, have been met by blank refusal (correspondence
on file).
It is my contention that members of the Council of the RCVS, whether
individually or jointly, have protected, even perpetrated, major
scientific and consumer fraud. That before any meaningful review of the
Veterinary Surgeons Act can be accomplished there needs to be a high-
level official enquiry.
I shall be pleased to supply supporting information as you may require.
Please advise how these allegations of serious corruption can be fully
aired and what further steps need to be taken to ensure all those in
positions of responsibility are fully briefed.
Thank you for your consideration.
Yours sincerely,
Tom Lonsdale
Cc Interested parties
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