CDB "Reform of Veterinary Surgeons Act" CAMPAIGN
Link to DEFRA consultation detail here
"Animal Welfare Bill" CAMPAIGN
Proposals to update legislation covering veterinary surgery were unveiled by Defra in September 2003.
The consultation paper recognises that the Veterinary Surgeons Act (1966) is in need of modernisation and it invited comments on proposed changes.
Among a range of issues, the consultation invited views on was " Deregulation of designated 'acts of veterinary surgery' to trained and competent para-professionals".
Thank you for your letter of 13 th October inviting us to submit our views concerning proposed changes to the Veterinary Surgeons Act 1966. We have pleasure in offering the following response to your consultation.
1.1 We note from your letter that there is a desire both within Government and within the veterinary profession to proceed further with the deregulation of veterinary medicine, thereby allowing appropriately qualified lay people to undertake minor procedures. This would enable veterinary surgeons to focus more closely on diagnosis and advanced veterinary procedures, so enhancing animal welfare overall.
1.2 We applaud the steps which the Government has already taken in pursuance of this objective. Recent legislation has both opened up the generality of veterinary practice to new groups of professionals and specified particular procedures that may be undertaken by suitable qualified individuals. An example of the former is the VSA (Schedule 3 Amendment) Order 2002 which authorised veterinary nurses to undertake minor non-intrusive surgery, while the latter is exemplified by the VSA (Rectal Ultrasound Scanning of Bovines) Order 2002 which allowed lay people to obtain 'Qualified Scanner Operator' status and thus operate pregnancy detection equipment in cattle. Another example is the deregulation of Equine dental procedures to appropriately trained para professionals.
1.3 The Council of Docked Breeds fully supports this approach, and suggests that the docking of dogs' tails is a minor procedure which could be so deregulated.
2 Tail Docking
2.1 Docking is the customary or prophylactic shortening of the tail. The procedure is undertaken both in the case of farm animals and in dogs. The CDB concerns itself solely with the latter.
2.2 Docking of dogs' tails has been undertaken for many hundreds of years, and certainly since specific dogs have been line bred in order to perform specialised tasks, for example those related to hunting and herding. The object of the procedure is to prevent future tail damage in many breeds which, if left with full tails are susceptible to tail damage, and to prevent perianal fouling, particularly in long-coated breeds. The need for tail docking in these breeds has been well established and is recognised both by the Kennel Club and by country sports organisations such as the British Association for Shooting and Conservation and the Countryside Alliance.
2.3 Prior to 1 st July 1993 docking was mostly carried out by experienced breeders. However, on that date a VSA Schedule 3 Amendment Order came into force, removing docking from the list of treatments and operations which may be carried out by unqualified persons. It may be noted that the amputation of dew claws, widely considered to be a more serious procedure than docking, remains exempted under Schedule 3.
2.4 Currently, prophylactic docking may be carried out only by a registered veterinary surgeon before a puppy's eyes are open, which normally occurs at around 10 days of life. The earlier a puppy is docked the better, and many vets like to carry out the procedure before 3 days of age. However, in some small breeds it can be left until the pups have reached 5 days of age. Docking can involve a surgical excision or the placing of a specialised rubber band at the required length on the tail. The blood supply to the end of the tail is thus constricted, and the end of the tail comes away within about three days.
3 Register of Lay Docking Practitioners
3.1 The Council of Docked Breeds supports the principle that docking should remain regulated insofar as it is undertaken by experienced, skilled and competent persons. In this way, the welfare of dogs is better safeguarded.
3.2 We submit that the only circumstances in which animal welfare is compromised by docking is when it is undertaken illegally by untrained persons, generally on puppies which are well in excess of the age at which the procedure may properly be carried out. A number of such cases have resulted in prosecutions. These cases appear often to occur when a breeder or owner has been unable within the narrow time frame available for prophylactic docking, which is literally a few hours, to find a registered veterinary surgeon willing to dock. This difficulty is exacerbated in the remoter rural areas where the use of dogs for sporting purposes and pest control is commonplace. Where litters are not docked because a registered veterinary surgeon cannot be found in time, then the dogs' future welfare may be compromised by tail injury. Overall, therefore, the availability of a wider pool of appropriately trained and registered individuals entitled to dock would serve to improve animal welfare.
3.3 We therefore propose a Register of Lay Docking Practitioners. Admission to the Register would be open to skilled professionals such as dog breeders of long standing and experience, accredited gamekeepers, dog trainers and persons of a similar nature. Individuals seeking for their names to be added to the Register would have to demonstrate
That they had attended a course of instruction approved by Defra and were familiar with and competent in approved docking techniques
That they had docked a given number of litters under supervision
That they kept a record of all litters docked
3.4 We offer no specific suggestion at this stage as to the composition of the course that might be envisaged, save that it might be administered and overseen by persons recognised in the field of veterinary science, pedigree dog breeding and the use of dogs for sporting purposes. We are prepared to put together a training programme administered by veterinary professionals however, we would be pleased to discuss this matter further in due course if the concept of a Register of Lay Docking Practitioners were to find favour with Ministers.
3.5 Ministers may also feel that the practice of dew claw removal, which can currently be carried out on whelps by any layperson, would also benefit from being regulated and a practice only able to be carried out by veterinary surgeons or persons regulated under the above register.
4 The Council of Docked Breeds
4.1 The Council of Docked Breeds (CDB) was founded in 1991 as the successor to an earlier body, the Council for Docked Breeds, which was previously involved in negotiation with Government and other parties over the 1991 amendment to Schedule 3 of the VSA regarding the docking of dogs' tails. The CDB has over 18,000 members who breed, own or support the customarily docked breeds.
4.2 The CDB's objective is to maintain the option of breeders to have their whelps legally docked.
4.3 The CDB, through its contacts within the veterinary profession, provides advice to members on how they may have their litters legally docked, by placing them in contact with supportive registered veterinary surgeons. It represents the interests of breeders and owners of docked breeds, and where necessary it assists with the defence of lay persons or veterinarians who are unjustly accused in relation to legislation or regulations concerned with the docking of dogs' tails.